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legislative history indicating that Congress intended
to apply § 3283 to a wide range of crimes against
children. See Weingarten, 865 F.3d at 60; Schneider,
801 F.3d at 196.
The purposes underlying the categorical approach
do not apply here either. For statutes dealing with
prior convictions, “[t]he categorical approach serves
‘practical’ purposes: It promotes judicial and adminis-
trative efficiency by precluding the relitigation of past
convictions in minitrials conducted long after the fact.”
Moncrieffe v. Holder, 569 U.S. 184, 200-01 (2013). In
the context of § 3283, there is no prior conviction to
assess, and the jury will determine in the first instance
whether “the defendant engaged in the applicable
abusive conduct.” Weingarten, 865 F.3d at 60. Maxwell
nonetheless contends that using a_ case-specific
approach for § 3283 would be impractical because the
Government would need to prove conduct beyond the
elements of the offense. It may be true that this
approach requires the Government to prove some
additional facts, but any statute-of-limitations defense
presents factual issues (including, at least, when the
alleged conduct took place). This is not a serious
practical problem and does not justify setting aside the
statute’s language and apparent purpose.
Maxwell relies primarily on Bridges v. United States,
346 U.S. 209 (1953), to urge this Court to cast
Weingarten aside. The Supreme Court in Bridges
addressed a statute that extended the limitations
period for defrauding the United States during the
Second World War. In that case, the Supreme Court
first concluded that making false statements at an
immigration hearing was not subject to the extended
limitations period because it lacked any pecuniary
element as required by the statute. Id. at 221.Then, as
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