United States v. Anthony Willoughby, 742 F.3d 229

Jury found Willoughby prostituted a 16-year-old runaway (SW) in violation of 18 U.S.C. §1591; district court sentenced him to 360 months.
SW lived with Willoughby for a time, subjected to daily sexual acts, coercion, and control; Willoughby directed calls to johns and kept records.
Items linking Willoughby to the crime were seized during a search of his home, including notebooks, condoms, a pillow, and anal beads.
Willoughby challenged the search as overbroad/untethered; the court denied suppression.
At trial, the government introduced Rule 404(b) pimping testimony and other acts; Willoughby challenged arrays of evidentiary rulings and sentencing enhancements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the search warrant was sufficiently particular	Warrant was overbroad and itemized without connection to the case.	Warrant tied to offenses with probable cause; not overbroad.	Warrant sufficiently particular; denial of suppression affirmed.
Whether the Rule 412 cross-examination of SW about recantation was proper	Recantation evidence aids credibility under Rule 608(b).	Recantation intertwined with sexual conduct; Rule 412 bars.	District court abused Rule 412 by excluding; harmless error analysis supports affirmance.
Whether pimping testimony under Rule 404(b) was admissible	Evidence shows Willoughby's knowledge and pattern relevant to defendant's intent.	Pimping testimony is improper character evidence, prejudicial.	Admissible for knowledge and opportunity; not reversible plain error given overwhelming evidence.
Whether Agent Hardie’s dual role as fact and expert witness required limiting instructions	Dual-role testimony requires cautionary instruction to avoid prejudice.	No proper objection raised; plain-error review applies.	Omission did not affect substantial rights; no relief awarded.
Whether Willoughby is a career offender due to §4B1.1 and whether §1591 is a crime of violence	§1591 is not a crime of violence; thus not a career-offender predicate.	§1591 can be a crime of violence under residual clause, making him a career offender.	§1591 qualifies as a crime of violence under residual clause; sentence affirmed.

United States v. Hodge, 714 F.3d 380 (6th Cir. 2013) (standards for reviewing suppression rulings)
Marcilis v. Twp. of Redford, 693 F.3d 589 (6th Cir. 2012) (particularity requirement for warrants)
United States v. Richards, 659 F.3d 527 (6th Cir. 2011) (scope of warrant authority and tailoring)
United States v. Cardinal, 782 F.2d 34 (6th Cir. 1986) (pre- am I rule 412 interpretation)
Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1997) (limits on expert testimony and weighing evidence)
United States v. Freeman, 730 F.3d 590 (6th Cir. 2013) (harmless-error standard for trial errors)
United States v. Merriweather, 78 F.3d 1070 (6th Cir. 1996) (knowledge as an element in proving crime)
United States v. Jenkins, 593 F.3d 480 (6th Cir. 2010) (probative value of prior acts and Rule 403 balancing)
United States v. Lopez-Medina, 461 F.3d 724 (6th Cir. 2006) (dual-role witness and required instructions)
United States v. Johnson, 27 F.3d 1186 (6th Cir. 1994) (prejudicial impact of prior acts evidence)
United States v. Mack, 729 F.3d 594 (6th Cir. 2013) (harmless error for evidentiary rulings)
United States v. Moon, 513 F.3d 527 (6th Cir. 2008) (double-counting and sentencing)
United States v. Garcia-Gonzalez, 714 F.3d 306 (5th Cir. 2013) (interpretation of 4B1.2 and violence consideration)
United States v. Jungers, 702 F.3d 1066 (8th Cir. 2013) (interpretation of §1591 facts and crime of violence)