United States v. Campbell

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Campbell recruited young women in the U.S. illegally, initially persuading the women to join his “Family” by offering comfortable places to live and jobs in massage parlors with no expectation that they perform sexual services. Later, Campbell required the women to break ties with their relatives and friends and confiscated their identification, immigration documents and money. Campbell renamed them, branded them with tattoos, abused them, and forced them to engage in prostitution. After a victim turned to law enforcement, Campbell was sentenced to life imprisonment. Campbell appealed, arguing that the district court erred in failing to instruct the jury that a conviction for harboring illegal aliens requires proof of his intent to shield the alien from detection by law enforcement and that the evidence was insufficient to establish the required interstate commerce elements for Hobbs Act extortion and the Trafficking Victim’s Protection Act. The Seventh Circuit affirmed. Any instructional error did not affect Campbell’s substantial rights. The prosecution produced sufficient evidence for a reasonable jury to find that extortion of the women had a direct effect on interstate commerce or a threatened effect which never materialized because the women met Campbell’s demands.View "United States v. Campbell" on Justia Law