United States v. Straker, No. 11-3054 (D.C. Cir. 2015)
Annotate this CaseNationals of the Republic of Trinidad and Tobago abducted wealthy individuals, held them captive in the island's mountainous forests, and extorted ransoms from terrified family and friends. The conspirators were extradited to the United States, tried, and convicted of violating the Hostage Taking Act, 18 U.S.C. 1203. Principally at issue was whether the Act applies if the victim secured his United States citizenship through fraud. The court agreed with the district court that the Act does apply. The court concluded that, by its plain language, section 1203 broadly protects United States citizens. The statute imposes no restriction on this protection. It does not, for example, exclude citizens who, in retrospect, are unworthy of the honor. Nor does it exclude persons whose citizenship might at some later time be invalidated. In other words, section 1203 protects victims according to their status at the time of the hostage-taking. Therefore, the court affirmed the district court's judgment as to this issue. Further, the court affirmed the district court's denial of defendants' petition for a writ of mandamus requiring the United States Attorney to initiate posthumous denaturalization proceedings against the victim under 8 U.S.C. 1451. The court rejected defendants' remaining claims. The court affirmed the convictions and the judgment of the district court.
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