1. Introduction

In United States v. Dustin Hatcher (11th Cir. Aug. 18, 2025) the Eleventh Circuit confronted a recurring question in Internet-sting prosecutions: How much evidence must the Government offer to prove that a defendant knew or believed he was dealing with a minor? The case arose from a “FetLife” undercover operation in which an agent told Hatcher, in a single text message, that his “niece is 14.” Despite receiving no additional age-related confirmations—and despite photographs and a voice that sounded adult—Hatcher travelled from Georgia to Florida for a sexual rendez-vous and was arrested.

Hatcher moved for judgments of acquittal under Fed. R. Crim. P. 29, arguing the Government’s proof of the mens rea element was fatally thin. The district court disagreed, and the jury convicted him of:

• Attempted enticement of a minor, 18 U.S.C. § 2422(b); and
• Travel with intent to engage in illicit sexual conduct, 18 U.S.C. § 2423(b).

The Eleventh Circuit affirmed, establishing a clear—though unpublished—rule: a single, explicit disclosure of the victim’s minority, read in context with the defendant’s subsequent sexual communications and travel, suffices to meet the knowledge requirement for both §2422(b) and §2423(b) at the sufficiency-of-the-evidence stage.

2. Summary of the Judgment

Applying de novo review to the denial of a Rule 29 motion, the panel (Rosenbaum, Luck, and Tjoflat, JJ.) held:

• The Government’s case—though “slight in quantity”—allowed reasonable jurors to conclude Hatcher believed he was dealing with a minor.
• Once that inference was permissible, the remaining elements (specific intent, substantial step, and interstate travel) were uncontested.
• Accordingly, the district court properly denied the motions for judgment of acquittal, and the convictions stand.

The court reiterated familiar standards: evidence is viewed in the Government’s favor, verdicts are upheld if any reasonable construction supports them, and circumstantial proof is adequate so long as conclusions rest on “reasonable inferences, not mere speculation.” On that foundation, the panel concluded that the single text message plus continued erotic dialogue, agreement to meet, and actual travel carried the Government’s burden.

3. Analysis

3.1 Precedents Cited and Their Influence

The judgment leans heavily on a line of Eleventh Circuit authority that emphasizes deference to jury fact-finding in sufficiency challenges:

• United States v. Capers, 708 F.3d 1286 (11th Cir. 2013) – recited for the de novo standard and Government-favoring inference rule.
• United States v. Gillis, 938 F.3d 1181 (11th Cir. 2019) – specified the two-element test for §2422(b) attempts (specific intent + substantial step).
• United States v. Hersh, 297 F.3d 1233 (11th Cir. 2002) – discussed §2423(b) mens rea (purpose of engaging in illegal sex with a minor).
• United States v. Mendez, 528 F.3d 811 (11th Cir. 2008) – warned that inferences, not speculation, must support convictions based on circumstantial evidence.
• United States v. Peters, 403 F.3d 1263 (11th Cir. 2005) and United States v. Bell, 678 F.2d 547 (5th Cir. Unit B 1982) (en banc) – underscored judicial restraint: courts cannot displace jury choice among competing reasonable inferences.

By weaving these cases into a tight analytical chain, the panel reaffirmed a principle of practical importance: Defendants in undercover operations face an uphill climb on appeal if at least one explicit, direct age disclosure entered the communication stream and was “received.”

3.2 Legal Reasoning

The panel’s reasoning proceeds in four steps:

1. Direct Evidence of Age Disclosure. The “14-year-old” text was undisputedly transmitted and logged on Hatcher’s device; metadata showed it was opened.
2. State of Mind Inferred from Subsequent Conduct. Immediately after receiving the disclosure, Hatcher (i) continued sexually explicit texting, (ii) spoke to the supposed minor, (iii) reassured her about pregnancy, and (iv) arranged and undertook interstate travel.
3. Absence of Consumption Doesn’t Defeat Knowledge. Although nothing on Hatcher’s phones showed prior child-sex interest, the court held that possession of corroborating child-pornography is not a statutory element. The jury could still infer knowledge from the charged episode alone.
4. Pictures/Voice Apparent-Age Argument Rejected. The district court conceded the images and voice sounded adult, but the panel deferred to the jury’s contrary factual inference, citing the settled rule that appellate courts do not re-weigh credibility or plausibility.

3.3 Impact on Future Litigation

Although unpublished and therefore non-precedential under 11th Cir. R. 36-2, the opinion will almost certainly be persuasive in several areas:

• Sting-Operation Design: Law-enforcement agencies may feel fortified in using a single, prominent age disclosure without repeated confirmations, knowing the Eleventh Circuit has validated such minimalism.
• Rule 29 Strategy: Defense counsel will need to confront the reality that quantity of age references may matter less than the presence of one explicit disclosure combined with immediate sexual-activity planning.
• Mens Rea Litigation: Arguments focused on “apparent age” (photos, voice) carry less sway when the communication record contains an explicit textual age statement that the defendant acknowledged by continued engagement.
• Inter-Circuit Dialogue: The decision aligns the Eleventh Circuit with similar holdings in the Fifth (United States v. Farmer), Sixth (United States v. Sorrell), and Ninth Circuits (United States v. Meek) where single disclosures sufficed, potentially influencing national uniformity.

4. Complex Concepts Simplified

• Judgment of Acquittal (Rule 29): A request made during and after trial asking the court to enter a verdict of “not guilty” on the ground that no rational juror could convict based on the evidence presented.
• Specific Intent vs. Knowledge: “Specific intent” under §2422(b) requires a purpose to persuade a minor to engage in sex, while “knowledge” means the defendant was aware (or believed) the person was a minor. Hatcher contested only the latter.
• Substantial Step: Conduct that strongly corroborates criminal intent—here, continued sexual dialogue and driving across state lines.
• Reasonable Inference vs. Speculation: A factfinder may draw logical conclusions from evidence (e.g., if message received + continued sexual chat → he read it), but cannot rely on fanciful guesswork.
• Non-Argument Calendar: The appeal was decided without oral argument, usually reserved for cases deemed straightforward on the briefs.

5. Conclusion

United States v. Hatcher crystallizes an important evidentiary principle in undercover child-exploitation cases: a single, unambiguous disclosure of a victim’s minority—if coupled with swift, sexually charged follow-up and concrete travel plans—will ordinarily satisfy the Government’s burden to prove the defendant’s knowledge or belief that he was engaging a minor.

The decision reinforces robust deference to jury determinations and signals that appellate courts will not second-guess plausible inferences about a defendant’s state of mind merely because the sting used adult-appearing decoys or minimal age reminders. For prosecutors, the case lowers the risk of reversal in “one and done” disclosures; for defense counsel, it highlights the necessity of attacking the credibility or authenticity of that lone disclosure early and aggressively. In the broader legal landscape, Hatcher stands as a concise yet potent affirmation of the judiciary’s willingness to uphold child-enticement convictions even on sparse—but explicit—evidence of age awareness.