U.S. v Williams

In prosecution on sex trafficking charges, govt. failed to comply with expert witness disclosure requirements set forth in Fed. Rule Crim. Pro. 16(a)(1)(G), which requires that disclosure contain written summary of any expert witness testimony that govt. intends to use in its case in chief. Instant summary was improper because it merely listed series of topics without any explanation of what expert intended to say on said topics, and Ct. rejected govt. contention that said description was adequate since expert was providing only “background, educational testimony” about sex-trafficking. However, any error was harmless, where evidence of defendant’s guilt was overwhelming based on testimony from actual victims of defendant’s prostitution operation who provided details as to their recruitment and retention in defendant’s prostitution operation. Ct. also rejected defendant’s claim that expert’s testimony constituted impermissible evidence of “group character trait,” since expert did not delve into propensity of people with certain dispositions to commit sex-trafficking crimes, but rather compared typical modus operandi of sex-traffickers with defendant’s use of similar techniques.