United States v. Rife, No. 20-5688 (6th Cir. 2022)
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In 2012, Rife moved from Kentucky to Cambodia, took a position as an elementary school teacher, began a relationship with a Cambodian woman, and adopted a young Cambodian girl. For six years, Rife lived and worked exclusively in Cambodia, obtaining annual “Extension of Stay” temporary visas through his U.S. passport. Rife did not visit the U.S. during that period but maintained a bank account and property in Kentucky. In 2018, Cambodian authorities investigated allegations that Rife had sexually assaulted his young female students. Rife’s school terminated his employment. He returned to Kentucky, where federal agents interviewed him. Rife eventually confessed to abusing two female students.
Rife was charged with two counts of illicit sexual conduct in a foreign place, 18 U.S.C. 2423(c). The government did not allege that Rife offered anything of value in connection with his abuse of the girls; his “illicit sexual conduct” was non-commercial in nature. Rife argued that Congress lacked constitutional authority to punish him for non-commercial acts of sexual abuse that occurred in a foreign country years after he had traveled there. The district court denied Rife’s motion to dismiss, passing over the foreign commerce issue but upholding section 2423(c) as a valid exercise of Congress’s power to implement the Optional Protocol. The court sentenced Rife to 252 months’ imprisonment. The Sixth Circuit affirmed, citing Supreme Court precedent; section 2423(c) as applied here was within Congress’s power to enact legislation implementing treaties.
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