United States v. Oropesa: Section 241 Applies to Conspiracies to Violate Rights Created by the FACE Act

I. Introduction

In United States v. Gabriella Victoria Oropesa, No. 25‑10928 (11th Cir. Nov. 20, 2025), the Eleventh Circuit addressed a novel and important question at the intersection of federal civil-rights criminal law and statutory clinic-access protections: may the federal conspiracy-against-rights statute, 18 U.S.C. § 241, be used to prosecute a conspiracy to violate rights created by the Freedom of Access to Clinic Entrances Act (“FACE Act”), 18 U.S.C. § 248?

The case arose from a series of politically motivated vandalism and threats directed at crisis-pregnancy centers (CPCs) in Florida by abortion-rights activists in the wake of intensified national debate over abortion. Rather than charging the defendant solely under the FACE Act, which includes its own set of criminal penalties and civil remedies, federal prosecutors also invoked § 241, a Reconstruction-era statute historically used to protect federal civil and constitutional rights from conspiratorial interference.

The appeal presented two principal questions:

Whether a conspiracy to violate the FACE Act can be charged under 18 U.S.C. § 241, given that the FACE Act contains its own “comprehensive” enforcement scheme with specific penalties and remedies.
Whether recent Supreme Court decisions—Fischer v. United States, 603 U.S. 480 (2024), and Snyder v. United States, 603 U.S. 1 (2024)—limited the ability of prosecutors to use § 241 as a supposedly “coverall” statute to increase the maximum penalty otherwise available under the FACE Act.

The Eleventh Circuit answered the first question decisively in favor of the government and rejected the second as largely irrelevant. The court held that:

Rights created by the FACE Act are “rights . . . secured by the . . . laws of the United States” within the meaning of § 241.
The FACE Act’s own enforcement provisions, including its saving clause expressly providing that its penalties are not exclusive, do not preclude § 241 conspiracy prosecutions.
Fischer and Snyder—both narrow statutory-interpretation decisions in different statutory schemes—do not materially affect the permissible scope of § 241 or its relationship to the FACE Act.

Judge Jordan concurred in the judgment and in all but one section of the per curiam opinion, offering a more focused, text-based analysis of the FACE Act’s saving clause and emphasizing the continued force of United States v. Johnson, 390 U.S. 563 (1968), a Supreme Court decision upholding use of § 241 to enforce Title II of the Civil Rights Act notwithstanding Title II’s own “exclusive means” language.

II. Summary of the Opinion

A. Factual Background

Beginning in spring 2022, Gabriella Oropesa and three co-activists (Caleb Freestone, Amber Smith‑Stewart, and Annarella Rivera) planned and executed a series of nighttime vandalism attacks against crisis-pregnancy centers in Florida. Wearing disguises, they spray-painted threatening and menacing messages on CPC buildings, including statements such as:

“If abortions aren’t SAFE then niether [sic] are you.”
“YOUR TIME IS UP!! WE’RE COMING for U.”
“We are everywhere.”

The group targeted CPCs in at least Hollywood, Winter Haven, and Hialeah, Florida. The government characterized the conduct as a coordinated effort to threaten and intimidate personnel at facilities that provide reproductive health services and counseling, and thus to interfere with the exercise of rights protected by the FACE Act.

Oropesa was indicted in the Middle District of Florida on a single count of conspiracy against rights under 18 U.S.C. § 241. Unlike her co-defendants, she was not charged with any substantive FACE Act violation, apparently because she did not personally vandalize a CPC located in the charging district.

B. District Court Proceedings

Oropesa moved to dismiss the indictment on three grounds (two of which matter here):

That § 241 requires “state action,” which she claimed was absent because the conspirators were private actors.
That the FACE Act is not among the “laws of the United States” whose violation may be the object of a § 241 conspiracy, primarily because Congress provided a dedicated enforcement scheme and specific penalties within the FACE Act itself.

The district court rejected these arguments, holding that:

State action is not an element of a § 241 conspiracy (a settled point in modern § 241 jurisprudence), and
The FACE Act does create a federal “right” that can be enforced through § 241.

Months after the deadline for pretrial motions, and on the eve of trial, Oropesa filed a second motion to dismiss, asserting that the Supreme Court’s intervening decisions in Fischer and Snyder “compel the conclusion” that the FACE Act cannot serve as a § 241 predicate. The district court denied the motion as untimely and found the cited cases irrelevant.

At trial, Oropesa renewed her arguments in an oral motion for judgment of acquittal. The court denied the motion, and the jury found her guilty on the § 241 conspiracy count. She was sentenced to 120 days’ imprisonment and three years of supervised release. She then brought this appeal.

C. Holdings on Appeal

The Eleventh Circuit affirmed, holding:

Substantive holding on § 241 and the FACE Act: A conspiracy to violate the FACE Act may be prosecuted under § 241. The FACE Act’s own enforcement regime does not exempt it from being a “law of the United States” whose violation can be the object of a § 241 conspiracy.
Procedural holding on the untimely motion: The district court did not abuse its discretion in denying Oropesa’s late second motion to dismiss; Fischer and Snyder did not constitute a relevant change in law that would supply “good cause” to excuse untimeliness.

Judge Jordan concurred, agreeing with the outcome and almost all of the reasoning, but emphasizing that:

The FACE Act’s explicit saving clause (“not . . . exclusive criminal penalties”) must be taken seriously, and
The § 1983 “comprehensive enforcement scheme” cases (like Sea Clammers and Rancho Palos Verdes) are inapposite in the § 241 criminal context, especially in light of Johnson.

III. Legal Framework and Key Statutes

A. Section 241 – Conspiracy Against Rights

Section 241 is a central criminal civil-rights statute, originating in the Enforcement Act of 1870, aimed at protecting federal rights against conspiratorial interference:

If two or more persons conspire to injure, oppress, threaten, or intimidate any person . . . in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised the same[,] . . . [t]hey shall be fined under this title or imprisoned not more than ten years, or both . . . .

Key features:

It criminalizes conspiracies (agreements) to interfere with federal rights, not merely completed rights violations.
It covers rights “secured” by both the Constitution and “laws of the United States,” i.e., federal statutes.
It carries a baseline maximum penalty of 10 years’ imprisonment, with enhanced penalties where death, kidnapping, aggravated sexual abuse, or attempted killing is involved.

The Supreme Court has consistently described § 241 as having broad textual reach. In United States v. Price, 383 U.S. 787, 800 (1966), the Court held that § 241 “embraces all of the rights and privileges secured to citizens by . . . all of the laws of the United States” (emphasis added).

B. The FACE Act – 18 U.S.C. § 248

The FACE Act was enacted in 1994 to address violence, threats, and obstruction at reproductive health facilities and places of worship. For present purposes, three core features matter:

It prohibits the use or threat of force and physical obstruction that injures, intimidates, or interferes with a person obtaining or providing “reproductive health services.” § 248(a)(1).
It prohibits similar conduct at places of religious worship. § 248(a)(2).
It prohibits intentional damage or destruction of the property of a facility providing reproductive health services. § 248(a)(3).

The FACE Act creates both:

Criminal penalties with tiered maximum sentences: up to 1 year for most first-time nonviolent offenses, up to 10 years for offenses resulting in bodily injury, and up to life for offenses resulting in death. § 248(b).
Civil remedies, including a private cause of action and injunctive relief.

Crucially, the Act contains a saving clause:

Nothing in this section shall be construed . . . to provide exclusive criminal penalties or civil remedies with respect to the conduct prohibited by this section, or to preempt State or local laws that may provide such penalties or remedies. (18 U.S.C. § 248(d)(3))

This language expressly disclaims exclusivity and invites the concurrent operation of other criminal and civil remedies at both federal and state levels.

IV. Detailed Analysis of the Court’s Reasoning

A. Section 241 Encompasses Conspiracies to Violate FACE Act Rights

1. Plain Text: “Laws of the United States” Means What It Says

The per curiam opinion begins from straightforward textualism:

Section 241 covers conspiracies to interfere with rights “secured . . . by the Constitution or laws of the United States.”
The Supreme Court has interpreted “laws of the United States” to mean “federal law” generally. See, e.g., United States v. Kozminski, 487 U.S. 931, 941 (1988); United States v. Waddell, 112 U.S. 76, 79 (1884); and Health & Hospital Corp. v. Talevski, 599 U.S. 166, 172 (2023) (“‘Laws’ means ‘laws,’ no less today than in the 1870s.”).
The FACE Act is plainly a federal law and, by its terms, provides a right to be free from threatened or actual force while seeking to obtain or provide reproductive health services. § 248(a)(1).

The defendant effectively conceded that:

The FACE Act creates an individual right, and
It is a “law of the United States.”

Thus, under the straightforward reading of § 241, a conspiracy to violate those FACE Act rights falls squarely within the statute. The court cites Price and underscores that it is “incumbent upon us to read § 241 with full credit to its language.”

2. The Attempted Importation of § 1983 “Comprehensive Enforcement Scheme” Doctrine

Recognizing the difficulty of arguing against the plain text of § 241, Oropesa pivoted to an analogy: she argued that the FACE Act’s dedicated enforcement structure (criminal penalties, civil actions, and remedies) constitutes a “comprehensive enforcement scheme” that implicitly precludes § 241 prosecutions, much as similar schemes sometimes foreclose actions under 42 U.S.C. § 1983.

Under modern § 1983 doctrine, a plaintiff may only sue to enforce a federal statute if:

The statute clearly confers an individually enforceable “right” (as distinguished from vague “benefits” or “interests”), and
Congress has not otherwise indicated that § 1983 enforcement is precluded—one such indicator being a “comprehensive enforcement scheme” that is “incompatible” with § 1983 suits. See, e.g., Blessing v. Freestone, 520 U.S. 329, 341 (1997); Gonzaga Univ. v. Doe, 536 U.S. 273, 283 (2002); City of Rancho Palos Verdes v. Abrams, 544 U.S. 113, 119–21 (2005); Middlesex Cnty. Sewerage Auth. v. Nat’l Sea Clammers Ass’n, 453 U.S. 1, 19–20 (1981); Smith v. Robinson, 468 U.S. 992 (1984).

The Eleventh Circuit explains why this analogy is misplaced:

The § 1983 “comprehensive scheme” doctrine grew out of concerns about implied private rights of action and separation of powers—courts are reluctant to assume Congress silently authorized private damages suits every time it enacted a regulatory statute. See Medina v. Planned Parenthood S. Atl., 145 S. Ct. 2219, 2229–33 (2025).
By contrast, § 241 is itself a criminal enforcement statute enacted by Congress to provide broad protection to all federal rights; there is no question of judicially “implying” anything. Congress, through § 241, has already expressly authorized federal criminal enforcement against conspiracies to violate “all” federal rights. See Price, 383 U.S. at 802–03.
The presence of a statutory enforcement scheme in the underlying substantive statute (here, the FACE Act) says nothing about whether that statute is a “law of the United States” within the meaning of § 241—and the defendant conceded that it is.

In short, § 1983 limits are about who may sue (private parties) and whether courts should infer new remedies; § 241 is about what conduct the federal government may criminally punish, under an enforcement mechanism (criminal prosecution) that Congress has explicitly created.

3. FACE Act’s Enforcement Scheme Is Not “Comprehensive” in Any Excluding Sense

Even if one assumed, counterfactually, that a sufficiently “comprehensive” enforcement scheme in a statute could limit § 241’s reach, the FACE Act would not qualify.

The key textual feature is § 248(d)(3):

Nothing in this section shall be construed . . . to provide exclusive criminal penalties or civil remedies with respect to the conduct prohibited by this section . . . .

The majority and the concurrence both take this language seriously:

Congress explicitly disclaimed that FACE Act criminal penalties are exclusive. That is, Congress anticipated and permitted overlap with other criminal enforcement tools.
A § 241 conspiracy charge is such a separate offense. The Supreme Court has long recognized that a criminal conspiracy is distinct from its underlying substantive crime and may be punished more harshly. See Iannelli v. United States, 420 U.S. 770, 777–78 (1975); Callanan v. United States, 364 U.S. 587, 593–97 (1961); Clune v. United States, 159 U.S. 590, 594–95 (1895).

Accordingly, nothing in the FACE Act suggests Congress “did not intend” § 241 to apply to conspiracies targeting rights it creates. If anything, the explicit non-exclusivity clause points the other way.

4. Distinguishing the Second Circuit’s DeLaurentis Decision

Oropesa could point to United States v. DeLaurentis, 491 F.2d 208 (2d Cir. 1974), where the Second Circuit held that § 241 could not be used to criminally enforce the National Labor Relations Act (NLRA), which merely defined “unfair labor practices” and provided no criminal or private civil cause of action.

The Eleventh Circuit distinguishes DeLaurentis on two grounds:

The NLRA section in DeLaurentis conferred no individual rights with associated penalties; Congress had designed a specialized administrative scheme (via the NLRB) with no criminal penalties at all. The Second Circuit found it implausible that Congress meant such provisions to be enforced via § 241.
By contrast, the FACE Act both creates individual rights and provides explicit criminal penalties and civil remedies, while also stating that those penalties are not exclusive. This is the opposite of the statutory structure in DeLaurentis.

Thus, DeLaurentis is “distinguishable and inapposite.”

B. Fischer and Snyder Do Not Undermine Section 241–FACE Act Overlap

1. The Fischer Argument

In Fischer v. United States, the Supreme Court interpreted 18 U.S.C. § 1512(c)(2), which penalizes one who “otherwise obstructs, influences, or impedes any official proceeding,” as limited by § 1512(c)(1), which addresses corrupt alteration or destruction of records and documents used in an official proceeding.

Applying canons of statutory interpretation, the Court in Fischer rejected a reading of “otherwise obstructs” so broad that it would swallow the rest of § 1512 and override Congress’s “careful delineation” of specific obstruction offenses and penalties elsewhere in the same statute.

Oropesa analogized:

If § 241 can be used whenever any federal right is implicated, it allegedly functions as a “catchall” that overrides Congress’s calibrated penalty structure in specific statutes like the FACE Act.

The Eleventh Circuit found Fischer “essentially irrelevant”:

Fischer dealt with two provisions in the same statute (different subsections of § 1512), where a broad reading of one would render the others superfluous or inconsistent.
Here, § 241 and the FACE Act are separate statutes that create distinct offenses: § 241 targets conspiracies to violate rights; the FACE Act targets substantive interference or damage.
Moreover, the FACE Act affirmatively disclaims exclusivity of its penalties, undercutting any suggestion that allowing a § 241 conspiracy charge would “override Congress’s careful delineation” of penalties in § 248.

In short, Fischer is about internal harmonization of a single statute; it does not speak to the coexistence of multiple statutes where Congress has expressly invited non-exclusive enforcement.

2. The Snyder Argument

In Snyder v. United States, the Supreme Court held that 18 U.S.C. § 666(a)(1)(B), which covers public officials who “corruptly solicit” benefits “intending to be influenced” in their official duties, criminalizes bribes but not post hoc gratuities.

Aside from textual analysis, the Snyder Court noted a structural concern: interpreting § 666 to cover gratuities would create a sentencing anomaly—gratuities for state and local officials would carry up to 10 years’ imprisonment under § 666, while similar conduct by federal officials would be punishable by only 2 years under the distinct federal gratuities statute, 18 U.S.C. § 201(c). The Court was skeptical that Congress intended such disparity for identical misconduct.

Oropesa argued by analogy that allowing § 241 to apply on top of the FACE Act similarly produces “substantial sentencing disparities” between essentially the same conduct:

Many nonviolent first-time FACE Act violations carry a maximum of 1 year, § 248(b)(1), whereas a § 241 conspiracy—even without bodily injury—carries a 10-year maximum.

The Eleventh Circuit rejected this analogy:

In Snyder, the issue was identical conduct (gratuities to officials) facing drastically different penalties depending only on whether the official was federal or state. The Court resisted that interpretation.
Here, by contrast, § 241 and the FACE Act punish different offenses:
- A substantive interference or damage offense (FACE Act), versus
- A conspiracy to violate rights (Section 241).
It has long been accepted that Congress may punish conspiracy more heavily than the completed substantive offense. Clune, 159 U.S. at 595; Iannelli, 420 U.S. at 776–78.
Therefore, there is nothing anomalous or constitutionally problematic about a scenario where a § 241 conspiracy carries a higher maximum sentence than a first-time, nonviolent substantive FACE Act offense.

The court thus concluded that neither Fischer nor Snyder changed the legal landscape in a way that would justify a late-filed motion to dismiss.

C. Timeliness and “Good Cause” for Late Motions

Under Federal Rule of Criminal Procedure 12, certain pretrial motions must be filed by a court-ordered deadline. A court may consider an untimely motion only for “good cause.”

Oropesa argued that Fischer and Snyder represented a “change in law” that supplied good cause. The Eleventh Circuit disagreed, finding that:

The Supreme Court decisions did not address § 241 or the FACE Act and did not cast doubt on the well-established principle that § 241 covers conspiracies to violate federal statutory rights.
Because the cases were inapposite, they did not amount to a change in relevant law, and thus could not justify excusing the untimeliness of the second motion to dismiss.

Even if the issues preserved only a “plain error” standard of review, the court explicitly noted that Oropesa’s arguments would fail under any standard.

D. Judge Jordan’s Concurrence: Focusing on the Saving Clause and Johnson

Judge Jordan joined almost all of the majority opinion but parted ways with one aspect: the suggestion that, hypothetically, a “comprehensive enforcement scheme” in some future statute might limit § 241’s scope. He saw no reason even to leave that door ajar.

1. Distinguishing the § 1983 Saving-Clause Cases

Jordan carefully distinguishes three Supreme Court § 1983 cases involving saving clauses:

Middlesex Cnty. Sewerage Auth. v. Nat’l Sea Clammers Ass’n, 453 U.S. 1 (1981).
City of Rancho Palos Verdes v. Abrams, 544 U.S. 113 (2005).
Health & Hosp. Corp. v. Talevski, 599 U.S. 166 (2023).

In each, the relevant saving clause was materially different from the FACE Act’s saving clause:

In Sea Clammers, the clause preserved rights under “any statute or common law,” which the Court thought likely did NOT include the very statute in which the saving clause appeared. By contrast, § 248(d)(3) of FACE explicitly speaks of the “conduct prohibited by this section” and non-exclusivity of “criminal penalties.”
In Rancho Palos Verdes, the clause protected federal, state, or local law from being “modified,” “impaired,” or “superseded” absent express provision. The Court held that “impair” was too weak a textual hook to overcome the strong inference that Congress did not intend § 1983 suits on top of the Telecommunications Act’s specific remedy structure.
In Talevski, the clause said remedies were “in addition to those otherwise available,” which the Court interpreted to require asking whether other remedies (like § 1983) were “otherwise available” in the first place; the clause did not independently resolve the § 1983 question.

Jordan’s point: the FACE Act’s saving clause is not linguistically or functionally identical to these clauses, and its explicit reference to criminal penalties sets it apart.

2. Johnson and Criminal Saving Clauses

Jordan emphasizes United States v. Johnson, 390 U.S. 563 (1968), which has not been overruled and directly addresses a statutory saving clause in the context of § 241.

In Johnson:

Defendants assaulted Black patrons exercising their right to equal access to public accommodations at a restaurant.
The government prosecuted under § 241, with the right at issue grounded in Title II of the Civil Rights Act of 1964.
Title II contained a saving clause stating that “remedies provided in this title shall be the exclusive means of enforcing the rights based on this title,” but preserving any rights under “other Federal or State law” and any “remedy, civil or criminal.”

The Supreme Court held that this language did not preclude § 241 prosecutions, because it affirmatively preserved criminal remedies under other federal laws. Jordan argues that, similarly, the FACE Act’s saving clause—explicitly stating that its criminal penalties are not exclusive—cannot plausibly be read as an implicit bar to § 241.

3. No Transplanting of § 1983 Doctrine into § 241

Jordan concludes that:

The § 1983 “comprehensive enforcement scheme” doctrine derives from separation-of-powers concerns in the civil context and should not be “engrafted” onto a criminal statute like § 241.
To do so would improperly constrain Congress’s explicit decision to create a broad federal criminal remedy against conspiracies that interfere with any federal right.
The proper approach is to take Congress at its word in § 248(d)(3) and § 241’s text, without layering on judge-made limitations arising from a different context.

V. Complex Concepts Explained in Plain Terms

A. What Is a “Conspiracy Against Rights” Under § 241?

A conspiracy, in basic criminal law, is an agreement between two or more people to commit a crime, plus (in most contexts) at least one overt act in furtherance of the agreement. Under § 241, the “crime” agreed upon is to injure, threaten, or intimidate someone in the exercise of a federal right (constitutional or statutory).

Important features:

The government does not have to prove that the conspirators succeeded in fully preventing the exercise of the right; the agreement and acts to carry it out may suffice.
State action is not required; purely private conspiracies may fall under § 241 where the right at issue is one that federal law secures against private interference.
Because conspiracy is considered a distinct wrong—group criminality poses special social dangers—Congress may punish it separately and more harshly than the completed underlying offense.

B. “Comprehensive Enforcement Scheme” – What Does That Mean?

A statute has a “comprehensive enforcement scheme” when Congress has built into it a detailed set of enforcement mechanisms and remedies—for example:

Specific administrative procedures and hearings.
Prescribed civil actions (who may sue, in what court, for what kinds of relief).
Explicit criminal penalties for defined violations.

In the § 1983 context, courts sometimes infer from such a scheme that Congress did not intend to allow private plaintiffs to bypass that scheme by bringing separate § 1983 lawsuits, unless Congress clearly said otherwise.

However, as this case underscores, that inference is about civil, private enforcement—not about whether the federal government may use an already existing criminal statute (§ 241) to prosecute conspiracies to violate the rights created by such laws.

C. Saving Clauses and Non-Exclusivity

A “saving clause” is a statutory provision stating that the new statute does not repeal, limit, or preempt other sources of law or remedies unless explicitly stated. In the FACE Act, the saving clause does two things:

It disclaims exclusivity of its criminal and civil remedies.
It preserves the operation of state and local laws that also penalize or remedy the proscribed conduct.

In plain language, Congress is saying: “This statute adds remedies and penalties; it does not replace or crowd out others.” That is fundamentally inconsistent with reading the Act as impliedly barring § 241 prosecutions.

D. Private Rights of Action vs. Criminal Enforcement

A “private right of action” means that a private individual can sue in court to enforce a statute and seek damages or other relief. Modern Supreme Court doctrine is highly skeptical of inferring such rights unless Congress has clearly signaled them.

By contrast:

Criminal enforcement involves prosecutions by the government (not private plaintiffs).
Congress’s decision to define certain conduct as a crime and to assign particular penalties is explicit—no one is asking courts to “imply” an enforcement mechanism.

This distinction underlies the Eleventh Circuit’s refusal to import § 1983 limitations into the § 241 context.

VI. Broader Impact and Significance

A. Strengthening Federal Criminal Enforcement of Statutory Civil Rights

The principal doctrinal contribution of Oropesa is to reaffirm and clarify that:

Section 241 is available as a criminal tool for enforcing not only constitutional rights but statutory civil rights, including those created by modern statutes with their own enforcement regimes.
The mere fact that Congress has specified penalties and civil remedies within a rights-conferring statute does not, without more, insulate violations of that statute from § 241 conspiracy prosecutions.

This will likely embolden federal prosecutors, at least within the Eleventh Circuit, to:

Charge § 241 in tandem with (or instead of) substantive violations of civil-rights statutes like the FACE Act, particularly in coordinated, multi-actor schemes.
Use § 241’s higher statutory maximums to address organized campaigns of threats or violence targeting protected classes or statutorily protected activities.

B. Practical Effects for Reproductive Health and Crisis-Pregnancy Centers

An important, and politically sensitive, aspect of this case is that the victims were crisis-pregnancy centers—often pro-life facilities offering counseling and services aimed at discouraging abortion. The FACE Act is ideologically neutral: it protects access to reproductive health services and places of worship regardless of the provider’s or patient’s position on abortion.

Oropesa confirms that:

Activism or protest that crosses the line into coordinated threats and intimidation directed at CPCs can be prosecuted not only as substantive FACE Act violations but also as § 241 conspiracies to violate FACE Act rights.
Federal criminal civil-rights law operates symmetrically: it can be used to protect abortion clinics against anti-abortion violence, and CPCs against pro-abortion-rights violence or intimidation.

This may have a moderating effect on extreme tactics in abortion-related activism, signaling that organized campaigns of threats and intimidation are likely to draw serious federal criminal charges.

C. Clarifying the Limits of Fischer and Snyder

There is a broader interpretive point: Fischer and Snyder are important statutory-interpretation decisions that narrowed the scope of particular federal criminal provisions. Defense counsel will understandably seek to use them as tools to narrow other statutes.

Oropesa indicates that the Eleventh Circuit will be cautious in extending those cases:

Fischer is confined to reading catchall phrases in the context of their statutory neighbors; it does not announce a general rule against overlapping penalties in separate statutes.
Snyder does not create a broad “no sentencing disparity” principle; it dealt with identical conduct treated radically differently solely based on the office held. Where Congress has chosen to punish conspiracy more severely than the underlying offense, Snyder is inapposite.

The decision thus reins in premature attempts to use these Supreme Court opinions to attack unrelated federal criminal provisions.

D. Boundary Between Civil and Criminal Rights Enforcement Doctrines

Finally, Oropesa contributes to the still-evolving boundary between civil and criminal enforcement of federal rights:

On the civil side, cases like Sea Clammers, Rancho Palos Verdes, Talevski, and Medina reflect tightening limits on when private plaintiffs may sue under § 1983 to enforce statutory rights.
On the criminal side, Oropesa (together with Price and Johnson) reinforces the broad reach of § 241 to cover conspiracies against virtually any federal right, absent a clear and specific congressional directive to the contrary.

This asymmetry is doctrinally coherent: courts are cautious about inventing new civil remedies but more deferential to criminal enforcement mechanisms that Congress has explicitly enacted.

VII. Conclusion

United States v. Oropesa is a significant Eleventh Circuit decision clarifying the robust scope of 18 U.S.C. § 241 in the modern statutory era. The court holds that:

The FACE Act’s clinic-access rights are “rights . . . secured . . . by the laws of the United States” within § 241’s meaning.
The Act’s internal enforcement provisions, including its express saving clause, do not preclude § 241 conspiracy prosecutions based on conspiracies to violate those rights.
Recent Supreme Court rulings in Fischer and Snyder do not curtail § 241’s application in this context and do not provide good cause for untimely pretrial motions.

Judge Jordan’s concurrence adds an important interpretive layer, grounded in the text of the FACE Act’s saving clause and the Supreme Court’s longstanding decision in Johnson, underscoring that § 1983 “comprehensive enforcement scheme” doctrine is not transportable to § 241’s criminal context.

In the broader legal landscape, Oropesa stands as a clear statement that federal criminal civil-rights enforcement can be used to protect statutory rights—such as those securing access to reproductive health services—against conspiratorial threats and intimidation, even where Congress has provided separate, detailed remedies in the underlying statute. It will likely serve as a key precedent in future efforts to deploy § 241 alongside modern civil-rights statutes to address organized campaigns of rights violations.