## Facts

- Laurence John Layton was a member of the Peoples Temple and lived at the Jonestown settlement in Guyana.
- In November 1978, U.S. Congressman Leo J. Ryan traveled to Jonestown to investigate allegations about conditions and treatment of residents.
- After Ryan’s visit, several residents sought to leave with Ryan’s group on November 18, 1978, traveling to the Port Kaituma airstrip to depart by plane.
- Shortly before the departure, Layton met with Peoples Temple leader Jim Jones, then announced he also wished to leave with Ryan’s group; some members of the group suspected his claimed desire to leave was a pretext.
- At the airstrip, armed Peoples Temple members attacked Ryan’s party, killing Ryan and others and wounding additional persons, including a U.S. diplomat.
- Trial evidence included that Layton boarded a plane, produced a weapon, and fired at passengers during the airstrip events.
- A federal jury in the Northern District of California convicted Layton of conspiracies and aiding-and-abetting offenses involving the killing of a member of Congress and the attempted killing of an internationally protected person under 18 U.S.C. §§ 351, 1116, and 1117.
- After conviction, Layton challenged the statutes’ application to conduct in Guyana and separately sought relief under 28 U.S.C. § 2255 for ineffective assistance of counsel; the district court denied both challenges.

## Issues

1. Whether 18 U.S.C. § 351 and 18 U.S.C. §§ 1116–1117 apply to covered offenses committed outside the United States.
2. Whether the evidence was sufficient to support Layton’s convictions for conspiracy and aiding and abetting.
3. Whether alleged instructional, evidentiary, and procedural errors required reversal.
4. Whether Layton was entitled to § 2255 relief for ineffective assistance of counsel.

## Decision

- The Ninth Circuit affirmed the convictions and affirmed the denial of Layton’s § 2255 motion.
- The court held that §§ 351 and 1116–1117 reach qualifying conduct abroad when the protected victim categories are involved (member of Congress; internationally protected person).
- The court concluded the record contained sufficient evidence for a rational jury to find Layton knowingly joined the conspiracies and intentionally aided the charged offenses.
- The court rejected asserted trial-error claims, finding no reversible error under the applicable standards of review.
- Applying the Sixth Amendment ineffective-assistance framework, the court held Layton failed to show deficient performance and resulting prejudice warranting collateral relief.

## Legal Principles

- Federal criminal statutes may apply extraterritorially when congressional intent is shown by statutory purpose, structure, and legislative history, including protection of U.S. governmental functions and implementation of treaty-based protections for internationally protected persons.
- Prosecution of offenses committed abroad against U.S. officials and protected persons is consistent with due process when there is a substantial nexus to U.S. interests and accepted jurisdictional bases support the exercise of jurisdiction.
- Sufficiency-of-the-evidence review asks whether, viewing the evidence in the light most favorable to the government, a rational jury could find the essential elements beyond a reasonable doubt.
- Ineffective assistance requires proof of both deficient performance and a reasonable probability of a different outcome absent the alleged errors.

## Conclusion

The court upheld Layton’s convictions arising from the Port Kaituma airstrip attack, ruling that the federal protections for members of Congress and internationally protected persons extend to qualifying conduct abroad, and it found the trial evidence and proceedings supported the verdict while the collateral ineffective-assistance challenge failed under the governing constitutional test.


United States v. Layton, 855 F.2d 1388 (9th Cir. 1988)