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Criminal Resource Manual

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Criminal Resource Manual
CRM 1500-1999

1838. Harboring -- 18 USC 1072 -- Second Element -- Concealing

"Harbor" and "conceal" have the same meaning as in 18 U.S.C. § 1071. See also this Manual at 1831. In United States v. Kutas, 542 F.2d 527, 528 (9th Cir. 1976), cert. denied, 429 U.S. 1073 (1977), the court upheld a Section 1072 conviction in which the words "harbor" and "conceal" were defined to "refer to any physical act of providing assistance, including food, shelter, and other assistance to aid the prisoner in avoiding detection and apprehension."