 In 1996 the Federal Prohibition of Female Genital Mutilation Act made it illegal to perform FGM on minors for non-medical reasons, and in 2013 the Transport for Female Genital Mutilation Act prohibited transporting a minor out of the country for the purpose of FGM.The first FGM conviction in the US was in 2006, when Khalid Adem, who had emigrated from Ethiopia, was sentenced to ten years for aggravated battery and cruelty to children after severing his two-year-old daughter's clitoris with a pair of scissors.A federal judge ruled in 2018 that the 1996 Act was unconstitutional, arguing that FGM is a "local criminal activity" that should be regulated by states, not by Congress; he made his ruling during a case against members of the Dawoodi Bohra community in Michigan accused of carrying out FGM.