United States v. Williams, No. 18-1002 (7th Cir. 2018)
Annotate this CaseWilliams was accused of offenses relating to a wide‐ranging sex‐trafficking scheme. He lured women in desperate circumstances into prostitution by convincing them that he would take care of them and maintained control through brutal physical abuse. Before trial, the government filed a notice of its intent to call FBI Agent Mentzel as an expert witness, adequately describing Mentzel’s credentials but listing only broad topics without explanation of what she would say about each. Williams argued that the disclosure was inadequate under Federal Rule of Criminal Procedure 16(a)(1)(G); that Mentzel’s testimony was unnecessary— jury instructions would define the crime of human trafficking; and that her testimony would be impermissible character evidence. The court overruled these objections. Mentzel testified about how human traffickers operate but did not testify about Williams or his actions. Three of Williams’ victims testified. There were pictures of injuries that Williams had inflicted on his victims and online prostitution ads for each testifying victim, all linked to Williams’ email addresses. There were text messages and Facebook messages in which Williams admitted to being a pimp and referred to the victims who later testified. The Seventh Circuit affirmed his conviction. While the government did not violate the rules prohibiting the use of character evidence, it probably did violate the expert disclosure requirement but any error was harmless. The evidence of guilt was so overwhelming that the jury would have convicted Williams even if Mentzel had not testified.
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