United States v. John Adams
132 F.4th 259
3rd Cir.2025Background
- John Adams pleaded guilty to federal charges including sex trafficking of minors and related offenses in Philadelphia, PA.
- Adams harbored two runaway minor girls, required them to perform sex acts, and advertised them for commercial sex online using a foreign website and devices.
- Law enforcement recovered incriminating communications corroborating the minors' accounts; Adams attempted to cover up his activities and tamper with witnesses after being investigated.
- Adams moved to dismiss charges, arguing that the Trafficking Victims Protection Act (TVPA) did not apply to his domestic conduct and challenged Congress’s authority to enact the statute.
- The District Court denied these motions, upheld the statute under the Commerce Clause, and denied Adams’s later motion to withdraw his guilty plea; Adams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of TVPA § 1591 to Conduct | Statute only applies to international, not domestic, sex trafficking | Statute covers both foreign and domestic conduct if affecting commerce | Statute applies; text and legislative intent clear |
| Constitutional Authority (Commerce Clause, Tenth Amendment) | Congress lacked power to criminalize purely local activity | Congress has authority if activity affects interstate/foreign commerce | Congress validly enacted TVPA under Commerce Clause |
| Statutory Construction (Federal-State Balance) | § 1591 should be construed narrowly to avoid federalizing local crimes | TVPA contains clear jurisdictional hook; intent was to reach all levels | Statute intended to cover local conduct; no overreach |
| Motion to Withdraw Guilty Plea | Government breached plea and claims innocence | Government acted within plea, Adams’s innocence claim unsupported | No breach, no plausible claim of innocence; motion denied |
Key Cases Cited
- Gonzales v. Raich, 545 U.S. 1 (2005) (Congress may regulate local activities if, in the aggregate, they affect interstate commerce under the Commerce Clause)
- Bond v. United States, 572 U.S. 844 (2014) (Ambiguous statutes should not be construed to intrude into core state powers absent clear congressional intent)
- Circuit City Stores, Inc. v. Adams, 532 U.S. 105 (2001) ("Affecting commerce" signals Congress’s intent to regulate up to the limits of its Commerce Clause authority)
- United States v. King, 604 F.3d 125 (3d Cir. 2010) (Government may change sentencing position if defendant’s conduct changes after plea agreement)
- United States v. Brown, 250 F.3d 811 (3d Cir. 2001) (Bald assertion of innocence not enough to withdraw guilty plea)