Summary
This Eighth Circuit Court of Appeals opinion affirms the conviction of Deonte Womack for two counts of sex trafficking by force, fraud, or coercion. The court reviews four appellate challenges: the admission of uncharged victim testimony under Federal Rule of Evidence 404(b), the denial of a proposed lesser-included offense jury instruction, the sufficiency of the evidence supporting the convictions, and the district court's calculation of the base offense level under the Sentencing Guidelines. Finding no abuse of discretion or legal error, the appellate court upholds the district court's judgment and 235-month sentence.
Topics
Practice areas
Questions Presented
- Whether the district court erred in admitting C.C.'s testimony under Federal Rule of Evidence 404(b).
- Whether the district court erred in denying Womack's proposed lesser‑included offense jury instruction.
- Whether the evidence was sufficient to support the convictions on the two remaining sex‑trafficking counts.
- Whether the district court correctly calculated the base offense level under the United States Sentencing Guidelines.
Holdings
- The district court did not abuse its discretion; the testimony was admissible because it was relevant to intent, similar in kind, supported by sufficient evidence, and the limiting instruction mitigated prejudice.
- The district court correctly denied the instruction because the elements of 18 U.S.C. § 2421(a) are not identical to those of § 1591(a); the mens‑rea requirements differ.
- The district court did not err; the evidence was sufficient for a reasonable jury to find beyond a reasonable doubt that Womack used force, threats of force, or coercion.
- The district court correctly applied a base offense level of 34 under U.S.S.G. § 2G1.1(a); the statutory language refers to § 1591(a) offenses punishable under § 1591(b)(1).
Key quotations
“We review the district court’s evidentiary rulings for an abuse of discretion, giving great deference to the district court’s balancing of the probative value and prejudicial impact of the evidence.” (1061)
“Rule 404(b) permits the admission of evidence of a criminal defendant’s ‘crime, wrong, or act’ to prove the defendant’s ‘motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.’” (753)
Factual background
In July 2019 LRPD conducted a sting operation that led to the arrest of a prostitute, A.B., who later identified Deonte Womack as her manager. FBI investigations uncovered a prostitution ring of at least twelve women, including A.B., J.G., T.S., and C.C., who testified that Womack used force, threats, and coercion to control them. Womack was indicted on four counts—three sex‑trafficking counts and one witness‑intimidation count—and was convicted on two sex‑trafficking counts after trial.
Procedural history
The district court convicted Womack of two counts of sex trafficking by force, fraud, or coercion and sentenced him to 235 months. Womack appealed the admission of certain testimony, the denial of a lesser‑included offense instruction, the denial of a judgment of acquittal on two counts, and the sentencing guideline base offense level.