What is the test for determining whether a stolen quantity of gold or other precious metals travelled in interstate commerce?

MultiRegion, United States of America

The following excerpt is from United States v. Lowery, 18-198-cr (2nd Cir. 2019):

Here, the Government has met this low bar. The victim testified that some of the jewelry sold in his jewelry store is purchased in California, that some of his gold comes from Italy, and that two bags of gold were among the items stolen. App'x 83. Based on this testimony as well as common knowledge about the basic facts of the gold market, the jury could infer that some of the stolen items traveled in interstate commerce. See e.g., United States v. Gomez, 580 F.3d 94, 102 (2d Cir. 2009) (holding that a "juror is surely capable of drawing the conclusion that a robbery undertaken with the object of stealing from a drug dealer three kilos of cocaine . . . would have had at least the required de minimus [sic] effect on interstate commerce").

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