US-CA9 · jury_instructions
9th Cir. Model Jury Instr. (Criminal) 20.28
Persuading or Coercing to Travel to Engage in Prostitution or Sexual Activity (18 U.S.C. § 2422(a))
The defendant is charged in [Count _______ of] the indictment with [persuading] [inducing] [enticing] [coercing] travel to engage in [prostitution] [sexual activity] in violation of Section 2422(a) of Title 18 of the United States Code. For the defendant to be found guilty of that charge, the government must prove beyond a reasonable doubt:
[First, that [[on] [between]] [insert dates alleged] the defendant knowingly [persuaded] [induced] [enticed] [coerced] an individual to travel in [interstate] [foreign] commerce to engage in [prostitution] [describe proposed sexual activity] [.] [; and]]
[Second, that [if the sexual activity had occurred] [based upon the sexual activity that occurred], the defendant could have been charged with a criminal offense under the laws of [the United States] [insert the state or territory]. [In [state or territory], it is a criminal offense to [describe proposed sexual activity]]].
or
[First, that [[on] [between]] [insert dates alleged] the defendant knowingly attempted to [persuade] [induce] [entice] [coerce] an individual to travel in [interstate] [foreign] commerce to engage in [prostitution] [describe proposed sexual activity]; and
[Second, that [if the sexual activity had occurred] [based upon the sexual activity that occurred], the defendant could have been charged with a criminal offense under the laws of [the United States] [insert the state or territory]. [In [state or territory], it is a criminal offense to [describe proposed sexual activity]; [and]]
[[Second/Third], the defendant did something that was a substantial step toward committing the crime.]
A “substantial step” is conduct that strongly corroborated the defendant’s intent to commit the crime. To constitute a substantial step, a defendant’s act or actions must unequivocally demonstrate that the crime will take place unless interrupted by independent circumstances. Mere preparation is not a substantial step toward committing the crime.
Jurors do not need to agree unanimously as to which particular act or actions constituted a substantial step toward the commission of a crime.]
Provenance
- Source
- ce9.uscourts.gov
- Retrieved
- 2026-08-20
- Edition
- 2026-08-20
- Content hash
b33e75400db095259f5fb1b5cf207dd23c56cf1aba18da66fa7e9e211ae007c2
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