United States v. Omar Taylor, No. 20-2756 (8th Cir. 2022)
Annotate this Case
The district court sentenced Defendant to concurrent terms of 280 months’ imprisonment on the sex trafficking offenses and a consecutive 120 months for committing a felony involving a minor while a registered sex offender, for a total imprisonment term of 400 months. Defendant raises four claims on appeal: (1) the evidence was insufficient to sustain the sex trafficking convictions; (2) the district court erred when it instructed the jury that a “happy ending massage” was a commercial sex act; (3) the district court abused its discretion when it admitted prior bad act evidence; and (4) a conviction on Count One—sex trafficking of a minor—violated the double jeopardy clause because it is a lesser included offense of Count Two—sex trafficking by force, fraud, and coercion.
The Eighth Circuit affirmed. The court held that the testimony at trial was sufficient beyond a reasonable doubt to establish the women were directed and encouraged by Defendant to digitally stimulate clients' genitalia in exchange for money—conduct that satisfies the statutory definition of a “commercial sex act.” Next, the evidence presented at trial was sufficient to prove beyond a reasonable doubt that Defendant participated in a venture by knowingly receiving money acquired from his massage business, which included assisting, supporting, and facilitating sex trafficking. Further, the testimony offered by the women working in Defendant’s massage business, if given credence by the jury, is sufficiently strong for the court to conclude that the 2005 conviction, even assuming it was improperly admitted, did not have a substantial influence on the jury’s verdict.
Court Description: [Erickson, Author, with Gruender and Stras, Circuit Judges] Criminal case - Criminal law. The evidence was sufficient to support defendant's sex trafficking convictions; the district court did not err when it instructed the jury that a "happy-ending massage" was a commercial sex act; the district court did not abuse its discretion in admitting prior bad act evidence - defendant's 2005 conviction for criminal sexual assault in the third degree, his acts with one of the sex workers, and his prior convictions for armed burglary and forgery; conviction for both sex trafficking of a minor and sex trafficking by force, fraud, and coercion with the same victim does not create Double Jeopardy violation as the two counts each require proof of an element the other does not. Judge Gruender concurring in part and dissenting in part.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.