United States v. Parks, No. 17-1914 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's conviction of one count of transportation of a minor to engage in prostitution; two counts of attempted transportation of a minor to engage in prostitution; and six counts of transportation of an individual with intent to engage in prostitution. The court held that the search of defendant's van was warranted under the community-caretaker exception where police officers knew that a minor was missing; the officer developed probable cause to search the van under the automobile warrant exception when he opened the door and discovered marijuana and an apparently comatose young woman; and thus the district court properly denied defendant's motion to suppress evidence. The court also held that the district court did not err in admitting evidence that defendant had asked two of the women to have sex with him and provided drugs to them. Finally, the evidence was sufficient to enable a reasonable jury to find that defendant transported all six women in interstate commerce with the intent to have them engage in prostitution.