United States v. Walls

Defendant, who operated as a small-time pimp, was convicted of sex-trafficking offenses in violation of the Trafficking Victims Protection Act (TVPA). Defendant appealed his convictions as to four counts for violations of the TVPA, arguing, among other things, that the district court misstated the law in its jury instructions. A panel of the Ninth Circuit affirmed, holding (1) when Congress used the language “in or affecting interstate or foreign commerce” in the TVPA, it intended to exercise its full powers under the Commerce Clause; (2) any individual instance of conduct regulated by the TVPA need only have a de minimis effect on interstate commerce, and accordingly, the district court did not err when it instructed the jury that “any act that crosses state lines is ‘in’ interstate commerce” and “an act or transaction that is economic in nature” and “affects the flow of money in the stream of commerce to any degree ‘affects’ interstate commerce”; and (3) the jury instruction did not essentially direct a verdict on the element of interstate commerce. View "United States v. Walls" on Justia Law