United States v. Chappell, No. 13-1748 (8th Cir. 2015)
Annotate this CaseBloomington, Minnesota police received a complaint from a hotel manager who suspected prostitution was occurring in a room registered to Chappell. After seeing scantily clad young women staying in the room and many daily male visitors, the manager identified one of her hotel rooms in a personal advertisement on Craigslist. Detectives identified similar advertisements, on the erotic services and adult sections of Craigslist and the website Backpage. The police interviewed the hotel staff and began surveillance. They saw three young women exit Chappell’s vehicle and enter the hotel. A detective recognized two of them from photographs in the illicit advertisements. After searching the vehicle, officers seized $5,738 in cash, false identification for Chappell, the credit card used to pay for the hotel room, and a “trick note” containing the aliases of prostitutes, dollar amounts, and customer names and contact information of their customers. Chappell was convicted of sex trafficking an underage female, 18 U.S.C. 1591 based on his recruitment and prostitution of a 17-year-old student. After a remand, on a superseding indictment, he was convicted of sex trafficking two underage females; possessing and producing child pornography; and various prostitution transportation charges. The district court rejected his claim of vindictive prosecution. The Eighth Circuit affirmed.
Court Description: Criminal case - Criminal law. For the court's prior opinion remanding the case for a new trial based on an error in the jury instructions, see U.S. v. Chappell, 665 F.3d 1012 (8th Cir. 2012). On remand, the district court did not abuse its discretion by denying defendant's motion to reopen the record on the issue of probable cause for defendant's arrest; police had probable cause to arrest defendant even if the issue were reopened; claim of vindictive prosecution rejected, as the new charges added after remand concern different criminal acts against mostly difference victims.
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