United States v. Maldonado-Burgos, No. 15-2145 (1st Cir. 2016)
Annotate this CaseIn the 1945 case Crespo v. United States, the First Circuit held that 18 U.S.C. 2421(a), which prohibits transportation of an individual “in interstate or foreign commerce, or in any Territory or Possession of the United States” for purposes of prostitution or other unlawful sexual activity, applies to transportation that occurs solely within Puerto Rico. Since that case was decided, Puerto Rico has transformed from a United States territory to a self-governing Commonwealth. Defendant, who transported a woman within Puerto Rico with the intent to engage in sexual activity that was criminal under Puerto Rico law, dismissed the indictment against him, arguing that transportation occurring solely within Puerto Rico no longer violates section 2421(a). The district court agreed with Defendant and dismissed the indictment. The First Circuit affirmed the dismissal of the indictment, holding that section 2421(a) does not extend to illicit transportation that occurs solely within Puerto Rico and instead reaches only transportation “in interstate or foreign commerce” with respect to the island.
The court issued a subsequent related opinion or order on July 7, 2017.
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