Clay v. United States
Petition for certiorari denied on November 17, 2025
Issue: (1) Whether the Foreign Commerce Clause empowers Congress to criminalize private, non-commercial conduct that occurs entirely abroad; and (2) whether Missouri v. Holland allows Congress to criminalize private, noncommercial conduct that occurs entirely abroad under the guise of implementing the Optional Protocol to the United Nations Convention on the Rights of the Child on the Sale of Children, Child Prostitution and Child Pornography.