Background
Defendant Troy Shelvin Cannon appealed his conviction for sex trafficking by force, fraud, or coercion in violation of Section one five nine one A of Title eighteen of the United States Code. The appeal challenged the district court’s evidentiary rulings and the sufficiency of the government’s case.
The court’s reasoning
The panel concluded that the district court did not abuse its discretion in admitting prior act evidence or excluding hearsay. The court noted that any error in admitting the evidence was harmless given the limiting instructions and the abundance of other evidence. Regarding the hearsay statement, the court found the defendant did not show he was unable to compel the witness’s attendance. The court also held that the district court’s response to jury questions was accurate and that the government offered sufficient evidence for a rational trier of fact to find the essential elements of the crime.
What it means going forward
The affirmation reinforces the Ninth Circuit’s standard for reviewing evidentiary rulings in sex trafficking cases and clarifies the burden on defendants to prove witness unavailability for hearsay exceptions.