United States v. Kil Soo Lee

This appeal raises the issue of whether a person arrested in American Samoa for allegedly committing federal crimes in American Samoa may be tried and convicted in the United States District Court for the District of Hawaii (“District Court”). Kil Soo Lee (“Lee”) was convicted of extortion, money laundering, conspiring to violate the civil rights of others, and holding workers to a condition of involuntary servitude. Lee argues that his conviction and sentence are void because, first, the District Court lacked jurisdiction, and, second, the District of Hawaii was an improper venue. We disagree. We hold that the District Court had jurisdiction, and the District of Hawaii was a proper venue, pursuant to 18 U.S.C. § 3231 , and 18 U.S.C. § 3238 , respectively.

I

BACKGROUND

Lee owned and operated a garment factory in American Samoa, an unincorporated territory of the United States located in the South Pacific. Lee recruited individuals from Vietnam, China, and American Samoa to work at the factory. Once the workers arrived in American Samoa, Lee controlled most aspects of their lives, including when and whether they could leave the compound, eat, or be paid.

Initially, Lee’s…