United States v. Geddes, No. 15-3731 (8th Cir. 2017)
Annotate this CaseDefendant was convicted of one count of aiding and abetting sex trafficking by force, fraud, or coercion; one count of aiding and abetting transportation with intent to engage in prostitution; and one count of being an armed career criminal in possession of a firearm. The court concluded that the district court did not abuse its discretion by denying severance of the firearm possession charge from the sex trafficking charges where all three counts involved a series of events that occurred between January 6 and January 14, 2014, on a trip defendant took with the victim; the facts in this case are relatively straightforward, and defendant failed to demonstrate severe prejudice; the district court did not abuse its discretion in allowing the testimony of defendant's girlfriend where the testimony about defendant's earlier use of force against her was relevant to the issue of his intent, the testimony was similar in kind and not overly remote in time to the crime charged, and the probative value outweighed any prejudice; the district court did not abuse its discretion in allowing the testimony of a special agent regarding sex trafficking; and the evidence was sufficient to sustain the convictions on Count 1 and 2. Accordingly, the court affirmed the judgment.
Court Description: Shepherd, Author, with Murphy and Gruender, Circuit Judges] Criminal case - Criminal law. The district court did not abuse its discretion by denying defendant's motion to sever a firearms count from the sex trafficking counts in the case, as the conduct took place over a short period of time on trip the defendant took with the victim and she would have been able to testify about the gun-related facts in a trial of the sex trafficking counts; in any event, there was little probability of prejudice given the relatively straightforward facts in the case; no error in permitting defendant's former girlfriend to testify about an incident in 2010 where defendant threatened her, as the jury was properly instructed on use of the testimony and the evidence's probative value outweighed any possible unfair prejudice; no error in permitting testimony from an expert in human trafficking; evidence was sufficient to support defendant's convictions on the sex trafficking counts.
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