Conviction and life sentence for sex trafficking a minor and adults upheld as reasonable in light of the evidence

Williams appeals his conviction and sentence by a federal judge for the federal offense of sex trafficking involving a minor, and two adults.  The evidence presented at his trial showed Williams used physical abuse and emotional manipulation to force vulnerable young women to work for him as prostitutes.  The evidence was graphic because the women who worked for Williams described Williams’ violent behavior and punishments.  He was sentenced to five terms of life imprisonment and ordered to pay restitution to his victims.  In his appeal he raised three issues.

First, he argued that the district court improperly admitted nude images and videos of the girls. The appellate court found the images, which Williams kept, were relevant because they were intended to prove coercion by showing how Williams dominated and degraded his victims by forcing them to engage in sexual conduct and keeping evidence of that behavior to use however he pleased.  The court also found that the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice because the explicit evidence needed to be introduced in view of the nature of the charges.  Potential jurors had been cautioned they would hear and see evidence of a sexually explicit nature and they confirmed that this would not impact their ability to be fair and impartial.

Second, he argued there was not enough evidence to show that he knowingly trafficked one of the girls as a minor and as an adult.  Though that victim never testified, the government presented plenty of evidence strongly suggesting that Williams knew the girl was under 18.  There was also plenty of evidence showing that while she was an adult, Williams used force, threats of force, and coercion to cause the victim to engage in prostitution.

Third, he argued that the district court should have given an instruction to the jury that a victim’s consent to perform a sex act is a defense to sex trafficking.  He argued this instruction was relevant because an adult can legally consent to commercial sex.  The appellate court rejected his argument because the Eleventh Circuit has never recognized consent as a valid defense to sex trafficking and Williams could not cite any circuit that approved.  Nevertheless, the jury instruction explained that Williams was guilty only if he knew that the means of force, threats of force, fraud, coercion, or any combination would be used to cause the person to engage in commercial sex.  The jury did not need a separate instruction to explain that if the victim willingly chose to engage in commercial sex, force or coercion did not cause her to do it.

Williams also challenged the restitution awarded to the victims, but the appellate court found the restitution was correctly calculated and lawfully imposed.

Willams also appealed the reasonableness of his federal sentence arguing that it was substantively unreasonable.  Under the prevailing law for reviewing a sentence for reasonableness, the appellate court applies the abuse of discretion standard and will only vacate a sentence if the appeals court is left with the definite and firm conviction that the district court committed a clear error of judgment in weighing the U.S.C.  §3553(a) factors by arriving at a sentence that lies outside  the range of reasonable sentences dictated by the facts of the case. In view of the years of brutal torturing, beating and threatening his victims into submission, the court found no abuse of discretion and upheld the sentence.