United States v. Daniel Joseph Maravilla, United States v. Rafael Jesus Dominguez
1990 U.S. App. LEXIS 11363, 907 F.2d 216, 30 Fed. R. Serv. 600 (1990)
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Rule of Law:
The federal statute 18 U.S.C. § 242, which criminalizes the deprivation of civil rights of any "inhabitant" of a State or Territory, does not apply to a foreign citizen whose presence in the United States is for only a few hours with no intent to remain overnight.
Facts:
- On September 10, 1982, Yamil Mitri Lajam, a money courier and citizen of the Dominican Republic, arrived at the airport in Puerto Rico.
- Lajam was carrying approximately $700,000 in cash and checks for his employer, which he intended to deposit in a local bank.
- Lajam planned to complete his business and return to the Dominican Republic on the same day.
- At the airport, U.S. Customs officers Rafael Dominguez and Daniel Maravilla interviewed Lajam.
- Dominguez was seen leaving the customs office with Lajam, and Maravilla left around the same time.
- After leaving with Dominguez, Lajam was never seen alive again; he was kidnapped, murdered, and robbed of the money.
- Immediately following Lajam's disappearance, Dominguez and Maravilla, who previously had very little money, began spending and concealing large sums of cash.
Procedural Posture:
- The United States government indicted Rafael Dominguez and Daniel Maravilla in the U.S. District Court for the District of Puerto Rico.
- The charges included depriving an 'inhabitant' of civil rights under 18 U.S.C. § 242, robbery affecting interstate commerce, and other related offenses.
- Following a trial, a jury in the district court convicted both defendants on all counts.
- Dominguez and Maravilla, as appellants, appealed their convictions to the United States Court of Appeals for the First Circuit, with the United States as the appellee.
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Issue:
Does 18 U.S.C. § 242, which protects any 'inhabitant of any State, Territory, or District' from civil rights violations, apply to a foreign citizen who is in the United States for only a few hours with no intention of staying overnight?
Opinions:
Majority - Breyer, J.
No. A foreign citizen who visits the United States for only a few hours with no intent to stay overnight is not an 'inhabitant' within the meaning of 18 U.S.C. § 242. The court reasoned that the ordinary and legal meaning of 'inhabitant' requires a degree of dwelling, residing, or having a habitation that a brief, temporary daytime visit does not satisfy. An extensive review of dictionary definitions, other federal statutes, and case law consistently showed that 'inhabitant' implies a more significant connection to a place than a mere sojourn. The court distinguished the Ninth Circuit's decision in United States v. Otherson, which applied the statute to illegal aliens who presumably intended to remain in the country for some time, from the present case where the victim's transient intent was undisputed. To extend the word's meaning to cover such a temporary visitor would cast the criminal statute 'adrift from its linguistic moorings,' violating the principle that individuals can only be punished according to the law as written.
Concurring - Aldrich, J.
No. The word 'inhabit' has a 'clear implication of continuum.' A person cannot be considered an inhabitant of every town a bus passes through or stops in for a brief period, such as for lunch.
Concurring-in-part-and-dissenting-in-part - Torruella, J.
Yes. The term 'inhabitant' in 18 U.S.C. § 242 should be interpreted broadly to include all persons physically present within the jurisdiction of the United States, regardless of the duration of their stay. This broad construction is supported by the legislative history of the Civil Rights Act of 1866, which indicates an intent to protect 'all persons in the United States.' The criminal enforcement provision (§ 242) should be read coextensively with the substantive civil rights provision (now 42 U.S.C. § 1981), which protects 'all persons.' The majority's narrow interpretation creates an absurd result where an overnight traveler is protected but a daytime visitor is not, thwarting the statute's protective purpose and contradicting the Ninth Circuit's holding in United States v. Otherson.
Analysis:
This decision significantly narrows the scope of the federal criminal civil rights statute, 18 U.S.C. § 242, by creating a distinction based on the duration and intent of a non-citizen's presence in the country. It establishes that the term 'inhabitant' requires some form of residence or intent to remain, excluding tourists or business travelers on very short trips from the statute's protection. The ruling highlights the judicial tension between adhering to the plain linguistic meaning of a statute, particularly a criminal one, and interpreting it broadly to achieve its overarching legislative purpose. This precedent may force federal prosecutors in similar cases involving transient victims to rely on other federal or state criminal laws rather than § 242.
