United States v. Rife (6th Cir. May 2022)
Recent Circuit Cases, Sex Offenses, Sixth Circuit
|The Sixth Circuit affirmed a defendant’s conviction for having sex with a minor while living or traveling abroad. While the Court held that the statute at issue (18 USC 2423(c)) was not authorized under the Foreign Commerce Clause of the Constitution, Congress had the authority to criminalize having sex with minors abroad based on an international treaty and Congress’s authority to enact laws that are “necessary and proper” to enforce the treaty.