Record contained sufficient evidence to support defendant’s conviction under 18 USC section 1591 for sex trafficking of minor if done “in or affecting interstate or foreign commerce.” Record showed that defendant convinced 15-year-old girl to earn money as prostitute under circumstances where defendant had posted girl’s picture on Craigslist and twice tried to arrange rendezvous with clients and girl, but where clients had failed to show up for said scheduled encounters. Ct. rejected defendant’s argument that conviction under section 1591 required proof that minor actually engaged in “commercial sex act,” since all elements of offense had been satisfied at time defendant had recruited girl under plan to have her engage in commercial sex acts. Ct. further found that element requiring proof that defendant’s actions affected interstate commerce was satisfied when: (1) defendant posted girl’s picture on internet; and (2) defendant stipulated that instant Craigslist advertisement affected interstate commerce.
Federal 7th Circuit Court
Criminal Court
Reasonable Doubt