US v. Johnson

U.S. v. Johnson, 194 F.3d 657 (5th Cir. 1999)

Johnson burned down a church, pled guilty, then challenged the conviction on the grounds that the jurisdictional element (interstate commerce) wasn't met. Judge Benavides, citing Rea and Robinson, with no analysis, said that the JE was not a prerequisite to SMJ, but merely an element of the offense.

References

US v. Rea, 169 F.3d 1111 (8th Cir. 1999)

US v. Robinson, 119 F.3d 1205 (5th Cir. 1997)

Citing references

US v. Reasor, 418 F.3d 466 (5th Cir. 2005)

US v. Nukida, 8 F.3d 665 (9th Cir. 1993)

US v. Barone, 71 F.3d 1442 (9th Cir. 1995)

U.S. v. Bustos-Useche, 273 F.3d 622 (5th Cir. 2001)