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724 KB
Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
724 KB
Summary
This legal document, part of an appellate court opinion, addresses arguments made by a defendant named Maxwell. The court rejects a 'categorical approach' for determining if offenses involved sexual abuse, citing testimony from a victim, 'Jane', about being abused as a minor across state lines. The document then introduces Maxwell's second argument: that certain counts are barred by the statute of limitations because a 2003 amendment to § 3283 should not apply retroactively, referencing the Supreme Court case Landgraf v. USI Film Products.
People (5)
| Name | Role | Context |
|---|---|---|
| Jane | Witness |
Mentioned as one of the women who testified at trial, providing evidence of being sexually abused as a minor.
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| Maxwell | Defendant/Appellant |
Argues that Counts Three, Four, and Six of the Indictment are barred by the statute of limitations.
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| Weingarten | Party in a cited legal case |
Referenced in the legal reasoning of the case 'Weingarten', which the court follows.
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| Landgraf | Party in a cited legal case |
Referenced in the Supreme Court case 'Landgraf v. USI Film Products' regarding retroactive application of statutes.
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| Taylor | Party in a cited legal case |
Referenced in the case 'Taylor v. United States' regarding the 'categorical approach' of statutory interpretation.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Supreme Court | Government agency |
Mentioned as having held a decision in 'Landgraf v. USI Film Products' regarding retroactive application of statutes.
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| Congress | Government agency |
Mentioned in the context of determining whether it has "expressly prescribed the statute’s proper reach."
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| USI Film Products | Company |
A party in the cited legal case 'Landgraf v. USI Film Products'.
|
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the cited case name 'Taylor v. United States'.
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Key Quotes (3)
"determine whether Congress has expressly prescribed the statute’s proper reach."Source
— Supreme Court (in Landgraf v. USI Film Products)
(Quoted as the first step a court must take when deciding if a statute applies retroactively.)
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Quote #1
"the inquiry ends, and the court enforces the"Source
— Supreme Court (in Landgraf v. USI Film Products)
(Describes the outcome if Congress has expressly prescribed a statute's reach.)
DOJ-OGR-00021892.jpg
Quote #2
"[t]he language of § 3283[] . . . reaches beyond the offense and its legal elements to the conduct ‘involv[ed]’ in the offense."Source
— Court in Weingarten case
(Quoted as the first reason for not applying the 'categorical approach' to § 3283.)
DOJ-OGR-00021892.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,049 characters)
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page15 of 26
approach as opposed to a “categorical approach.”22 We see no reason to depart from our reasoning in Weingarten. Accordingly, the question presented here is whether the charged offenses involved the sexual abuse of a minor for the purposes of § 3283 based on the facts of the case. Jane, one of the women who testified at trial, gave evidence that she had been sexually abused when transported across state lines as a minor. Counts Three and Four thus qualify as offenses, and § 3283 applies to those offenses.
Second, Maxwell argues that Counts Three, Four, and Six of the Indictment are barred by the statute of limitations because the extended statute of limitations provided by the 2003 amendment to § 3283 does not apply to pre-enactment conduct. In Landgraf v. USI Film Products, the Supreme Court held that a court, in deciding whether a statute applies retroactively, must first “determine whether Congress has expressly prescribed the statute’s proper reach.”23 If Congress has done so, “the inquiry ends, and the court enforces the
22 The “categorical approach” is a method of statutory interpretation that requires courts to look “only to the statutory definitions of the prior offenses, and not to the particular facts underlying those convictions” for sentencing and immigration purposes. Taylor v. United States, 495 U.S. 575, 600 (1990). We properly reasoned in Weingarten that § 3283 met none of the conditions listed by Taylor that might require application of the categorical approach. See Weingarten, 865 F.3d at 58-60. First, “[t]he language of § 3283[] . . . reaches beyond the offense and its legal elements to the conduct ‘involv[ed]’ in the offense.” Id. at 59-60. Second, legislative history suggests that Congress intended § 3283 to be applied broadly. Id. at 60. Third, a case-specific approach would not produce practical difficulties or potential unfairness. Id.
23 511 U.S. 244, 280 (1994); see also Weingarten, 865 F.3d at 54-55.
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DOJ-OGR-00021892
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