United States v. Pawinee Unpradit, No. 21-1341 (8th Cir. 2022)
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Five defendants were found guilty of conspiracy to commit sex trafficking, conspiracy to transport persons to engage in prostitution, conspiracy to engage in money laundering, and conspiracy to use a communication facility to promote prostitution. The jury also found one of the five, guilty of a substantive count of sex trafficking. Defendants appealed various aspects of their convictions and sentences.
The Eighth Circuit affirmed the district court’s judgment finding that there was no reversible error. Defendants 1 and 2 argued that their convictions must be reversed because there was a variance between the conspiracy charged in the indictment and the conspiracy proved at trial. The court held that there was sufficient evidence for a reasonable jury to find that they joined a single ongoing conspiracy to commit sex trafficking.
Defendant 3 challenged the sufficiency of the evidence to support her conviction for conspiracy to commit sex trafficking. The court held that based on the evidence a reasonable jury could conclude that Defendant 3 knowingly agreed to engage in sex trafficking and did so with the knowledge that women working in her houses were subject to coercive debt.
Defendant 4 challenged the sufficiency of the evidence to support his conviction on a substantive count of sex trafficking. The court reasoned that the offense of benefiting from participation in a venture to “maintain” a victim of sex trafficking is a continuing offense that may occur in more than one district. The court found no clear error in the district court’s orders of restitution and forfeiture to Defendant 5.
Court Description: [Colloton, Author, with Shepherd and Kelly, Circuit Judges] Criminal case - Criminal law and sentencing. Defendants participated in a large sex-trafficking conspiracy which brought women from Thailand to engage in commercial sex activities in the U.S. There was no variance between the conspiracy charged in the indictment and the conspiracy proved at trial, and there was sufficient evidence for a reasonable jury to find that defendants Unpradit and Thinram joined a single ongoing conspiracy to commit sex trafficking; challenges to jury instructions, including an instruction on the elements of conspiracy and an instruction on willful blindness, rejected; evidence was sufficient to support defendant Ruttanamongkongul's conviction for conspiracy to commit sex trafficking; evidence was sufficient to support defendant Morris's conviction for a substantive count of sex trafficking; assuming for the sake of analysis that Morris properly preserved his venue challenge,venue on the substantive count of sex trafficking was proper in the District of Minnesota; challenges to base offense level calculations for conspiracy to commit sex trafficking under 18 U.S.C. Sec. 1594 rejected as this court has previously held that level 34, which was used here, is the proper base offense level - see U.S. v. Carter, 960 F.3d 1007 (8th Cir. 2020); restitution and forfeiture findings affirmed; Brady challenge rejected; claims of prosecutorial misconduct rejected; claim of ineffective assistance of counsel rejected; defendant Wanless was not entitled to an evidentiary hearing on the forfeiture issues.
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