The following excerpt is from U.S. v. Torres, 129 F.3d 710 (2nd Cir. 1997):
The substantial effect requirement is satisfied when criminal statutes contain a jurisdictional element, which ensures through case-by-case inquiry, that the prohibited act affects interstate commerce. See id. at 561, 115 S.Ct. at 1631; United States v. Bass, 404 U.S. 336, 348-49, 92 S.Ct. 515, 522-23, 30 L.Ed.2d 488 (1971).
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