DOJ-OGR-00021809.jpg
724 KB
Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
0
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
724 KB
Summary
This legal document, part of Case 22-1426, discusses two key arguments. First, it affirms that charges involving the sexual abuse of a minor ("Jane") transported across state lines fall under § 3283. Second, it addresses an argument by Maxwell that certain counts are time-barred because a 2003 amendment to the statute of limitations in § 3283 should not apply retroactively, referencing the Supreme Court's test in 'Landgraf v. USI Film Products'.
People (5)
| Name | Role | Context |
|---|---|---|
| Jane | Witness |
One of the women who testified at trial, providing evidence of being sexually abused as a minor when transported acro...
|
| Maxwell | Party to the case (likely defendant) |
Argues that Counts Three, Four, and Six of the Indictment are barred by the statute of limitations.
|
| Weingarten | Party in a cited legal case |
Mentioned in the context of the legal case 'Weingarten', which provides reasoning relevant to the current case.
|
| Landgraf | Party in a cited legal case |
Mentioned in the context of the legal case 'Landgraf v. USI Film Products', which established a test for retroactive ...
|
| Taylor | Party in a cited legal case |
Mentioned in the context of the legal case 'Taylor v. United States', which discusses the 'categorical approach' to s...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| USI Film Products | company |
A party in the cited legal case 'Landgraf v. USI Film Products'.
|
| Supreme Court | government agency |
Mentioned as having held a position in the 'Landgraf' case regarding the retroactive application of statutes.
|
| Congress | government agency |
Mentioned in the context of statutory interpretation and whether it has expressly prescribed a statute's reach.
|
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the cited case name 'Taylor v. United States'.
|
Key Quotes (3)
"determine whether Congress has expressly prescribed the statute’s proper reach."Source
— Supreme Court (in Landgraf v. USI Film Products)
(A quote describing the first step a court must take when deciding if a statute applies retroactively.)
DOJ-OGR-00021809.jpg
Quote #1
"the inquiry ends, and the court enforces the"Source
— Supreme Court (in Landgraf v. USI Film Products)
(Describes the outcome if Congress has expressly prescribed a statute's reach.)
DOJ-OGR-00021809.jpg
Quote #2
"[t]he language of § 3283[] . . . reaches beyond the offense and its legal elements to the conduct ‘involv[ed]’ in the offense."Source
— Court in Weingarten case
(A quote from the Weingarten case explaining why the categorical approach does not apply to § 3283.)
DOJ-OGR-00021809.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,049 characters)
Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page15 of 26
approach as opposed to a “categorical approach.”22 We see no reason to depart from our reasoning in Weingarten. Accordingly, the question presented here is whether the charged offenses involved the sexual abuse of a minor for the purposes of § 3283 based on the facts of the case. Jane, one of the women who testified at trial, gave evidence that she had been sexually abused when transported across state lines as a minor. Counts Three and Four thus qualify as offenses, and § 3283 applies to those offenses.
Second, Maxwell argues that Counts Three, Four, and Six of the Indictment are barred by the statute of limitations because the extended statute of limitations provided by the 2003 amendment to § 3283 does not apply to pre-enactment conduct. In Landgraf v. USI Film Products, the Supreme Court held that a court, in deciding whether a statute applies retroactively, must first “determine whether Congress has expressly prescribed the statute’s proper reach.”23 If Congress has done so, “the inquiry ends, and the court enforces the
22 The “categorical approach” is a method of statutory interpretation that requires courts to look “only to the statutory definitions of the prior offenses, and not to the particular facts underlying those convictions” for sentencing and immigration purposes. Taylor v. United States, 495 U.S. 575, 600 (1990). We properly reasoned in Weingarten that § 3283 met none of the conditions listed by Taylor that might require application of the categorical approach. See Weingarten, 865 F.3d at 58-60. First, “[t]he language of § 3283[] . . . reaches beyond the offense and its legal elements to the conduct ‘involv[ed]’ in the offense.” Id. at 59-60. Second, legislative history suggests that Congress intended § 3283 to be applied broadly. Id. at 60. Third, a case-specific approach would not produce practical difficulties or potential unfairness. Id.
23 511 U.S. 244, 280 (1994); see also Weingarten, 865 F.3d at 54-55.
15
DOJ-OGR-00021809
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document