U.S. v. Vines

In prosecution on series of sex-trafficking charges, Dist. Ct. did not err in admitting testimony of expert witness regarding behavior of victims of sex trafficking. Expert never met instant victim, and expert’s testimony was limited to discussion of behavior of sex trafficking victims in general and why said victims may not be able to be completely forthcoming when questioned by law enforcement and medical personnel. Also, expert’s testimony would benefit jury’s understanding of behavior of victims of sex trafficking, and defendant otherwise failed to show that expert’s testimony exceeded scope of permissible testimony under Rule 702, or that expert’s testimony improperly bolstered victim’s testimony. Also, Dist. Ct. did not err in denying defendant’s motion to suppress seizure of his cell phone under circumstances, where: (1) police visited his girlfriend’s home and asked her if she would provide defendant’s phone; and (2) girlfriend gave phone to police, who subsequently obtained and received warrant to search phone. Girlfriend was able to consent to seizure of phone, where she had phone for over one month, and defendant did not otherwise restrict her control over phone. Too, Dist. Ct. did not err in denying defendant’s motion to suppress results of search of his Facebook and iCloud accounts, even though defendant asserted that victim made inconsistent statements in warrant application. Dist. Ct. could properly deny defendant’s request for Franks hearing, where other evidence in warrant application corroborated victim’s statements and established probable cause to search defendant’s Facebook and iCloud accounts.