No. 23-6424

Taquarius Kaream Ford v. United States

Lower Court: Ninth Circuit
Docketed: 2024-01-05
Status: Denied
Type: IFP
Response WaivedIFP
Tags: 18-usc-1591 18-usc-1594 circuit-split criminal-sentencing double-jeopardy mandatory-minimum sex-trafficking statutory-interpretation
Key Terms:
FifthAmendment HabeasCorpus
Latest Conference: 2024-02-16
Question Presented (AI Summary)

When two Sex Trafficking statutes combine into a single Count, does the penalty for Sex Trafficking Conspiracy under 18 U.S.C. Section 1594(c) which has no required mandatory-minimum, take precedence over the substantive punishment of : 18 U.S.C. Section 1591(b) which has a guaranteed mandatory-minimum of 15 years? And is it Double Jeopardy when the two above statutes affirm guilt by joining them 'together' in multiple counts?

Question Presented (from Petition)

QUESTIONS PRESENTED : When two Sex Trafficking statutes combine into a single Count, does the penalty for Sex Trafficking Conspiracy under 18 U.S.C. Section 1594(c) which has no required 7 mandatory-minimum, take precedence over the substantive punishment of : 18 U.S.C. Section 1591(b) which has a guaranteed mandatory-minimum of 15 years? And is it Double Jeopardy when the two above statutes affirm guilt by joining them "together" in multiple counts? There is a major divide in the circuits about this. iii TABLE OF. CONTENTS Cece awe nae . an There is a major split in the Circuits regarding the ambiguity of the unique conspiracy statute U.S.C. Section 1594(c) which covers the penalty of sex trafficking conspiracies. The Fourth, Seventh and Ninth Circuits are in agreement as to a base offense level of 14, even if paired with a substantive count. While the Third and Eighth Circuits have opposite conclusions rendering a base level of 34 with or without a substantive offense. The difference between the two offense levels can determine decades in prison, even for first time Offenders... eee testers es eee eseetest

Docket Entries

2024-02-20
Petition DENIED.
2024-01-11
DISTRIBUTED for Conference of 2/16/2024.
2024-01-09
Waiver of right of respondent United States to respond filed.
2023-12-05
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due February 5, 2024)
2023-11-05
Application (23A400) granted by Justice Kagan extending the time to file until December 5, 2023.
2023-10-26
Application (23A400) to extend the time to file a petition for a writ of certiorari from November 5, 2023 to December 5, 2023, submitted to Justice Kagan.

Attorneys

Taquarius Ford
Taquarius Kaream Ford — Petitioner
Taquarius Kaream Ford — Petitioner
United States
Elizabeth B. PrelogarSolicitor General, Respondent
Elizabeth B. PrelogarSolicitor General, Respondent