Ford v. State

Jerome Ford was convicted of pandering of prostitution pursuant to Nev. Rev. Stat. 201.300(1)(a), which criminalizes the act of soliciting another person with the specific intent that, in response to the solicitation, she become a prostitute or continue to engage in prostitution. Ford appealed, contending that the statute was unconstitutionally overbroad and vague. The Supreme Court reversed, holding (1) the statute does not criminalize such a substantial amount of protected expressive activity as to be unconstitutionally overbroad, and statute is not impermissibly vague; (2) the statute applies even when the target is an undercover police officer who disavows having been or intending to become a prostitute; but (3) the jury instructions in this case did not adequately describe the specific intent required for pandering, and the error affected Ford's substantial rights. Remanded for a new trial.