Summary
Defendant appealed the denial of pretrial release after being charged with sex trafficking of a minor and related offenses. The D.C. Circuit affirmed, holding that the statutory presumption of detention under 18 U.S.C. § 3142(e)(3) applied because probable cause was established, and the defendant failed to offer credible evidence to rebut it. The court also rejected the due process challenge to the length and conditions of pretrial detention.
Topics
Practice areas
Questions Presented
- Whether the district court erred in denying appellant's motion for pretrial release because she failed to rebut the statutory presumption under 18 U.S.C. § 3142(e)(3).
- Whether the length and conditions of appellant's pretrial detention violate due process.
Holdings
- The district court did not err because appellant failed to offer some credible evidence contrary to the statutory presumption.
- The length and conditions of appellant's pretrial detention do not violate due process.
Key quotations
“appellant failed 'to offer some credible evidence contrary to the statutory presumption.'”
“appellant has not demonstrated that the length or conditions of her pretrial detention violate due process.”
Factual background
Appellant was charged with sex trafficking of a minor and transportation of a minor in violation of 18 U.S.C. §§ 1591 and 2423. A magistrate judge found probable cause, triggering a rebuttable presumption that no condition or combination of conditions would reasonably assure appearance and community safety. Appellant moved for pretrial release, which the district court denied.
Procedural history
Appellant was charged with sex trafficking of a minor and transportation of a minor. A magistrate judge found probable cause and ordered detention. Appellant moved for pretrial release; the district court denied the motion. Appellant appealed.