United States Ninth Circuit
US v. Backman, 14-10078
Conviction and sentence for sex trafficking by force, fraud, and coercion in violation of 18 U.S.C. section 1591(a) is affirmed where: 1) the district court did not err in declining to instruct the jury that defendant's coercion must be a 'but for' cause of the victim's commercial sex acts; 2) section 1591(a)(1)'s commerce element has no mens rea requirement and there was sufficient evidence to support the jury's finding of an effect on interstate commerce; and 3) the district court properly applied a vulnerable victim sentencing enhancement under U.S.S.G. section 3A1.1(b)(1).
Appellate Information
- Decided
- Published 2016/03/30
Judges
- GRABER
Court
- United States Ninth Circuit