Precedents Cited

The Judgment meticulously examined several key precedents that shaped the court’s reasoning:

• TAYLOR v. UNITED STATES, 495 U.S. 575 (1990): Established the categorical approach, emphasizing that courts must rely solely on the statutory definitions of prior offenses without considering the underlying facts.
• Shular v. United States, 140 S.Ct. 779 (2020): Highlighted that the categorical approach could vary based on statutory language, distinguishing between generic and conduct-based analyses.
• Kaufmann v. United States, 940 F.3d 377 (7th Cir. 2019): Affirmed that broader state definitions relating to the federal statute could qualify as predicate offenses under § 2252(b)(1).
• Mellouli v. Lynch, 575 U.S. 798 (2015) and Ruth v. United States, 966 F.3d 642 (7th Cir. 2020): Addressed the interpretation of "relating to" in other statutory contexts, arguing for more constrained applications.
• Pugin v. Garland, 599 U.S. 600 (2023): Reinforced the broad interpretation of "relating to" in the context of immigration law, supporting expansive applications of statutory language.

These precedents collectively influenced the court's stance on interpreting the statutory language "relating to" within § 2252(b)(1), advocating for a broad, ordinary meaning that encompasses state offenses overlapping with federal definitions, even if state laws are more expansive.

Legal Reasoning

The court employed the categorical approach to determine whether Liestman's prior Wisconsin conviction qualified as a predicate offense under § 2252(b)(1). This approach mandates that the definitions of prior offenses are compared solely based on their statutory language, irrespective of the specific circumstances of each case.

Central to the court's reasoning was the interpretation of the phrase "relating to" within the enhancement statute. Drawing from Morales v. Trans World Airlines, 504 U.S. 374 (1992), the court upheld that "relating to" should be construed in its broad, ordinary sense, meaning any offense that bears a connection to the enumerated federal conduct. This interpretation aligns with the majority of circuit courts, promoting uniformity across federal and state legal frameworks.

The court further distinguished contrasting interpretations presented in cases like Mellouli and Ruth, emphasizing that context-specific legislative intent plays a pivotal role. In the absence of conflicting legislative directives, the default broad interpretation prevails.

Applying this framework, the court concluded that Wisconsin's § 948.12(1m), despite being broader in scope by criminalizing access in addition to possession and encompassing a wider range of explicit conduct, sufficiently "relates to" the federal offense. The inclusion of "accessing" was deemed functionally similar to "possessing," and the expanded definition was viewed as complementary rather than contradictory to federal law.

Impact

This judgment reinforces the broad application of federal sentencing enhancements based on state convictions that share a connection with federal offenses, even if state laws are more expansive. The affirmation solidifies the categorical approach's reliance on statutory language over factual distinctions, thereby:

• Encouraging coherence between federal and state criminal statutes.
• Facilitating enhanced penalties for repeat offenders across jurisdictions.
• Establishing a consistent framework for interpreting "relating to" in federal enhancements, potentially influencing future cases involving diverse statutory language.

However, the dissent highlights the ongoing debate regarding the breadth of such interpretations, suggesting potential future challenges and calls for more nuanced judicial discretion based on legislative intent.