California v. BrownAnnotate this Case
A jury found defendant Chester Brown guilty of two counts of human trafficking involving two different victims. During the trial, the jury heard evidence that defendant was essentially pimping minors, in at least one instance against their will. Proposition 35, the Californians Against Sexual Exploitation Act (the “CASE” Act), was designed in part to protect trafficked minors by treating them as victims, not criminals, and ensuring they receive services to protect them from exploitation. Defendant’s claims made on appeal concerned the application and certain aspects of this law. D. Doe (D.), the named victim in count two, was treated as his coconspirator for the purpose of introducing hearsay evidence. B. Doe (B.), the named victim in count one, was recruited by D to work for defendant. Defendant argued that because D. was immune from prosecution for trafficking under Proposition 35, she could not have been his coconspirator, and her out-of-court statements therefore constituted inadmissible hearsay. The Court of Appeal concluded D. was properly deemed an uncharged coconspirator for purposes of Evidence Code section 1223, and that Proposition 35 did not compel a ruling to the contrary. The Court rejected other arguments made on appeal and affirmed defendant’s convictions.