USA v. Khalil Jackson, No. 21-2811 (7th Cir. 2023)
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Defendant was arrested on several counts of sex trafficking a minor, child pornography and cyberstalking. A jury convicted Defendant on all counts, and he was sentenced to forty years in prison.
Defendant appealed on two issues. First, the district court erred in admitting his confession to detectives. However, each of the challenged statements were made after Defendant was Mirandized. While Defendant indicated prior to this point that he would "rather have a lawyer," even if that statement invoked his right to counsel, subsequent re-initiation of the conversation by Defendant waived his right to counsel.
Second, Defendant claimed the district court erred in refusing to provide a limiting instruction related to three threatening voicemails Defendant left for members of the victim's family. These statements were "other acts" admissible under Fed. R. Evid. 404(b)(1).
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