United States v. Walls

A regulation that uses the phrase “affecting interstate commerce” indicates that Congress intended that regulation to extend to the outer limits of Congress’s commerce power.

Alexander Walls was found guilty of four counts of sex-trafficking crimes under the Trafficking Victims Protection Act (“TVPA”). Walls appealed his conviction, arguing that the district court incorrectly applied the Commerce Clause of the United States Constitution, and also provided a jury instruction that unlawfully directed a verdict. When a regulation uses the language “affecting interstate commerce,” a court may concluded that Congress meant to regulate to the outer limits of its commerce power. The Ninth Circuit reviewed the district court’s interpretation of the TVPA. The panel determined that Congress intended the TVPA to regulate to the outer limits of its commerce power by using the relevant language. The panel held that activity regulated by the TVPA needs only a de minimis effect on interstate commerce since the class of activity substantially affects interstate commerce. Furthermore, the panel determined that the jury instruction was valid because it left the jury with the ability to determine whether Walls’s conduct had at least a de minimis effect on interstate commerce. AFFIRMED.