United States v. Chanze Pringler
2014 U.S. App. LEXIS 16481
| 5th Cir. | 2014Background
- BL, 16, ran away from foster care and met Pringler; she began a sexual relationship with him.
- Norman and BL were pro-prostitution partners, with Norman posting ads for BL using webpages; Pringler owned key advertising laptop.
- Pringler financed and facilitated prostitution: bought and supplied the laptop, paid for hotel rooms, and provided transportation.
- Undercover sting on March 16, 2011 led to arrest of Norman and BL after Daggers identified Pringler surveilling; laptop and related items seized.
- Indicted for aiding and abetting sex trafficking of a minor under 18 U.S.C. §1591(a) and 18 U.S.C. §2; district court adopted PSR and sentenced within Guidelines range.
- On appeal, Pringler challenges sufficiency of the evidence, ineffective assistance of counsel, and two Sentencing Guidelines enhancements (computer-use and undue-influence).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for aiding and abetting §1591(a) | Pringler argues only presence at scene; insufficient to prove aiding and abetting. | Government shows Pringler's integral role (money, accommodations, laptop, transport). | Evidence supports aiding-and-abetting liability; not plain error. |
| Ineffective assistance for failure to move for acquittal | Counsel’s failure to move for acquittal prejudiced the defense. | No prejudice; record shows substantial involvement. | No prejudice; ineffective-assistance claim rejected on direct appeal. |
| Computer-use enhancement under § 2G1.3(b)(3)(B) | Note 4 limits applicability to direct communication with minor or custodian. | Undisputed use of computer to advertise and solicit third parties; note 4 inconsistent. | Application note 4 inconsistent; enhancement applied based on plain language of guideline. |
| Undue-influence enhancement under § 2G1.3(b)(2)(B) | Victim acted voluntarily; no undue influence. | Victim testified to fear and control by Pringler; evidence supports undue influence. | Upheld; substantial evidence of compromised voluntariness. |
Key Cases Cited
- United States v. Garcia–Gonzalez, 714 F.3d 306 (5th Cir. 2013) (elements of the substantive offense and aiding-and-abetting liability)
- United States v. Delgarza–Villareal, 141 F.3d 133 (5th Cir. 1997) (aiding-and-abetting liability standard)
- United States v. Rosalez–Orozco, 8 F.3d 198 (5th Cir. 1993) (ineffective-assistance review framework on appeal)
- United States v. Patterson, 576 F.3d 431 (7th Cir. 2009) (application note interpretation of computer-use enhancement under § 2G1.3(b)(3))
- Stinson v. United States, 508 U.S. 36 (1993) (notes that are inconsistent with guidelines cannot control)
- Green v. Bock Laundry Mach. Co., 490 U.S. 504 (1989) (interpretive note cannot override clear guideline language)
- United States v. Ashburn, 20 F.3d 1336 (5th Cir. 1994) (note on treatment of guidelines language)