U.S. Court of Appeals for the First Circuit

United States v. Cooper

August 6, 2026

Summary

The court affirmed Cooper's convictions for sex trafficking and transporting a minor, holding that the listed acts in the sex-trafficking statute are alternative means of committing one offense and that the evidence supported both convictions. It vacated the forced-labor conviction because Cooper created a genuine factual dispute about whether venue existed in Massachusetts, requiring the jury to decide venue, and the instructional error was not harmless beyond a reasonable doubt. The court remanded for further proceedings limited to the forced-labor conviction.