United States v. Amador Cortes-Meza
685 F. App'x 731
| 11th Cir. | 2017Background
- In 2008 a federal grand jury charged Amador Cortes‑Meza and five co‑defendants in a human‑trafficking/prostitution ring; Cortes‑Meza proceeded to trial while co‑defendants pled guilty.
- Nine women testified over a ten‑day trial that defendants lured them from Mexico to Atlanta and forced them to work as prostitutes through violence, threats (including threats to family), and tight control; some victims were minors.
- Specific victims (RHP and LMJ) described repeated beatings, sexual assaults, threats, and other coercive measures; physical injuries were corroborated by physicians and ICE agents.
- Jury convicted Cortes‑Meza on all 19 counts against him, including sex trafficking of minors, sex trafficking by force/fraud/coercion, transporting a minor for prostitution, harboring/importing aliens for prostitution, and conspiracy.
- District court varied downward from a Guidelines life sentence and imposed concurrent 480‑month terms; Cortes‑Meza appealed arguing error in diary admission, denial of a new‑trial motion based on newly discovered evidence, and substantive unreasonableness of sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of victims’ diaries | Government: diaries admissible to show victims’ state of mind and corroborate coercive environment; many entries non‑hearsay or fall under state‑of‑mind exception | Cortes‑Meza: diary entries were hearsay and prejudicial; their admission violated evidentiary rules and affected verdict | Court affirmed: admission not an abuse of discretion; even if error, it was harmless given overwhelming corroborating evidence |
| Motion for new trial based on newly discovered witness | Government: proffered witness inconsistent and limited; testimony would not likely produce different result | Cortes‑Meza: new deposition showed victims voluntarily prostituted and later fabricated coercion to obtain immigration papers, warranting a new trial | Court affirmed denial: witness testimony undermined by inconsistencies and contradicted by trial evidence; did not meet Rule 33 standard to likely produce acquittal |
| Substantive reasonableness of 480‑month sentence | Government: within district court’s broad discretion; court considered §3553(a) factors and validly varied downward from life term | Cortes‑Meza: sentence unreasonable and disparate compared to co‑defendants; 480 months is a de facto life sentence | Court affirmed: disparity justified by greater number/severity of convictions, leadership role, violence, and refusal to accept responsibility; 480 months not substantively unreasonable nor equivalent to life for constitutional/appeal purposes |
Key Cases Cited
- United States v. Frazier, 387 F.3d 1244 (11th Cir. 2004) (abuse‑of‑discretion review of evidentiary rulings)
- Yellow Pages Photos, Inc. v. Ziplocal, LP, 795 F.3d 1255 (11th Cir. 2015) (harmless‑error prejudicial‑effect standard)
- United States v. Hersh, 297 F.3d 1233 (11th Cir. 2002) (harmless error analysis)
- United States v. Phaknikone, 605 F.3d 1099 (11th Cir. 2010) (harmless error precedent)
- United States v. Harriston, 329 F.3d 779 (11th Cir. 2003) (harmless error precedent)
- United States v. Campa, 459 F.3d 1121 (11th Cir. 2006) (Rule 33 new‑trial motions are disfavored)
- United States v. Jernigan, 341 F.3d 1273 (11th Cir. 2003) (factors for newly discovered evidence relief)
- United States v. Scrushy, 721 F.3d 1288 (11th Cir. 2013) (new‑evidence must probably produce acquittal)
- United States v. Cavallo, 790 F.3d 1202 (11th Cir. 2015) (deferential review of sentence reasonableness)
- United States v. Hunt, 526 F.3d 739 (11th Cir. 2008) (expectation of Guidelines‑range reasonableness)
- United States v. Docampo, 573 F.3d 1091 (11th Cir. 2009) (range of reasonable sentences)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (distinction between life sentences and term‑of‑years regarding denial of hope)