A federal appeals court has thrown out the sex trafficking conviction of a man whose defense was that he was actually involved in a consensual sadomasochistic relationship.

The U.S. Court of Appeals for the Second Circuit found that the due process rights of defendant Glenn Marcus were violated because the jury heard evidence of conduct that occurred before the enactment of the Trafficking Victims Protection Act—and that conduct was “materially” different after the act became law in October 2000.