United States v. James

When interpreting the meaning of words or phrases in federal statutes, it is improper to derive the meaning of the word or phrase from closely related state statutes.

T.C. suffers from cerebral palsy. T.C. is unable to care for herself, is greatly limited in her mobility, and has difficulty communicating. In 2011, a family member caught Christopher James having sex with T.C. The assault took place on the Fort Apache Indian Reservation, meaning James could only be indicted by the federal government. The government indicted James under 18 U.S.C. § 2242(2)(B), for being physically incapable. The federal government has no generic statute for non-consensual rape, unlike the states. The district court granted a motion for acquittal for Christopher James after the jury rendered two counts of sexual abuse of a severely disabled woman. The district court found there was insufficient evidence that the victim was physically incapable of resisting or declining participation. On appeal,the Ninth Circuit first looked for a meaning of “physically incapable,” as the definition was the turning point of the case. No statutory or legislative history was found to define the term. The panel next noted that the district court erred when it looked to state law to define physically incapable. The district court, unable to find a meaning for “physically incapable,” used a closely related term “physically helpless” from state law to support their ruling. The panel held this to be incorrect procedure. The panel next held that the government did produce sufficient evidence—when viewed in the light most favorable to it—to allow a rational juror to doubt that T.C. was physically incapable of declining participation in or communicating her unwillingness in a sexual act with James because of her extreme physical and verbal limitations. REVERSED, VACATED, and REMANDED with instructions.