Appeal from the United States District Court
for the Western District of Michigan at Marquette.
No. 2:15-cr-00018-1—R. Allan Edgar, District Judge.
Argued: February 2, 2017
Decided and Filed: June 12, 2017
Before: GIBBONS, COOK, and KETHLEDGE, Circuit Judges.
KETHLEDGE, Circuit Judge. In February of 2014, the eight year-old victim in this case,
whom we refer to as KV, accused her seventeen year-old uncle, whom we refer to as JAS, of
sexually abusing her on tribal land. Specifically, she said that JAS had vaginally raped her,
though she did not use that term. The FBI soon interviewed KV, who described the assault to an
interviewer who had conducted more than 5,000 such interviews. JAS was thereafter charged
with an act of juvenile delinquency, to wit, sexual abuse of a child under the age of twelve in
violation of 18 U.S.C. § 2241(c). The district court held a bench trial under 18 U.S.C. § 5032
and found beyond a reasonable doubt that JAS had sexually assaulted KV as charged. Although
the Sentencing Guidelines would have recommended a life sentence had JAS been an adult, his
maximum sentence as a juvenile was only five years of “official detention,” see 18 U.S.C.
§ 5037(c)(2)(A), and the district court sentenced him to three. JAS now appeals, arguing that the
district court improperly admitted the video of the victim’s FBI interview and that the evidence
at trial was insufficient to support the finding that he sexually assaulted KV. We affirm.