In United States v. Walker, No. 22-10164 (July 13, 2023) (William Pryor, Luck, Hull), the Court affirmed the defendant’s sex trafficking convictions.
First, the evidence was sufficient to support a conviction of sex trafficking by coercion because a reasonable jury could have found that the defendant had a scheme, plan, or pattern intended to cause the woman to believe that failure to engage in prostitution would resulted in serious harm—namely, not having a place to stay and going hungry in a city hundreds of miles away from her home and family.
Second, and applying plain error, the government’s alleged failure to disclose its expert testimony before trial did not affect the defendant’s substantial rights because defense counsel anticipated the testimony and there was ample additional evidence of guilt apart from the expert’s testimony.
