United States v. Patricia King Hill

This appeal presents three questions: (1) whether it is constitutional to prosecute a wife for harboring her fugitive husband or for being an accessory after the fact to his crime; (2) whether the federal proscription against harboring a fugitive confers jurisdiction even if the harboring occurs outside the United States; and (3) whether an accessory indictment that fails to specify the principal’s crime is legally sufficient. Because we hold that the answer to the first two questions is “yes” and the answer to the third question is “no,” we affirm Patricia King Hill’s harboring conviction but reverse her accessory conviction.

I

FACTS AND PROCEDURAL HISTORY

This case arises from one man’s efforts to avoid paying more than $100,000 in past-due child support. In 1979, Charlie Hill (Charlie) divorced his wife, Victoria, in New Mexico. As part of the divorce decree, Charlie acknowledged that he was the father of two children born of the union and agreed to pay Victoria $450 per month for their support. Despite this agreement, he has made no voluntary support payments since 1979.

In November 1993, Charlie married the defendant/ appellant, Patricia King Hill (Hill), an attorney and…