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639 KB
Extraction Summary
6
People
6
Organizations
0
Locations
5
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
639 KB
Summary
This document is a page from a legal filing in a criminal case against an individual named Maxwell. The court analyzes and ultimately rejects Maxwell's argument that a 'categorical approach' should be used to interpret the statutes related to the charges. The court relies on precedent from the Second and Third Circuits, particularly the reasoning in *Weingarten v. United States*, to conclude that the categorical approach is not applicable in this context.
People (6)
| Name | Role | Context |
|---|---|---|
| Maxwell |
Mentioned as making a legal argument regarding enticement and conspiracy charges, advocating for a 'categorical appro...
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| Taylor |
A party in the cited case *Taylor v. United States*, used as an example of the 'categorical approach'.
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| Descamps |
A party in the cited case *Descamps v. United States*, which defines the 'categorical approach'.
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| Davis |
A party in the cited case *United States v. Davis*, referenced for its method of statutory interpretation.
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| Weingarten |
A party in the cited case *Weingarten v. United States*, whose reasoning the current Court is following.
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| Schneider |
A party in the cited case *United States v. Schneider*, which reached a similar conclusion to the *Weingarten* case.
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
A party in several cited court cases: *Taylor v. United States*, *Descamps v. United States*, *United States v. Davis...
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| Congress | government agency |
Mentioned in the context of its intent when writing statutes, specifically the use of the word 'offense'.
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| The Court | judicial body |
Refers to the court authoring this document, which is analyzing Maxwell's argument and citing precedent.
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| Second Circuit | judicial body |
A U.S. Court of Appeals that has 'strongly suggested that Maxwell's approach is the wrong one' in the *Weingarten* case.
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| Third Circuit | judicial body |
A U.S. Court of Appeals that 'reached the same conclusion' as the Second Circuit in the *Schneider* case.
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| Supreme Court | judicial body |
Mentioned in a quote from *Weingarten* stating that its 'modern categorical approach jurisprudence is confined to the...
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Timeline (5 events)
1990
The case of *Taylor v. United States*, 495 U.S. 575, 602 (1990) is cited as an example of courts employing the 'categorical approach'.
2013
The case of *Descamps v. United States*, 570 U.S. 254, 261 (2013) is cited for its definition of the 'categorical approach'.
2015
The case of *United States v. Schneider*, 801 F.3d 186, 196 (3d Cir. 2015) is cited as a Third Circuit decision that reached the same conclusion as *Weingarten*.
2017
The case of *Weingarten v. United States*, 865 F.3d 48, 58–60 (2d Cir. 2017) is cited as a Second Circuit decision arguing for a case-specific approach, and its reasoning is adopted by the current court.
2019
The case of *United States v. Davis*, 139 S. Ct. 2319, 2327 (2019) is cited for the principle that courts must examine a statute's 'text, context, and history'.
Relationships (1)
The document discusses legal arguments made by Maxwell in a criminal case (Case 1:20-cr-00330-AJN), implying an adversarial relationship with the prosecuting entity, the United States.
Key Quotes (3)
"look only to the statutory definitions—i.e., the elements” of the relevant offense to determine if the provision applies “and not to the particular facts underlying those convictions."Source
— Descamps v. United States
(Defining the 'categorical approach' used by courts to evaluate prior convictions.)
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Quote #1
"text, context, and history."Source
— United States v. Davis
(Describing what a court must examine to determine Congress's intent in a statute.)
DOJ-OGR-00020769.jpg
Quote #2
"[t]he Supreme Court’s modern categorical approach jurisprudence is confined to the post-conviction contexts of criminal sentencing and immigration deportation cases."Source
— Weingarten v. United States
(Quoted by the Court to support its reasoning for not applying the categorical approach in the current case.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,143 characters)
Case 22-1426, Document 57, 02/28/2023, 3475900, Page151 of 208
A-147
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 10 of 34
A-147
Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 10 of 34
for example, it is possible to transport a minor with intent to engage in criminal sexual activity and not follow through with the planned sexual abuse, and so sexual abuse is not an essential ingredient of the offense. Maxwell makes the same argument for the enticement and related conspiracy charges.
This approach is analogous to the “categorical approach” employed by courts to evaluate prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 U.S. 575, 602 (1990). Generally speaking, the “categorical approach” requires that courts “look only to the statutory definitions—i.e., the elements” of the relevant offense to determine if the provision applies “and not to the particular facts underlying those convictions.” Descamps v. United States, 570 U.S. 254, 261 (2013) (internal quotation marks omitted). Whether a statute requires a categorical or case-specific approach is a question of statutory interpretation. To determine whether Congress used the word “offense” in a statute to refer to an offense in the abstract or to the facts of each individual case, the Court must examine the statute’s “text, context, and history.” United States v. Davis, 139 S. Ct. 2319, 2327 (2019).
Though it has not authoritatively settled the question, the Second Circuit has strongly suggested that Maxwell’s approach is the wrong one. In Weingarten v. United States, 865 F.3d 48, 58–60 (2d Cir. 2017), the Second Circuit discussed at length how the text, context, and history of § 3283 show that Congress intended courts to apply the statute using a case-specific approach. The Third Circuit reached the same conclusion in United States v. Schneider, 801 F.3d 186, 196 (3d Cir. 2015).
The Court sees no reason to depart from the reasoning in Weingarten. First, “[t]he Supreme Court’s modern categorical approach jurisprudence is confined to the post-conviction contexts of criminal sentencing and immigration deportation cases.” Weingarten, 865 F.3d at 58.
This approach is analogous to the “categorical approach” employed by courts to evaluate prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 U.S. 575, 602 (1990). Generally speaking, the “categorical approach” requires that courts “look only to the statutory definitions—i.e., the elements” of the relevant offense to determine if the provision applies “and not to the particular facts underlying those convictions.” Descamps v. United States, 570 U.S. 254, 261 (2013) (internal quotation marks omitted). Whether a statute requires a categorical or case-specific approach is a question of statutory interpretation. To determine whether Congress used the word “offense” in a statute to refer to an offense in the abstract or to the facts of each individual case, the Court must examine the statute’s “text, context, and history.” United States v. Davis, 139 S. Ct. 2319, 2327 (2019).
Though it has not authoritatively settled the question, the Second Circuit has strongly suggested that Maxwell’s approach is the wrong one. In Weingarten v. United States, 865 F.3d 48, 58–60 (2d Cir. 2017), the Second Circuit discussed at length how the text, context, and history of § 3283 show that Congress intended courts to apply the statute using a case-specific approach. The Third Circuit reached the same conclusion in United States v. Schneider, 801 F.3d 186, 196 (3d Cir. 2015).
The Court sees no reason to depart from the reasoning in Weingarten. First, “[t]he Supreme Court’s modern categorical approach jurisprudence is confined to the post-conviction contexts of criminal sentencing and immigration deportation cases.” Weingarten, 865 F.3d at 58.
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