State of Minnesota v. Prince Antonio Dequante Jones, A15-1519

In June 2014 a 13-year-old (M.A.) engaged in prostitution after moving in with E.H.; appellant Prince Jones drove M.A. and E.H. to Moorhead, placed an ad for M.A. online using a prepaid card, and was present in a car outside the motel room where detectives later contacted M.A.
Detectives arranged a sting, found M.A. in a motel room after she gave false identifying information, tracked E.H.’s phone by GPS to a hotel, located Jones and E.H., seized two phones (one prepaid) from Jones, and arrested both.
Jones was charged with first-degree sex trafficking (promoting prostitution of a minor) and third-degree criminal sexual conduct; convicted of the trafficking charge and acquitted of CSC.
The state sought to admit two expert witnesses: Ann Quinn (investigative/BCI special agent) to explain trafficking practices, online ads, prepaid phones, and investigative techniques; Joy Friedman (victim-services trainer) to explain common victim behaviors and counterintuitive responses to trauma.
The district court conditionally admitted both experts, limiting testimony to matters tied to evidence the state introduced or would introduce; Jones objected at the pretrial hearing but did not lodge trial objections to much of the contested testimony.
On appeal Jones argued (1) the expert testimony was irrelevant and amounted to impermissible profile evidence, and (2) the prosecutor committed misconduct by eliciting testimony exceeding the court’s pretrial limits. The court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of expert testimony on trafficking practices and victim behaviors	Experts were relevant to explain actions that bore on intent to aid prostitution and to explain victim behavior; testimony assists jury	Jones: testimony unrelated to his case, amounted to profiling/character evidence and was prejudicial	Court: testimony linked to element of promoting prostitution and to credibility of victim; not improper profile evidence; admissible under trial court limits
Prosecutorial misconduct for eliciting testimony beyond pretrial limitations	State: any challenged testimony was foundational to qualify experts and explain background; no misconduct	Jones: prosecutor elicited general industry terms and topics beyond court’s limitations (e.g., slang, task forces, interview protocols, victim risk factors)	Court: either testimony was within permissible foundational scope or, if beyond limits, any error was not plainly prejudicial and did not affect substantial rights; no reversible misconduct

DeShay v. State, 669 N.W.2d 878 (Minn. 2003) (expert testimony must help jury understand evidence and address matters beyond common knowledge)
Lopez-Rios v. State, 669 N.W.2d 603 (Minn. 2003) (limits on expert testimony that is duplicative, extraneous, or prejudicial)
McDaniel v. State, 777 N.W.2d 739 (Minn. 2010) (expert testimony permitted when tied to elements and assists jury in determining whether state met its burden)
Williams v. State, 525 N.W.2d 538 (Minn. 1994) (discussing inadmissibility of "profile" evidence and limits on inferring guilt from generalized conduct)
Barajas v. State, 817 N.W.2d 204 (Minn. App. 2012) (expert testimony explaining significance of evidence is not necessarily impermissible profile evidence)
Ramey v. State, 721 N.W.2d 294 (Minn. 2006) (modified plain-error standard for unobjected-to prosecutorial misconduct)