18 U.S.C. § 25

Use of minors in crimes of violence

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(a)Definitions.—In this section, the following definitions shall apply:(1)Crime of violence.—The term “crime of violence” has the meaning set forth in section 16.(2)Minor.—The term “minor” means a person who has not reached 18 years of age.(3)Uses.—The term “uses” means employs, hires, persuades, induces, entices, or coerces.(b)Penalties.—Any person who is 18 years of age or older, who intentionally uses a minor to commit a crime of violence for which such person may be prosecuted in a court of the United States, or to assist in avoiding detection or apprehension for such an offense, shall—(1) for the first conviction, be subject to twice the maximum term of imprisonment and twice the maximum fine that would otherwise be authorized for the offense; and(2) for each subsequent conviction, be subject to 3 times the maximum term of imprisonment and 3 times the maximum fine that would otherwise be authorized for the offense.(Added Pub. L. 108–21, title VI, § 601[(a)], Apr. 30, 2003, 117 Stat. 686.)

Notes of Decisions

Cited in 18 cases (1 in the last 5 years), 2006–2023 · leading case: United States v. Joseph Simms, 914 F.3d 229 (4th Cir. 2019).

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United States v. Joseph Simms, 914 F.3d 229 (4th Cir. 2019). · cites it 2× “used to conduct or facilitate” a crime of violence); 18 U.S.C. § 25 (b) (multiplying maximum sentence for adult who “intentionally uses a minor to commit a [federal] crime of violence”).”

Sessions v. Dimaya, 138 S. Ct. 1204 (2018). “See 18 U. S. C. §§25 (a)(1), 842(p)(2), 1952(a), 1956(c)(7)(B)(ii), 1959(a)(4), 2261(a), 3561(b).”

Irma Ovalles v. United States, 905 F.3d 1231 (11th Cir. 2018). · cites it 2× “For example, 18 U.S.C. § 25 criminalizes and provides penalties for an adult "who intentionally uses a minor to commit a crime of violence," as that term is defined in § 16.”

United States v. Gregorio Gonzalez-Longoria, 831 F.3d 670 (5th Cir. 2016). “, 18 U.S.C. § 25 (a)(1) (use of minor to commit a crime of violence); § 931(a)(1) (purchase of body armor by violent felons); § 1956(c)(7)(B)(ii) (money laundering); see also 18 U.”

United States v. Fish, 758 F.3d 1 (1st Cir. 2014). · cites it 2× “§ 1227 (a)(2)(E)(i) (allowing deportation of any alien who commits a crime of violence against a domestic relation); 18 U.S.C. § 25 (doubling the statutory maximum sentence if a defendant intentionally uses a minor to commit a crime of violence).”

United States v. Daye, 571 F.3d 225 (2d Cir. 2009). “, 18 U.S.C. § 25 (criminalizing the use of a minor to commit a crime of violence).”

Royer v. United States, 324 F. Supp. 3d 719 (E.D. Va. 2018). · cites it 2× “See 18 U.S.C. §§ 25 (a)(1), 842(p)(2), 1952(a), 1956(c)(7)(B)(ii), 1959(a)(4), 2261(a), 3561(b).”

Khan v. United States, 330 F. Supp. 3d 1076 (E.D. Va. 2018). · cites it 2× “See 18 U.S.C. §§ 25 (a)(1), 842(p)(2), 1952(a), 1956(c)(7)(B)(ii), 1959(a)(4), 2261(a), 3561(b).”

United States v. Handley, 564 F. Supp. 2d 996 (S.D. Iowa 2008). “” 18 U.S.C. § 25 (a)(2). Thus, while the term is not explicitly defined in 18 U.”

United States v. Lopez, 252 F. App'x 908 (10th Cir. 2007). · cites it 2× “§§ 1112 and 1153, and two counts of using a minor to commit a violent crime, in violation of 18 U.S.C. §§25 and 1153. He argues that (1) the evidence was insufficient to prove that he killed the victim, or aided and abetted the person who did; and (2) the district court erred in…”

United States v. Witt, 187 F. App'x 406 (5th Cir. 2006). “Finally, Witt asserts that the judgment should be corrected to omit a reference to 18 U.S.C. § 25 . He argues that the Government agreed to drop the sentencing enhancement under that section in exchange for his guilty plea.”

Chapman v. United States, 326 F. Supp. 3d 228 (E.D. Va. 2018). · cites it 2× “See 18 U.S.C. §§ 25 (a)(1), 842(p)(2), 1952(a), 1956(c)(7)(B)(ii), 1959(a)(4), 2261(a), 3561(b).”

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