United States v. Parks, No. 17-1914 (8th Cir. 2018)
Annotate this CaseThe 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.
Court Description: Wollman, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Criminal case - Criminal law. Where police were aware that a young girl, supposedly in defendant's custody, was missing, the search of defendant's van was warranted under the community-caretaker exception; the officer developed probable cause to search the van under the automobile warrant exception when he opened the van door, smelled and saw marijuana and discovered a comatose young woman; in this prosecution for transportation of minors to engage in prostitution, 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; the testimony was properly admitted as res gestae evidence which provided context to the prostitution crimes with which defendant was charged; the probative value of the evidence outweighed the danger of prejudice because the evidence showed defendant's intent to solicit, entice and maintain the women so that they would engage in commercial sex acts; the evidence was sufficient to support defendant's convictions for bringing women from Ohio to Missouri for the purpose of prostitution.
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