United States v. Marcus Thompson
2017 U.S. App. LEXIS 13739
| 7th Cir. | 2017Background
- In June 2015, Thompson encountered a 15‑year‑old runaway, lured her with promises of modeling work, then transported her across states and sold her sexual services to multiple men over ~6 weeks.
- Thompson and his wife posted suggestive and nude photos online, arranged paid sexual encounters (with a sliding fee scale), and permitted customers to take photos/videos of the minor.
- Thompson used threats and coercion (including threats after escape attempts and when the victim refused certain sex acts) and took steps to conceal the victim’s identity.
- The victim was eventually returned to Illinois and received medical attention; Thompson was arrested and indicted under 18 U.S.C. §§ 1591 and 1594 for sex trafficking of a child and conspiracy.
- Thompson pleaded guilty (no plea deal), certified the presentence report’s facts as true, and was sentenced to life imprisonment following adoption of the PSR and § 3553(a) analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Voluntariness of guilty plea | N/A (government contended plea was valid) | Thompson argued plea was not knowing/voluntary | Plea was knowing and voluntary; court’s colloquy and Thompson’s background support validity. |
| Factual basis for plea | N/A | Thompson argued insufficient factual basis before judgment | Sufficient factual basis existed via stipulation and PSR; court may rely on record/PSR. |
| Procedural errors at sentencing (e.g., refusal to accept submitted case summaries; consideration of outside materials; labels applied) | N/A | Thompson claimed multiple procedural errors that rendered sentence unreasonable | No reversible procedural error; court acted within discretion and limited reliance to PSR facts. |
| Substantive reasonableness of life sentence | N/A | Thompson argued sentence was unreasonable given mitigating evidence (cognitive issues, childhood adversity) and comparative sentencing info | Life sentence affirmed as reasonable given severity, coercion, and lasting harm; sentencing within Guidelines and § 3553(a) support. |
Key Cases Cited
- United States v. Woodard, 744 F.3d 488 (7th Cir. 2014) (factors for assessing voluntariness of a guilty plea)
- United States v. Blalock, 321 F.3d 686 (7th Cir. 2003) (factors for plea voluntariness inquiry)
- United States v. LeDonne, 21 F.3d 1418 (7th Cir. 1994) (district court may establish factual basis from the record)
- United States v. Arenal, 500 F.3d 634 (7th Cir. 2007) (PSR may supply factual basis for offense elements)
- United States v. Nania, 724 F.3d 824 (7th Cir. 2013) (standards of review for procedural and substantive sentencing claims)
- United States v. Blagojevich, 854 F.3d 918 (7th Cir. 2017) (Guidelines serve anti‑disparity function)
- United States v. Hull, 608 F.3d 340 (7th Cir. 2010) (mitigating evidence must be meaningfully distinct to affect sentence)