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42.6 KB

Extraction Summary

3
People
3
Organizations
2
Locations
5
Events
2
Relationships
7
Quotes

Document Information

Type: Legal document / court opinion
File Size: 42.6 KB
Summary

This legal document discusses the denial of Maxwell's motions to dismiss charges related to the sexual abuse of minors, focusing on the application of § 3283. It references the Weingarten v. United States case, which established a 'case-specific approach' for interpreting statutory provisions, and notes that one of the victims is identified as 'Jane'. The document cites several legal precedents, including United States v. Sampson, Weingarten v. United States, United States v. Maxwell, and Taylor v. United States.

People (3)

Name Role Context
Maxwell Defendant
Motions to dismiss charges denied by District Court. Involved in United States v. Maxwell case.
Jane Victim/Witness
One of the women involved in the case related to sexual abuse of a minor.
Taylor Party in a cited case
Party in Taylor v. United States, relevant to the 'categorical approach'.

Organizations (3)

Name Type Context
District Court
Denied Maxwell's motions to dismiss, applied Weingarten v. United States, reviewed de novo.
Congress
Intended courts to apply § 3283 using a case-specific approach; legislative history suggests broad application.
United States
Party in several cited cases (United States v. Sampson, Weingarten v. United States, United States v. Maxwell, Taylor...

Timeline (5 events)

1990
Taylor v. United States case, 495 U.S. 575, 600
2017
Weingarten case, 865 F.3d 48, 58-60 (2d Cir.)
2018
United States v. Sampson case, 898 F.3d 270, 276, 278 (2d Cir.)
2021
United States v. Maxwell case, 534 F. Supp. 3d 299, 313 14 (S.D.N.Y.)
Prior to enactment of provision
Offenses committed by Maxwell that were subject to motions to dismiss.

Locations (2)

Location Context
Citation for United States v. Sampson (2018) and Weingarten (2017)
Citation for United States v. Maxwell (2021)

Relationships (2)

Maxwell defendant-court (motions denied) District Court
District Court correctly denied Maxwell's motions to dismiss
Jane victim/involved party Maxwell (implied)
Jane, one of the women who [involved in the sexual abuse of minor case]

Key Quotes (7)

""We review de novo the denial of a motion to dismiss an indictment and the application of a statute of limitations.""
Source
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Quote #1
""Counts Three and Four of the Indictment are offenses involving the sexual abuse of minors.""
Source
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Quote #2
""In Weingarten, we explained that Congress intended courts to apply § 3283 using a case-specific approach as opposed to a "categorical approach."""
Source
DOJ-OGR-00000076.tif
Quote #3
""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.""
Source
DOJ-OGR-00000076.tif
Quote #4
""[t]he language of § 3283[]... reaches beyond the offense and its legal elements to the conduct 'involv[ed]' in the offense.""
Source
DOJ-OGR-00000076.tif
Quote #5
""legislative history suggests that Congress intended § 3283 to be applied broadly.""
Source
DOJ-OGR-00000076.tif
Quote #6
""a case-specific approach would not produce practical difficulties or potential unfairness.""
Source
DOJ-OGR-00000076.tif
Quote #7

Full Extracted Text

Complete text extracted from the document (1,957 characters)

13a
those offenses that were committed before the
enactment into law of the provision. On both points,
we disagree and hold that the District Court correctly
denied Maxwell's motions to dismiss the charges as
untimely. We review de novo the denial of a motion to
dismiss an indictment and the application of a statute
of limitations.20
First, Counts Three and Four of the Indictment are
offenses involving the sexual abuse of minors. The
District Court properly applied Weingarten v. United
States.21 In Weingarten, we explained that Congress
intended courts to apply § 3283 using a case-specific
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
20 United States v. Sampson, 898 F.3d 270, 276, 278 (2d Cir.
2018).
21 865 F.3d 48, 58-60 (2d Cir. 2017); see also United States v.
Maxwell, 534 F. Supp. 3d 299, 313 14 (S.D.N.Y. 2021).
22 The "categorical approach" is a method of statutory inter-
pretation 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.
DOJ-OGR-00000076

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