United States v. Hollinshead: A New Leap in Extraterritorial Application of Criminal Laws

In United States v. Hollinshead, the defendants were convicted of violating a federal penal statute and subjected to criminal penalties in the United States for the importation of Mayan artifacts illegally exported from Guatemala. The case held, in effect, that articles not characterized as stolen under the laws of the United States may still become the basis for violation of 18 USC § 2314, interstate transportation of stolen property. In his note, the author analyzes the usefulness of this decision in the extraterritorial applications of United States penal laws.