Protecting Our Nation’s Children in the Technological Age: Arguing For An Interpretation of “Sexual Activity” in 18 U.S.C. § 2422(b) That Does Not Require Physical Contact

Our Nation’s justice system values “equal protection under the law.” This represents the belief that all individuals should be treated equally under the law regardless of personal characteristics. Traditionally, we think about this in a context of things like race, gender, or ethnicity. However, this also encompasses the general idea that individuals nationwide should be accountable to and protected by the same laws. As it relates to criminal law, this notion highlights the importance of uniformity in a criminal justice system. Without consistent application and execution, a criminal justice system will never be fair or “equal.” The federal child enticement statute, 18 U.S.C. § 2422(b), criminalizes the coercion or enticement of a minor to engage in “any sexual activity for which any person can be charged with a criminal offense.” The statute was initially enacted as part of the Mann Act to punish the prostitution of females, but it has since been expanded to target sexual harms against children regardless of gender and to account for the growing risk of online harms stemming from the rise in the Internet, social media, and other technology. Notably, the statute carries a 10-year mandatory minimum term of imprisonment. When the statute was enacted, Congress did not provide a definition for the phrase “sexual activity.” As a result, a circuit split is emerging among the federal jurisdictions about how the term “sexual activity” should be properly interpreted. The Seventh Circuit is the only circuit thus far to hold that “sexual activity” as it is used in section 2422(b) requires interpersonal physical activity between individuals. Conversely, the Fourth and Eleventh Circuits held that “sexual activity” does not require interpersonal physical contact between individuals, so sexual crimes that only occur online could constitute an offense. This Note argues that the proper interpretation of “sexual activity” is the broader definition endorsed by the Fourth and Eleventh Circuits that does not require interpersonal physical contact between individuals. First, this Note argues that this interpretation is more appropriate because it conforms with the traditional canons of statutory interpretation unlike the reasoning underlying the narrow interpretation endorsed by the Seventh Circuit. Second, this Note argues that the broader interpretation is necessary because children have become more vulnerable due to developments in technology and because of the COVID-19 pandemic. Third, this Note argues that by adopting a broader interpretation of “sexual activity,” section 2422(b) can serve as a stronger prosecutorial tool and will help fill in gaps in the justice system left by the federal trafficking statute codified in 18 U.S.C. § 1591. Lastly, this Note addresses potential problems with this interpretation and some solutions to address these

Social Citizens Beta

Provides a profile of the Millennial generation, born between 1978 and 1993, and how its digital fluency and immersion in social media shape its activism, including preferences for interactive, hands-on collaboration and global causes with moral clarity

America's Giving Challenge: Assessment and Reflection Report

Provides an overview of Case's 2007-08 online Giving Challenge and its impact on grassroots fundraising. Outlines the types of participating causes, charities, and donors; characteristics of successful efforts; lessons learned; and recommendations

America's Giving Challenge 2009: Assessment & Reflection Report

Based on a survey of participants and "conversational case studies," outlines lessons learned about social media outreach and giving contests, such as winners' common attributes, fundraisers' online media adoption, and best practices in vetting contests

Civic Works, Inc. The Environmental and PAL After School Mentoring Teams - Final Evaluation Report

Civic Works is a youth service corps program based in Baltimore, Maryland. The program operates a number of activities in which teams of corps members perform community service work in urban neighborhoods. Several of its teams are funded by AmeriCorps. Civic Works commissioned Innovation Network, Inc. (InnoNet) to design and conduct participatory assessment activities with two of its AmeriCorps service teams: the Environmental Team and PAL After School Mentoring Team

Echoes From the Field: Proven Capacity-Building Principles for Nonprofits

Identifies nine principles of best practices in capacity building, and key skills necessary in order to implement the principles most effectively. Focuses on issues related to progressive nonprofit organizations. Raises questions for future examination

Body Mass Index, abdominal adiposity, obesity, and cardiovascular reactions to psychological stress in a large community sample

OBJECTIVE: To examine the association between adiposity and the magnitude of cardiovascular reactions to acute psychological stress cross-sectionally and prospectively in a large community sample.\ud \ud METHODS: Blood pressure and heart rate (HR) were measured at rest and in response to a brief time-pressured mental arithmetic stress in 1647 adults. At the same session and 5 years later, height, weight, waist and hip circumference were measured and body mass index (BMI) and waist-hip ratio were computed. Obesity was defined as a body mass index of > or = 30 kg/m(2).\ud \ud RESULTS: Contrary to expectations, the most robust and consistent results to emerge from cross-sectional analyses were negative associations between all three measures of adiposity and HR reactivity; those with greater BMI and waist-hip ratios and those categorized as obese displayed smaller HR reactions to stress. In prospective analyses, high HR reactivity was associated with a reduced likelihood of becoming obese in the subsequent 5 years.\ud \ud CONCLUSIONS: Our analyses suggest that it is low, not high, HR reactivity that is related to adiposity. Low HR reactivity, probably by reflecting generally blunted sympathetic nervous system reactions to challenge, may be a risk marker for developing obesity.\ud \u

A bi-directional relationship between obesity and health-related quality of life : evidence from the longitudinal AusDiab study

Objective: To assess the prospective relationship between obesity and health-related quality of life, including a novel assessment of the impact of health-related quality of life on weight gain.Design and setting: Longitudinal, national, population-based Australian Diabetes, Obesity and Lifestyle (AusDiab) study, with surveys conducted in 1999/2000 and 2004/2005.Participants: A total of 5985 men and women aged 25 years at study entry.Main outcome measure(s): At both time points, height, weight and waist circumference were measured and self-report data on health-related quality of life from the SF-36 questionnaire were obtained. Cross-sectional and bi-directional, prospective associations between obesity categories and health-related quality of life were assessed.Results: Higher body mass index (BMI) at baseline was associated with deterioration in health-related quality of life over 5 years for seven of the eight health-related quality of life domains in women (all P0.01, with the exception of mental health, P&gt;0.05), and six out of eight in men (all P&lt;0.05, with the exception of role-emotional, P=0.055, and mental health, P&gt;0.05). Each of the quality-of-life domains related to mental health as well as the mental component summary were inversely associated with BMI change (all P&lt;0.0001 for women and P0.01 for men), with the exception of vitality, which was significant in women only (P=0.008). For the physical domains, change in BMI was inversely associated with baseline general health in women only (P=0.023).Conclusions: Obesity was associated with a deterioration in health-related quality of life (including both physical and mental health domains) in this cohort of Australian adults followed over 5 years. Health-related quality of life was also a predictor of weight gain over 5 years, indicating a bi-directional association between obesity and health-related quality of life. The identification of those with poor health-related quality of life may be important in assessing the risk of future weight gain, and a focus on health-related quality of life may be beneficial in weight management strategies.<br /