United States v. Noel, No. 17-10529 (11th Cir. 2018)
Annotate this CaseThe International Convention Against the Taking of Hostages provides global notice to the world that the hostage taking criminalized by 18 U.S.C. 1203 can be prosecuted in any signatory nation of which the hostage is a citizen or a national, notwithstanding that the crime occurred elsewhere. The Eleventh Circuit affirmed defendant's conviction for conspiracy to seize or detain, and threaten to kill, injure, or continue to detain, a national of the United States in order to compel a third person to pay ransom (count 1), and hostage taking (count 2). The court held that the relevant statute's requirement that the victim be Americans is jurisdictional only and there was no mens rea requirement for that part of the statute; the conduct of which defendant was convicted clearly fell within the plain meaning of the statutory language of the hostage taking statute; and the court rejected defendant's constitutional challenges to section 1203 where his empowerment argument and due process argument were without merit.
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