11th Cir. Pattern Jury Instr. (Criminal) O92.1

Criminal Sexual Activity

18 U.S.C. § 2422(a)

It’s a Federal crime to [persuade] [induce] [entice] [coerce] an individual to

travel in interstate or foreign commerce with the intent that the individual engage

in [prostitution] [sexual activity for which any person can be charged with a

criminal offense].

The Defendant can be found guilty of this crime only if all the following

facts are proved beyond a reasonable doubt:

(1) the Defendant knowingly [persuaded] [induced] [enticed]

[coerced] [person named in indictment] to travel in [interstate]

[foreign] commerce;

(2) at the time the travel commenced, the Defendant intended that

[person named in indictment] would engage in [prostitution] [any

sexual activity for which any person can be charged with a

criminal offense].

[It is not necessary for the Government to prove anyone actually engaged in

any prostitution or other illegal sexual activity after traveling across state lines.

What the Government must prove beyond a reasonable doubt is that a person was

[persuaded] [induced] [enticed] [coerced] to travel across state lines by the

Defendant, and that the Defendant intended at the time for the person to engage in

prostitution or other illegal sexual activity, even if the person who traveled did not

have the same intention to engage in such activity.]

The Government must prove that, if the intended sexual activity had

occurred, [the Defendant] [one or more of the individuals engaging in the sexual

activity] could have been charged with a criminal offense under the laws of [state].

As a matter of law the following acts are crimes under [state] law. [Describe the

applicable state law].

[The term “sexual activity for which any person can be charged with a

criminal offense” includes the production of child pornography.]

[As used in this instruction, the term “prostitution” means engaging in or

agreeing or offering to engage in any lewd act with or for another person in

exchange for money or other consideration.]

[As used in this instruction, “induce” means to stimulate the occurrence of or

to cause.]

To “travel in interstate commerce” means to move from one state to another.

The term “State” includes a State of the United States, the District of Columbia,

and any commonwealth, territory, or possession of the United States. It is not

necessary to show that the Defendant knew that state lines were being crossed, but

the Government must prove that state lines were crossed.