United States v. Roy, No. 14-1054 (8th Cir. 2015)
Annotate this CaseAfter arresting prostitutes, officers noticed markings on one woman (victim). She identified Roy as her pimp and boyfriend. Roy had posted ads for the victim on Backpage.com. She was required to give Roy the money she earned. Roy hit and threatened her. The victim received disability benefits because she had difficulty reading, writing, and understanding complex concepts. In his trial for violation of 18 U.S.C. 1591(a)(1), Roy sought to introduce a videotape of the victim performing oral sex on him, claiming that it showed that the victim was not forced into engaging in prostitution. The district court allowed Roy to cross-examine the victim about the video, but ruled that showing it was too prejudicial. The court did not allow testimony that the victim had engaged in prostitution before meeting Roy. The government provided disclosure about prosecution witnesses, but did not know that, years earlier, the victim made a statement in an Arkansas murder investigation, identifying the shooter. She later testified that she did not see the shooter and had told the police what her friend said to say. Roy moved for a new trial, claiming that the court erred in excluding the video and the victim’s sexual history, and asserting a Brady violation for failure to disclose the prior false statement. The Eighth Circuit affirmed denial of the motion.
Court Description: Criminal case - Criminal law. In this prosecution for sex trafficking, the district court did not abuse its discretion by refusing to permit defendant to show a video of the victim performing a sex act on him; the district court did not err under Fed. R. Evid. 412(a) in refusing to permit defendant to introduce evidence of he victim's past sexual behavior; nor did exclusion of the evidence violate defendant's Sixth Amendment rights; in any event, defendant's failure to file a timely notice under Rule 412(c)(1)(B) was sufficient grounds to deny the request; claim of Brady violation rejected as defendant had access to the relevant information, which was in a published Arkansas Supreme Court decision, and the government was unaware of the fact that the victim had made a false statement to state police in an unrelated case.
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