United States v. Roach, No. 17-2085 (10th Cir. 2018)Annotate this Case
A jury convicted Shane Roach of coercing D.G. into prostitution. Roach recruited D.G. and, with help from Angela Santillanes, prostituted D.G. to clients. D.G. became scared and reached out for help, leading to Roach’s and Santillanes’s arrests. The Government charged Roach and Santillanes, but after Santillanes agreed to testify against Roach, it dropped her charge. At trial, Roach attempted to cross-examine Santillanes about three topics. The Government successfully objected. On appeal, Roach argued the district court’s rulings preventing cross-examination violated: (1) the Confrontation Clause; and (2) the Federal Rules of Evidence, and because these errors were not harmless, the Tenth Circuit had to vacate his conviction and remand for a new trial. After review, the Tenth Circuit concluded: (1) Roach waived his Confrontation Clause arguments; and (2) any error in limiting his cross-examination under the evidence rules was harmless. Accordingly, the Court affirmed his conviction.