Page 24 - PCPA Winter 2025 Bulletin Magazine

PA CHIEFS OF POLICE ASSOCIATION
CHRIS BOYLE'S LEGAL UPDATE:
UNITED STATES V. RONK, 2025 U.S. DIST. LEXIS 214309
When a word like “involving” is not defined within a statute,
the court construes it in accordance with its ordinary
meaning. United States v. Husmann, 765 F.3d 169, 173
(3d Cir. 2014). Courts look to dictionary definitions to
determine the ordinary meaning of a word, Id. (citing
United States v. Geiser, 527 F.3d 288, 294 (3d Cir. 2008)).
But the court may not do so blindly. United States v. Brown,
740 F.3d 145, 149 (3d Cir. 2014) (quoting FDIC v. Meyer,
510 U.S. 471, 476 (1994)) (cleaned up). That is, “resorting
to dictionary definitions may be helpful[,]” however, “the
touchstone of statutory analysis should, again, be the
statute itself.” Id. (citations omitted). “After all, ‘[a] word
in a statute may or may not extend to the outer limits of
its definitional possibilities.’” Husmann, 765 F.3d at 173
(quoting Dolan, 546 U.S. at 486). Therefore, “interpretation
of a word or phrase depends upon reading the whole
statutory text, considering the purpose and context of the
statute, and consulting any precedents or authorities that
inform the analysis.” Id. (cleaned up).
To determine the meaning of “involving” in 18 U.S.C. §
2260A, the court considers “definitions of the term, the
statutory context, and the case law.” Id. The base word
“involve” is a word with various dictionary definitions. See
United States v. Chau, 293 F.3d 96, 102 (3d Cir. 2002)
According to Merriam-Webster, those various (non-
archaic) definitions include: 1a) “to engage as [*38] a
participant”; 1b) “to oblige to take part”; 1c) “to occupy
(someone, such as oneself) absorbingly especially :to
commit (someone) emotionally”; 2a) “to have within or as
part of itself” as in “include”; 2b) “to require as a necessary
accompaniment” as in “entail”; 2c) as in the word “affect”;
3) “to relate closely” as in the word “connect”; and 4) “to
surround as if with a wrapping” as in “envelop.”13
Consequently, such dictionary definitions can have
restrictive and broad meanings when applied to the phrase
“involving a minor” in 18 U.S.C. § 2260A. Christopher v.
United States, 148 F.4th 885, 894 (7th Cir. 2025) (comparing
the narrower “to require as a necessary accompaniment”
with the broader “to relate closely”). In other contexts, the
Third Circuit Court of Appeals has determined that “[t]he
plain meaning of ‘involve’ is ‘to relate closely’ or to ‘connect
closely.’” United States v. Daniels, 915 F.3d 148, 153 (3d
Cir. 2019) (citing United States v. Gibbs, 656 F.3d 180, 184-
85 (3d Cir. 2011); United States v. McKenney, 450 F.3d
39, 43 (1st Cir. 2006); Webster’s Third New International
Dictionary 1191 (1993); The American Heritage Dictionary
921 (4th ed. 2000)). Specifically, when used in the context
of the Armed Career Criminal Act (“ACCA”), 18 U.S.C.
§ 924(e), “involving” takes on a broad meaning and
encompasses attempt crimes. Daniels, 915 F.3d at 157
(discussing 18 U.S.C. § 924(e)(2)(A)(i)).
Although a shortcut to a conclusion now emerges, the
court will not blindly apply the “to relate closely” [*39]
definition from the dictionary. See Alli v. Decker, 650 F.3d
1007, 1016 (3d Cir. 2011) (“over-reliance on dictionaries—
to the exclusion of sources such as adjacent statutory
provisions—can lead a court astray.”). Furthermore,
although it makes for a compelling argument, the court will
not apply the “plain meaning” of “involving” in 18 U.S.C.
§ 924(e)(2)(A)(i) to 18 U.S.C. § 2660A because “[w]hen
Congress writes, context matters,” see Clean Air Council
v. United States Steel Corp., 4 F.4th 204, 206 (3d Cir.
2021), and these two statutes address different legislative
concerns. Rather, the analysis moves a consideration of
the specific purpose and specific context of Section 2660A.
Section 2260Awas added to Chapter 110 of Title 18
by the Adam Walsh Child Protection and Safety Act of
2006 (“Adam Walsh Act”). Pub. L No. 109-248, Title VII,
§ 702, July 27, 2006, 120 Stat 587. The 109th Congress
passed the Adam Walsh Act “[t]o protect children from
sexual exploitation and violent crime, to prevent child
abuse and child pornography, to promote Internet safety,
and to honor the memory of Adam Walsh and other child
crime victims.” Id.; see also Bakran v. Sec’y, United States
Dep’t of Homeland Sec, 894 F.3d 557, 567 (3d Cir. 2018)
(collecting cases finding that the Adam Walsh Act was
enacted to prevent future harm).
The Adam Walsh Act was enacted, in part, “to close the
loopholes in previous sex offender registration legislation
and to standardize registration across the states.” United
States v. Shenandoah, 595 F.3d 151, 154 (3d Cir. 2010),
abrogated on other grounds by Reynolds v. United States,
565 U.S. 432 (2012) (footnote omitted). Title I of the Adam
Walsh Act contains the originally enacted provisions of
the Sex Offender Registration and Notification [*40] Act
(“SORNA”). Id.
In enacting 18 U.S.C. § 2260A specifically, Congress
clearly sought to prevent child sexual exploitation (and
honor child crime victims) by imposing a mandatory 10-year
consecutive sentence on specific recidivists — individuals,
already registered as sex offenders, who committed felony
offenses involving children. Consequently, the purpose and
context of the Adam Walsh Act supports a broad meaning
of “involving” within in the phrase “involving a minor” in
18U.S.C. § 2260A. See United States v. Slaughter, 708
F.3d 1208, 1216 (11th Cir. 2013) (“We cannot say that this
stated purpose would be furthered by treating a recidivist
13 Involve, Merriam-Webster.com Dictionary, https://www.merriam-web-
ster.com/dictionary/involve (last updated Oct. 23, 2025 (example sen-
tences)) (last accessed Oct. 28, 2025).
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