Is the date of an alleged crime not an element of the crime?

Our holding that the date of a crime is not an element of the offense is consistent with our case law regarding the sufficiency of indictments containing factual disparities. In United States v. Hinton, 222 F.3d 664 (9th Cir.2000), for instance, we upheld an indictment which misstated the date of the offense by 18 days, and which misidentified the cities between which contraband was shipped in interstate commerce. In finding these errors to be insignificant, we held that "the test of the sufficiency of the indictment is not whether it could have been framed in a more satisfactory manner, but whether it conforms to minimal constitutional standards." Id. at 672 (citing United States v. Rosi, 27 F.3d 409, 415 (9th Cir.1994)); see also United States v. Alviso, 152 F.3d 1195, 1197 (9th Cir.1998) (recognizing that the Government need only prove that crime occurred "reasonably near" the date stated in the indictment).