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Supreme Court and Fourth Circuit Criminal Law Update

October 17, 2014
Cassie Crawford

Reprinted with permission from The Middle Ground, the Federal Bar Association - Middle District of North Carolina Chapter

In United States v. Washington, 743 F.3d 938 (4th Cir. 2014), the Fourth Circuit revisited, and reaffirmed, its prior interpretation of 18 U.S.C. § 2423(a)—which prohibits interstate transportation of a minor for prostitution—in light of intervening Supreme Court precedent. Fourteen-year old victim R.C. was a runaway who informed defendant Washington that she was nineteen years old. Id. at 940. Washington became R.C.'s pimp and brought her to states throughout the Southeast, advertising her prostitution services on the internet as they traveled. Id. Washington was charged with and convicted for violating Section 2423(a), which provides that a "person who knowingly transports an individual who has not attained the age of 18 years in interstate or foreign commerce . . . with intent that the individual engage in prostitution . . . shall be fined and imprisoned not less than ten years." Id. at 940-41 (emphasis added).

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