United States v. Perrien

Brandon Perrien appeals his conviction on two counts of violating 18 U.S.C. § 113(a), which criminalizes assaults “within the special maritime and territorial jurisdiction of the United States.” The victims were Perrien’s twin three-month old daughters. Perrien challenges the sufficiency of the evidence that the assaults occurred within the special maritime and territorial jurisdiction of the United States, the sufficiency of the evidence that he committed the assaults, and the allowance of a two-level sentencing enhancement for “more than minimal planning.”

On the day the assaults were…