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v EFTA00099956 United States v. Israel, 05 Cr. 1039 (CM) 286 United States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33,37,38,46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1
Falter, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactivel
he categorical approach. 39 EFTA00100006 `Involving' . . is equally consistent with applying a fact-based approach." 865 F.3d at 60 n.11 (citing Nijhawan v. Holder, 557 U.S. 29,38 (2009) (applying the circumstances-specific approach to a statute containing the word "involves")). Moreover, as the Weing
v EFTA00077621 United States v. Israel, 05 Cr. 1039 (CM) 286 United States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d
g Faker, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively
the categorical approach. 'Involving' . is equally consistent with applying a fact-based approach." 865 F.3d at 60 n.11 39 EFTA00077671 (citing Nijhawan v. Holder, 557 U.S. 29, 38 (2009) (applying the circumstances-specific approach to a statute containing the word "involves")). Moreover, as the Wein
v EFTA00039436 United States v. Israel, 05 Cr. 1039 (CM) 286 United States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d
g Faker, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively
the categorical approach. 'Involving' . is equally consistent with applying a fact-based approach." 865 F.3d at 60 n.11 39 EFTA00039486 (citing Nijhawan v. Holder, 557 U.S. 29, 38 (2009) (applying the circumstances-specific approach to a statute containing the word "involves")). Moreover, as the Wein
Falter, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief, 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactivel
the categorical approach. 39 EFTA00103064 `Involving' . is equally consistent with applying a fact-based approach." 865 F.3d at 60 n.11 (citing Nijhawan v. Holder, 557 U.S. 29, 38 (2009) (applying the circumstances-specific approach to a statute containing the word "involves")). Moreover, as the Wein
andgraf v. USI Film Products, 511 U.S. 244 (1994) Leocal v. Ashcroft, 11 passim 543 U.S. 1 (2004) 11 Martin v. Hadix, 527 U.S. 343 (1999) 6 Nijhawan v. Holder, 557 U.S. 29 (2009) 12, 13 Shular v. United States, 140 S. Ct. 779 (2020) 11, 14 Toussie v. United States, 397 U.S. 112 (1970) 8, 9
Page: EFTA00028905 →3 United States v. Davis, 139 S. Ct. 2319 (2019) 11, 14 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 8, 9, 10 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005), cert. denied, 546 U.S. 1007 (2005) 5 United States v. Leo Sure Chief 438 F.3d 920 (9th Cir. 2006) 5 United State
Page: EFTA00028906 →the government cites in which the Court applied a fact-based approach to an "offense involving" statute—does not break this line of cases at all. In Nijhawan, the statutory provision at issue referred to "an offense that . . . involves fraud or deceit in which the loss to the victim or victims exceeds $1
Page: EFTA00028919 →t . . . involves fraud or deceit in which the loss to the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an
Page: EFTA00020271 →3, which allowed prosecution of sex crimes against children until the victim reached age twenty-five, applied to past conduct. See United States v. Jeffries, 405 F.3d 682, 684-85 (8th Cir. 2005). The Second Circuit has observed that the Higher Education Technical Amendments of 1991, Pub. L. No. 102-26, 1
Page: EFTA00020274 →t . . . involves fraud or deceit in which the loss to the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an
Page: EFTA00022101 →3, which allowed prosecution of sex crimes against children until the victim reached age twenty-five, applied to past conduct. See United States v. Jeffries, 405 F.3d 682, 684-85 (8th Cir. 2005). The Second Circuit has observed that the Higher Education Technical Amendments of 1991, Pub. L. No. 102-26, 1
Page: EFTA00022104 →t . . . involves fraud or deceit in which the loss to the victim or victims exceeds $10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an
Page: EFTA00029550 →3, which allowed prosecution of sex crimes against children until the victim reached age twenty-five, applied to past conduct. See United States v. Jeffries, 405 F.3d 682, 684-85 (8th Cir. 2005). The Second Circuit has observed that the Higher Education Technical Amendments of 1991, Pub. L. No. 102-26, 1
Page: EFTA00029553 →Entities connected to both Jeffries and Nijhawan

Jeffrey Epstein
PERSON
United States
LOCATIONEmmy Taylor
PERSON
Ghislaine Maxwell
PERSON
Eric Holder
PERSON
Hernandez
PERSON
Leahy
PERSON
Supreme Court
ORGANIZATIONSchneider
PERSON
Bridges
PERSON
Vernon
PERSON
Reid Weingarten
PERSONUSI Film Products
ORGANIZATIONWalker
PERSONCollins
PERSONWerner
PERSONThompson
PERSON
Dodge
ORGANIZATIONForde
ORGANIZATIONTracy
PERSON