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On February 22, 2013, in United States v. Izurieta, the U.S. Court of Appeals for the Eleventh Circuit found 18 U.S.C. § 545—a federal statute criminalizing the importation of goods “contrary to law”—ambiguous as to whether it criminalizes violations of a regulation and, as a result, applied the rule of lenity. In reaching this conclusion, the court rejected approaches espoused by two split circuits, instead examining whether the regulation appears civil or criminal in nature. To avoid this type of uncertainty, this Comment argues that courts should instead apply the rule of lenity consistently based on § 545’s ambiguous text and history, rather than examine the nature of each regulation.


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8 Sep 2022
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  • Subject
    • Administrative Law

    • Criminal Law

    • Criminal Procedure

    • Food and Drug Law

    • International Trade Law

  • Journal title
    • Boston College Law Review

  • Volume
    • 55

  • Issue
    • 6

  • Pagination
    • E. Supp. 115

  • Date submitted

    8 September 2022