USA v. Renteria, No. 22-50242 (5th Cir. 2023)
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Defendant was charged with and convicted of (1) producing child pornography, (2) committing that offense while being required to register as a sex offender, (3) possessing child pornography, and (4) sex trafficking of a child. All four charges involved his conduct with “Minor Victim-1” or “the Minor.” Defendant appealed his conviction for Count 4, sex trafficking of a child. He maintains that in light of Bond v. United States, 572 U.S. 844 (2014), 18 U.S.C. Section 1591 should not be interpreted to reach his conduct, which he terms a “purely local sex offense.”
The Fifth Circuit affirmed. The court explained that overturning Defendant’s conviction under Bond requires him to show three things: (1) that allowing his conviction would “significantly change the federal-state balance,” (2) that Congress has not included a clear indication that they meant to reach “purely local crimes,” and (3) that his is a purely local crime. The court explained without expressing any view on (1) or (3), it determines that Defendant failed to demonstrate (2). Congress included a clear indication that Section 1591 is meant to reach “purely local crimes.” The court explained that it is not alone in adopting a broader interpretation of Section 1591 despite Bond. Because Congress included a clear indication that Section 1591 is meant to reach “purely local crimes,” Defendant’s argument under Bond fails.
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