906 F. Supp. 2d 20
D.P.R.2012Background
- On Sept. 12, 2012, a grand jury returned a four-count indictment charging Medina-Ayala with production of child pornography, transportation of a minor (Counts Two and Three), and possession of child pornography.
- On Nov. 1, 2012, Medina-Ayala moved to dismiss Counts Two and Three arguing 18 U.S.C. § 2423 (the Mann Act) does not apply to Puerto Rico.
- The Government opposed the motion on Nov. 20, 2012; Medina-Ayala did not respond.
- The court addressed whether the Mann Act applies to Puerto Rico and denied the motion.
- The Mann Act makes it a federal crime to transport a minor or an individual with intent to engage in prohibited sexual activity, and it was amended to cover commonwealths.
- The court concluded §2423 applies to Puerto Rico and accordingly denied the motion to dismiss Counts Two and Three.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Mann Act applies to Puerto Rico | Government argues Mann Act covers commonwealths. | Medina-Ayala argues Mann Act does not apply to Puerto Rico. | Mann Act applies to Puerto Rico; motion denied. |
Key Cases Cited
- Cordova & Simonpietri Insurance Agency v. Chase Manhattan Bank N.A., 649 F.2d 36 (1st Cir. 1981) (treatment of Puerto Rico under Sherman Act analogy; Commonwealth status matters for applicability)
- Antilles Cement Corp. v. Fortuño, 670 F.3d 310 (1st Cir. 2012) (statutory interpretation based on congressional intent with PR)
- Puerto Rico v. Shell Co., 302 U.S. 253 (1937) (statute meaning construed to effect lawmakers' intent to PR)
- United States v. Ron Pair Enters., Inc., 489 U.S. 235 (1989) (plain meaning rule; apply unless dovetailing drafters' intent)