United States v. Valas, No. 15-50176 (5th Cir. 2016)Annotate this Case
Defendant appealed his conviction for engaging in a commercial sex act with a minor in violation of 18 U.S.C. 1591. The court concluded that the district court properly instructed the jury on section 1591's scienter requirements; the district court did not abuse its discretion in denying defendant’s motion for a mistrial because the court found no Brady violation; the district court did not abuse its discretion in denying an alibi instruction; the district court did not abuse its discretion in denying defendant's request for a spoliation instruction; the court rejected defendant's claims regarding the admissibility of rebuttal evidence and claims regarding government statements during closing arguments; and the court concluded that there is no cumulative error. Accordingly, the court affirmed the judgment.