112 F.4th 545
8th Cir.2024Background
- Keith Euring, Sr., was convicted of sex trafficking of a child and distribution of marijuana to a person under 21.
- The alleged victim, S.G., a minor, traveled with Euring to Chicago, set up a dating profile with his help, and met with clients for sex acts.
- At trial, evidence included S.G.'s testimony, corroborating phone and travel records, and client testimony describing sex acts for money.
- Euring sought to admit grand-jury testimony from Dr. Ali (unavailable at trial) and to introduce extrinsic evidence of S.G.’s inconsistent statements.
- The district court excluded Dr. Ali’s transcript and limited impeachment evidence, then denied Euring’s motion for acquittal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Dr. Ali’s grand jury testimony | Government lacked similar motive at grand jury | Govt. had similar motive; testimony critical to defense | Exclusion affirmed; no similar motive existed |
| Introduction of Extrinsic Evidence of Prior Statements | S.G. should explain/deny statements before extrinsic proof | Only denial required, not explanation | Affirmed; both denial or explanation opportunity required |
| Sufficiency of the Evidence (Trafficking Conviction) | Evidence sufficient to show knew/risked sex act | Evidence insufficient to show knowledge commercial sex act would occur | Evidence sufficient; conviction affirmed |
Key Cases Cited
- United States v. Dunn, 76 F.4th 1062 (8th Cir. 2023) (standard for evidentiary rulings)
- United States v. Salerno, 505 U.S. 317 (1992) (“similar motive” requirement for prior testimony admissibility)
- United States v. Smith, 383 F.3d 700 (8th Cir. 2004) (standard of review for evidentiary rulings)
- United States v. Paul, 885 F.3d 1099 (8th Cir. 2018) (sufficiency standard for sex trafficking of a child)