Fugit v. United States

Under 18 U.S.C. § 2422(b), one may not entice a minor "to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense." Does the "sexual activity" element require the defendant to make or attempt physical contact with a minor, as the Seventh Circuit holds, or may a single Internet chat and phone call with no attempted physical contact with a minor satisfy the element, so long as the defendant caller was involved in the "active pursuit of [his own] libidinal gratification," as the Fourth Circuit holds.