Statute’s Express Coverage of Extraterritorial Conduct Supports Conviction

The World in U.S. Courts: Fall 2013 - Criminal Law | August.19.2013

United States v. Bollinger, 2013 U.S. Dist. LEXIS 117156 (W.D.N.C. Aug. 19, 2013)

In a prosecution for engaging in illicit sexual conduct with a minor in Haiti, Defendant challenged the extraterritorial application of the criminal statute to conduct occurring in Haiti under the Due Process Clause of the Fifth Amendment. By its own terms, the statute applied to conduct occurring outside the United States. Because Congress clearly intended extraterritorial application of the law, and because the statute was drafted to combat “sexual exploration” trips by U.S. citizens to foreign countries, the District Court for the Western District of North Carolina rejected the Due Process claim.

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