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Fourth Circuit

United States v. Schmidt, 845 F.3d 153 (4th Cir. 2017). Defendant who pled guilty to traveling in foreign commerce and engaging in illicit sexual conduct with minor challenged his sentence claiming insufficient evidence to support travel element of statute. Defendant spent 18 months in Philippines on series of two-month tourist visas. Term “traveling” denotes broad concept of movement abroad and may continue after significant amount of time in given location until party either returns to place of origin or permanently resettles elsewhere.