Doe v. Reed

Background

Jane Doe brought a civil action under 18 U.S.C. § 2255, a federal statute that allows certain people who were minors when they were victims of specified crimes to seek damages. Doe alleged that James Marvin Reed sexually assaulted her several times in the Philippines between September and December 2007, when she was 14. She alleged that she became pregnant as a result and later gave birth to Reed’s child. She also alleged emotional distress and effects on her education, health, and employment. DNA testing confirmed that Reed was the child’s biological father.

Reed pleaded guilty in the District of Minnesota to one count of engaging in illicit sexual conduct in a foreign place under 18 U.S.C. § 2423(c). He was sentenced to 72 months in prison followed by 15 years of supervised release. At the time of this order, he was serving his sentence at a residential reentry center.

Motion and legal standard

Doe moved for summary judgment, asking for the $150,000 in liquidated damages authorized by § 2255. Summary judgment is a decision entered without a trial when the evidence shows there is no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment under the law.

Court’s ruling

The court concluded that Doe was the victim of a crime covered by § 2255 and that she suffered personal injury as a result. The court also concluded that Reed had not presented specific facts showing a genuine dispute over whether Doe was entitled to the requested damages. The court therefore held that summary judgment was warranted.

The court granted Doe’s motion for summary judgment. It ordered that judgment be entered in her favor for $150,000, plus reasonable attorney’s fees and other reasonably incurred litigation costs. The court directed Doe’s lawyer to submit a declaration and supporting documents concerning the fees and costs within 30 days of the order.