United States v. Alex Campbell
2014 U.S. App. LEXIS 20149
| 7th Cir. | 2014Background
- Campbell recruited young Ukrainian women illegally to work as masseuses and later prostitutes, forming a “Family” that he controlled.
- He branded and tattooed the women, confiscated their identification and immigration documents, renamed them, and forced them to live and work for his benefit.
- A superseding indictment charged eleven counts; a jury convicted Campbell on all counts except Count 5, with sentencing life imprisonment.
- Key victims discussed on appeal are Diamond, Loni, and Masha, who testified about coercion, beatings, and Campbell’s control over their lives and labor.
- Campbell challenges harboring instructions and the sufficiency of the evidence on harboring, extortion under the Hobbs Act, and TVPA nexus, raising plain-error and sufficiency arguments.
- The appellate court analyzes whether the harboring statute’s intent element was properly defined, and whether the evidence supports a finding of intent to shield from detection as part of Campbell’s overall scheme.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Harboring intent element standard | Government contends Costello governs harboring intent | Campbell argues the district court erred by not requiring driving intent to evade detection | No reversible error; substantial rights not affected |
| Sufficiency of harboring evidence | Government asserts evidence showed intent to evade authorities | Campbell claims evidence insufficient to prove sheltering for evasion | Evidence supports intent to shield from detection; no reversal on sufficiency |
| Hobbs Act interstate commerce nexus | Government must show nexus or potential impact on interstate commerce | Campbell asserts insufficient nexus tying extortion to interstate commerce | Direct connection or potential impact shown; sufficient interstate nexus |
| TVPA interstate commerce element | Government argues use of internet ads, phones, and multi-sp spa operations establish nexus | Campbell contends nexus insufficient beyond legitimate spa activity | Evidence, viewed collectively, satisfies interstate commerce element of TVPA |
Key Cases Cited
- United States v. Ye, 588 F.3d 411 (7th Cir. 2009) (defined harboring terms and helped shape harboring interpretation)
- United States v. Costello, 666 F.3d 1040 (7th Cir. 2012) (set harboring definition restricting expansive interpretation)
- Vargas-Cordon v. United States, 733 F.3d 366 (2d Cir. 2013) (evidence of intent to prevent detection supports harboring conviction)
- United States v. Mattson, 671 F.2d 1020 (7th Cir. 1982) (discussed depletion of assets theory under Hobbs Act)
- United States v. Re, 401 F.3d 828 (7th Cir. 2005) (de minimis effect on commerce suffices for Hobbs Act)