United States v. Palms, No. 20-5072 (10th Cir. 2021)
Annotate this CaseAppellant Ramar Palms was convicted by jury in the Northern District of Oklahoma on three crimes related to sex trafficking. On appeal, Palms sought to reverse his convictions and remand for a new trial because: (1) the district court should have suppressed the evidence obtained from his cell phone because the warrant and the search of his cell phone violated the Fourth Amendment; and (2) the district court abused its discretion when it excluded sexual behavior evidence under Federal Rule of Evidence 412 because the exclusion violated the Fifth and Sixth Amendments. The Tenth Circuit held that the warrant to search Palms’s cell phone was sufficiently particular and the search was reasonable. Further, the Court held the district court did not abuse its discretion in excluding sexual behavior evidence under Rule 412. Therefore, Palms’s convictions were affirmed.
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