Ninth Circuit: US v. Pepe

Post-conviction amendment of statute prohibiting certain conduct when travelling abroad to include conduct while residing abroad permits abrogation of circuit precedent that held the earlier form to include both travelling and residence.  Lenity, Constitutional avoidance.

Dissent: It was a clarifying amendment in light of uniform judicial interpretation that both meanings were originally included.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/07/11/14-50095.pdf