United States v. Collier, No. 18-1025 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction of five counts of sex trafficking and attempted sex trafficking, and one count of conspiracy to commit an offense against the United States, specifically facilitating the promotion and management of a business enterprise involving prostitution.
The court held that the search of defendant's cell phone did not violate the Fourth Amendment because, under the totality of the circumstances, he did not have a reasonable expectation of privacy in it. In this case, defendant was on restrictive supervised release and suspected of engaging in illicit activities, and he was on notice due to the conditions of his supervised release. The court also held that the district court did not abuse its discretion in instructing the jury; defendant's waiver to his Sixth Amendment right to counsel was not involuntary; and defendant's remaining claims of trial error failed
Court Description: Grasz, Author, with Benton and Wollman, Circuit Judges] Criminal case - Criminal law. Search of defendant's cell phone was reasonable under the circumstances, where he was on restrictive supervised release, had notice his phone could be searched, and was suspected of engaging in illicit activities; challenge to jury instruction on federal sex trafficking offenses rejected as this circuit joins other circuits in concluding that the word "knowingly" in 18 U.S.C. Sec. 1591(a)(1) does not apply to the interstate commerce element of the offense; no error in refusing to give a willful blindness instruction; no abuse of discretion in denying motion for continuance of trial; defendant's waiver of Sixth Amendment right to counsel was not involuntary; the district court did not err in finding there was no violation of its sequestration order; no error in excluding evidence that one of the victims was previously involved in prostitution; no error in seizing defendant's computer after it was discovered he was recording witness testimony; claim of judicial bias rejected; challenge to the sufficiency of the evidence with respect to two of the counts of sex trafficking rejected.
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