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United States v. Townsend

United States Court of Appeals for the Eleventh Circuit

521 Fed. Appx. 904 (2013)

Facts

Tyrone Townsend (plaintiff) was a pimp. C.B. and L.F., both adult women, voluntarily became prostitutes for Townsend. After some time, C.B. and L.F. wanted to stop working for Townsend, but he kept them in his employ through threats, violence, and by withholding their phones and government identification documents. During the time Townsend forced C.B. and L.F. to remain in his employ, Townsend repeatedly transported C.B. and L.F. across state lines to either meet with clients or to force them to engage in prostitution. The federal government (defendant) convicted Townsend under two federal statutes, Section 1519(a), which criminalized sex trafficking, and Section 2422(a), which criminalized transporting persons in interstate commerce with the intent to force the transported persons into prostitution. Townsend appealed, arguing that charging him under both Section 1519(a) and Section 2422(a) was double jeopardy because Section 2422(a) was a lesser-included offense of Section 1591(a).

Rule of Law

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Issue

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Holding and Reasoning (Per curiam)

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