The following excerpt is from United States v. Escalera, 957 F.3d 122 (2nd Cir. 2020):
When, on the other hand, the statutory text or legislative history makes clear that a statutes mens rea element extends to a jurisdictional element, courts give effect to that requirement. See Epskamp , 832 F.3d at 167 (noting that an "obvious exception" to the rule that "knowledge of the jurisdictional fact ... [is not] an essential element" is "when the statute itself requires knowledge of the jurisdictional element" (quoting United States v. Eisenberg , 596 F.2d 522, 526 (2d Cir. 1979) )).11
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