Thomas Tso v. United States

A “statute of limitations reflects a legislative judgment that, after a certain time, no quantum of evidence is sufficient to convict. Stogner v. California, 539 U.S. 607, 615 (2003). The general statute of limitations of five years ensures fair and just proceedings. The general statute of limitations prevents defendants from having to mount a defense despite, due to the passage of time, faded memories, lost evidence, or witnesses who moved, became ill, or died. I. Does the phrase “an offense involving the sexual or physical abuse, or kidnaping, of a child” mean even a non-child abuser or kidnapper faces a lifetime threat of prosecution if their offense “involves child abuse” under the Tenth Circuit’s case-specific approach?