Miguel Scott Arnold v. United States
What is the allowable unit of prosecution for violations of 18 U.S.C. § 1591(a)?
2. Did the Third Circuit Court of Appeals err by not remanding to the lower court with an order for the District Court to dismiss petitioner's indictment due to the Jury not being instructed to specifically find, if any, what victim the jury believed met the burden?
3. Because of the complexity of petitioner's case/charge(s), should the lower courts had tasked the jury to find/been given instructions to find petitioner guilty of each individual victim the jury believed met the burden?
4. Due to the allowable unit of prosecution, not being established, nor firmly understood by any of the lower courts in regards to 18 U.S.C. § 1591(a), and being that this Honorable Court had/has not yet defined or established such, should the "Rule of Lenity" be/have been applied to petitioner as this Honorable Court has explained/established in similar case(s)/situation(s)?
allowable-unit-of-prosecution-for-18-usc-1591(a)