United States v. Munoz-Ortenza, 563 F.3d 112 (5th Cir. Mar. 18, 2009) ("We need not decide here whether "minor" as used in the enumerated category of "sexual abuse of a minor" means those under sixteen versus those under seventeen. We can say that "minor" in this context does not include all persons under eighteennamely, seventeen-year-olds. We are mindful that in many contexts a minor is defined as a person under eighteen. See Blacks Law Dictionary 997 (6th ed. 1990) ("In most states, a person is no longer a minor after reaching the age of 18 . . . ."). However, in the unique crime-of-violence context, we must follow the Taylor common-sense approach.").
jurisdiction:
Fifth Circuit