## Facts

- Donald Lynn Baggett and Catherine Baggett married in Tennessee in November 1998; the relationship involved prior physical abuse.
- In May 1999, Catherine accompanied Baggett, an interstate truck driver, on a long-haul trip.
- While returning to Tennessee and traveling through Oklahoma, an argument escalated into violence while Baggett was driving; he struck Catherine’s head against the steering wheel, tore her shirt, and choked her.
- Baggett stopped at a rest area, forced Catherine into the sleeper compartment, and repeatedly assaulted her (slapping, punching, kicking, choking, and spitting on her).
- Baggett ordered Catherine to remain in the sleeper and out of sight; Catherine testified she did not feel safe or free to leave and complied as Baggett continued driving across state lines.
- Baggett continued beating Catherine during the trip; she later received a concussion diagnosis.
- After arriving in Memphis, Tennessee, Catherine exited the truck to use a warehouse bathroom and collapsed; an employee found her with blood, bruises, and red marks.
- Medical testimony described extensive upper-body injuries; Catherine reported multiple assaults in multiple states.
- After arrest, Baggett stated assaults occurred in Oklahoma and Arkansas but not Tennessee.
- A jury convicted Baggett of interstate domestic violence (18 U.S.C. § 2261(a)(2)) and kidnapping (18 U.S.C. § 1201); the district court granted a post-verdict judgment of acquittal on both counts for insufficient evidence.

## Issues

1. Whether sufficient evidence supported conviction under 18 U.S.C. § 2261(a)(2), including whether the “in the course of or as a result of” requirement limits liability to violence occurring only after a state line is crossed.
2. Whether sufficient evidence supported conviction under 18 U.S.C. § 1201 for kidnapping, including whether force, threats, and confinement in a moving truck established unlawful confinement and holding in connection with interstate transportation.
3. Whether the district court improperly displaced the jury’s role when assessing credibility and drawing inferences under the sufficiency-of-the-evidence standard.

## Decision

- The Sixth Circuit reversed the district court’s judgment of acquittal and remanded with instructions to reinstate the jury’s guilty verdict.
- The court held the evidence was sufficient for a rational juror to find interstate domestic violence under § 2261(a)(2).
- The court held the evidence was sufficient for a rational juror to find kidnapping under § 1201.
- Applying the sufficiency standard, the court viewed the evidence in the light most favorable to the government and concluded the district court had drawn inferences against the verdict and intruded on the jury’s factfinding.

## Legal Principles

- On review of a post-verdict judgment of acquittal, evidence must be viewed in the light most favorable to the prosecution; the verdict stands if any rational trier of fact could find each element beyond a reasonable doubt.
- 18 U.S.C. § 2261(a)(2) covers crimes of violence committed “in the course of or as a result of” causing a spouse or intimate partner to travel in interstate commerce by force, coercion, duress, or fraud; it does not require the violence to occur only after the victim crosses a state line.
- A jury may infer coerced interstate travel where violence and threats effectively compel the victim to remain in interstate movement, including continued travel in a confined setting.
- Federal kidnapping under 18 U.S.C. § 1201 may be established by force and threats that unlawfully confine a victim and cause continued detention; psychological coercion and a reasonable fear of leaving can support involuntariness.
- Credibility determinations and reasonable inferences about fear, coercion, and confinement are for the jury, not the trial judge, when evidence permits competing interpretations.

## Conclusion

The Sixth Circuit held that a jury could reasonably find that Baggett’s violence and coercion compelled his spouse’s continued interstate travel and confinement in the truck, satisfying § 2261(a)(2) and § 1201; it therefore reversed the judgment of acquittal and ordered reinstatement of the guilty verdict.


United States v. Baggett, 251 F.3d 1087 (6th Cir. 2001)