Case Explained: USA V. CANNON

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-13

Docket: 3:24-cr-00135-BAS-1

The Ninth Circuit affirmed Troy Shelvin Cannon’s conviction for sex trafficking by force, fraud, or coercion in violation of 18 U.S.C. § 1591(a). The court held that the district court did not abuse its discretion in admitting prior act evidence under Federal Rule of Evidence 404(b) and 403, noting that any potential error was harmless given the jury’s limiting instruction, the government’s failure to reference the evidence in closing arguments, and the overwhelming nature of the remaining proof. Regarding the exclusion of a hearsay statement by witness J.B., the court ruled that the district court correctly applied Rule 804(b)(3) because Cannon failed to demonstrate that he was unable to compel the declarant’s attendance or that she would have invoked her Fifth Amendment privilege against self-incrimination, characterizing such claims as mere speculation. Furthermore, the court found no error in the district court’s responses to jury questions, which accurately reflected the plain language of the statute and controlling precedent, nor did it find the evidence insufficient to support a rational trier of fact finding the essential elements of the crime beyond a reasonable doubt under the standard set forth in *Jackson v. Virginia*. Consequently, Cannon’s conviction stands and he remains subject to the sentence imposed by the district court.

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