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Anton Joseph Lazzaro v. United States

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 23-3098, 23-3411 · judgment February 25, 2025


Certiorari denied · October 6, 2025
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Does a person who engages in otherwise lawful, consensual sex with a 16 or 17-year-old dating partner commit “sex-trafficking” if the person gives unconditional gifts to the date? May a person be convicted under 18 U.S.C. § 1591(a), for the sex trafficking of a minor without knowledge that a minor would be caused to engage in a commercial sex act?

Counsel of record

For petitioner
Daniel L. Gerdts
Daniel L. Gerdts, Lawyer

For respondent
D. John Sauer
Solicitor General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Oct 06 2025
    Petition DENIED.
  2. Aug 27 2025
    DISTRIBUTED for Conference of 9/29/2025.
  3. Aug 20 2025
    Waiver of right of respondent United States to respond filed.
  4. Aug 04 2025
    Petition for a writ of certiorari filed. (Response due September 8, 2025)