Base de données Jurisprudence

Traite des personnes

Infractions

• Traite de personnes (adultes)
• Traite d’enfants (âgés de moins de 18 ans)

Actes commis

• Recrutement/embauche
• Transport

Moyen

• Abus d’autorité ou d’une situation de vulnérabilité

Fins d’exploitation

• Exploitation de la prostitution d’autrui ou autres formes d’exploitation sexuelle

United States v. Warren, 2014 WL 3805664 (D. Minn. Aug. 1, 2014)

Résumé des faits

Between November 2008 to March 2009, the defendant, Stevon Warren, knowingly transported an adult woman (“V1”) from Minnesota to Wisconsin, to engage in commercial sex acts.  He arranged V1’s appointments and gave her drugs in exchange for the money she earned from prostitution. 

In March 2009, the defendant transported V1 and her minor sister (“V2”) to a Minneapolis hotel to engage in commercial sex acts with someone who happened to be an undercover police officer.  The defendant was aware that V2 was a minor.  As his usual course, the defendant was expecting to get the money V1 earned.  He was also going to take a portion of V2’s earnings, but, before he could do so, he was arrested nearby the hotel.

The authorities learned of the defendant’s activities through advertisements that he posted on Craigslist.org.
On March 15, 2011 in a superseding indictment, the defendant was charged with one count of sex trafficking of a minor and one count of transporting an adult for prostitution in violation of the Mann Act.  A jury found him guilty on both charges on August 18, 2011.

Commentaire / Faits marquants

Both of the victims, V1 and V2, were witnesses at the defendant’s trial. 

Date de la peine:
2012-01-13
Auteur:
Human Trafficking Database of the University of Michigan Law School

Mots-clefs

Actes:
Recrutement
Transport
Moyens:
Abus d’autorité ou d’une situation de vulnérabilité
Fins d’exploitation:
Exploitation de la prostitution d’autrui ou d’autres formes d’exploitation sexuelle,
Formes de la Traite:
National
Secteur dans lequel l'exploitation a lieu:
Exploitation sexuelle commerciale

Questions transversales

Responsabilité

Responsabilité pour

• Infraction consommée

Responsabilité fondée sur

• Intention criminelle

Responsabilité impliquant

• Auteur principal (d’une infraction)

enquête

Organismes concernés

• Minneapolis Police Department
• Federal Bureau of Investigation (“FBI”)

Techniques spéciales d'enquête

• Opération(s) d’infiltration/identités d’emprunt/infiltration

Informations sur la procédure

Système juridique:
Droit commun
Décision judiciaire la plus récente:
Juridiction d’appel
Type d'Action Juridique:
Criminel / pénal

1st Instance: 

Court: United States District Court for the District of Minnesota

Date of decision: 18 August 2011 (jury verdict); 13 January 2012 (sentencing date)

Reference: Docket Number: 10-CR-0276

2nd Instance:

Court: United States Circuit Court for the Eighth Circuit

Date of decision: 2 November 2012

Reference: United States v. Warren, 491 Fed. Appx. 775 (8th Cir. 2012); 2012 U.S. App. LEXIS 22564 (8th Cir. Nov. 2, 2012)

3rd instance:

Court: United States District Court for the District of Minnesota

Date of decision: 1 August 2014

Reference: United States v. Warren, 2014 WL 3805664 (D. Minn. Aug. 1, 2014)

Other clarifying information:

The third instance was a request for post-conviction relief at the District Court level.  It was filed by the defendant pro-se.

 
 

Victime / Demandeurs de la première instance

Victime:
V1
Sexe:
Femme
Nationalité:
Américain
Victime:
V2
Sexe:
Enfant
Nationalité:
Américain
Ancienneté:
15
The victim is a minor female.

Défendeurs / Répondants de la première instance

Nombre d'autres accusés:
1
Prévenu:
Stevon Warren
Sexe:
Homme
Nationalité:
Américain
Ancienneté:
52
The defendant was 52 years of age at the time he was sentenced.
Raisonnement juridique:

The jury rendered a guilty verdict. 

V1 testified at trial that she lived in Minnesota and was a prostitute who purchased drugs from the defendant.  She testified that when she told him that she was a prostitute in 2004 or 2005, the defendant suggested that he would want to split her earnings.  In May of 2008, she moved to a house that her mother was renting from the defendant.  The defendant knew about V1’s appointments and how much she earned from them because he was present when the witness would make her appointments, he would drive her to them and then would ask how much she earned.

V1 also testified that the defendant had paid for her to post online ads and booked hotel rooms before he began demanding all of her proceeds from prostitution in exchange for drugs.  When V1 refused to turn over her earnings, the defendant would beat her and withhold drugs from her.

She further testified that in November 2008, she asked the defendant to drive her from Minnesota to Wisconsin for a “date” and the defendant drove her.

On another occasion, in March 2009, V1 asked the defendant to driver to a “date” at a Minneapolis hotel, which he did.  When he returned to the hotel, the defendant told V1 that they had to pick up the her 15-year-old sister (“V2”) and go to a hotel later because a “guy wanted a younger girl.”

V2 was also a witness at trial.  She testified that her older sister agreed that the younger sister would give the client a massage and the older sister would “do everything else.”   

The client was an undercover police officer who took both V1 and V2 into custody and arrested the defendant at a nearby gas station that same day.

Accusations / Demandes d’indemnité / Décisions

Prévenu:
Stevon Warren
Législation/Code:
18 U.S.C. § 1592
Détails de charges:
Sex Trafficking of a Minor
Verdict:
Guilty
Législation/Code:
18 U.S.C. § 2421
Détails de charges:
Interstate Transportation of an Adult for Prostitution (Mann Act)
Verdict:
Guilty
Peine de prison:
11 ans
Indemnisation des victimes:
Non 
Amende / Paiement à l’État:
Non 
Décision rendue en appel:
Upheld

2nd instance:

The defendant appealed to the 8th Circuit arguing that the evidence did not support either of his convictions.  For his first conviction, the defendant argued that, under the Mann Act, the government did not bring enough evidence to meet their burden of proof showing that the defendant transported the individual with the intent that the individual engage in prostitution.  For his second conviction for sex trafficking of a minor, the defendant argued that the government did not bring enough evidence to meet their burden of proof showing that he transported the minor knowing that she would be forced to engage in a commercial sex act.    

This Court concluded that the testimonies of both victims (as illustrated above) was sufficient evidence for a conviction on both counts and that the defendant’s argument had no merit. Thus, this Court affirms the trial court’s ruling. 

3rd instance:

The defendant filed this appeal pro se requesting this Court (District Court) to vacate, set aside or correct his sentence.  “[The defendant] [] alleges that his sentence should be vacated for the following four reasons: (1) the government did not prove—indeed, expressly denied during its opening argument—that [the defendant] [] transported anyone across a state line, an element of the crime charged in Count One; (2) [One victim] [] committed perjury while testifying before the grand jury that indicted [the defendant] []; (3) “inflammatory” portions of an audio recording of an interview of [that victim] [] were introduced at trial without introduction of a portion of that interview in which [the victim] [] stated that she “held extreme dislike and contempt” for [the defendant] [], ECF No. 190 at 6, 12; and (4) [the defendant’s] [] attorneys failed to provide effective assistance.”

As to the defendant’s first argument, this is untrue.  The government stressed that it had to, and did, prove that the defendant and V1 crossed state lines.  However, the government did not have to prove a crossing of state lines to convict the defendant for sex trafficking a minor under 18 U.S.C. § 1592.   

As to the defendant’s second argument, even if there was an error in the jury verdict, such error was “harmless beyond a reasonable doubt.”

As to the defendant’s third argument, this claim fails because the requirement is that the government disclose exculpatory evidence to the defendant; it does not have to introduce it at trial. Irrespective of that rule, the government did not introduce any portion of the interview of V2 at trial; thus, it did not introduce any inflammatory portions of evidence.

As to the defendant’s fourth argument, in order to have a successful claim for ineffective assistance of counsel, the defendant must prove that the attorney’s performance fell below an objective standard of reasonableness and that, but for the attorney’s errors, the result of the defendant’s proceeding would have been different.  This is a heavy burden and the defendant did not provide evidence to satisfy that burden.  Consequently, this Court rejects this argument.     

Therefore, as explained in the aforementioned reasons, this Court denies the defendant’s motion. 

Tribunal

United States District Court for the District of Minnesota

Sources / citations

Woodbury Man Sentenced For Sex Trafficking A Minor And Interstate Prostitution, USDOJ, Jan. 13, 2012, http://www.justice.gov/usao/mn/warrensentenced.html

Michigan database: http://www.law.umich.edu/CLINICAL/HUTRAFFICCASES/Pages/CaseDisp.aspx?caseID=713