Petitioner was convicted under 18 U.S.C. § 2241(c), which criminalizes "cross[ing]a state line with intent to engage in a sexual act with a person who has not attainedthe age of 12 years," and 18 U.S.C. § 2423(a), which criminalizes "knowinglytransport[ing] an individual who has not attained the age of 18 years in interstate orforeign commerce, or in any commonwealth, territory or possession of the UnitedStates, with intent that the individual engage in prostitution, or in any sexual activityfor which any person can be charged with a criminal offense." The two questionspresented are:
(1) What connection must exist between the defendant's travel and the unlawfulsexual act or sexual activity to support the exercise of federal jurisdiction under thesestatutes?
(2) What do the Constitution and Rule 7 of the Federal Rules of Criminal Procedurerequire the government to charge in an indictment when the statute defining theoffense contains a generic phrase such as "any sexual activity for which any personcan be charged with a criminal offense" that potentially encompasses a multitude ofcrimes?
What connection must exist between the defendant's travel and the unlawful sexual act or sexual activity to support the exercise of federal jurisdiction under these statutes?