United States v. Anthony Ray Lawrence

Holding: The Eleventh Circuit affirmed the conviction, holding that the jury was not required to unanimously agree on which specific state offense underlay the federal attempt charge.
Vote: Per Curiam decision affirming the district court's judgment.
Practical effect: This decision reinforces that federal prosecutors may charge defendants under Section 2422(b) based on multiple potential state predicate offenses without needing to secure a unanimous jury finding on which specific state law was violated.

United States v. Anthony Ray Lawrence

March 23, 2026 ·2:23-cr-00439-MHH-NAD-1 ·Per Curiam · By James Taylor

The Eleventh Circuit affirmed a conviction for attempting to entice a minor to engage in sexual activity. The court held that jury unanimity is not required regarding which specific state offense underlies the federal charge.

Background

Anthony Ray Lawrence appealed his conviction for attempting to entice a minor to engage in sexual activity in violation of 18 U.S.C. Section 2422(b). He argued that the district court should have required the jury to specify in a special verdict form which underlying state offense supported his conviction.

The court’s reasoning

The court relied on its precedent in United States v. Jockisch, which held that when the government relies on multiple potential state predicate offenses to convict a defendant under Section 2422(b), the jury need not unanimously agree about which sex offense the defendant’s intended conduct would have violated. The court further noted that Lawrence’s argument that Jockisch was wrongly decided is foreclosed by the prior-panel precedent rule.

What it means going forward

This decision reinforces that federal prosecutors may charge defendants under Section 2422(b) based on multiple potential state predicate offenses without needing to secure a unanimous jury finding on which specific state law was violated.