United States v. Maurice Williams
714 F. App'x 917
| 11th Cir. | 2017Background
- Maurice Williams was convicted of six counts: five counts of sex trafficking of a minor by force, threats, fraud, or coercion (18 U.S.C. § 1591) and one count of conspiracy to commit sex trafficking (18 U.S.C. § 1594(c)).
- Williams moved for judgment of acquittal after the government rested and renewed post-verdict; he preserved sufficiency-of-the-evidence review on appeal.
- Trial evidence showed victims were minors with unstable backgrounds (single-parent homes, dropped out of school, foster care, ran away), making them vulnerable to recruitment.
- Testimony established physical violence: Williams restrained and punched a victim in a hotel room; other victims suffered injuries from altercations involving Williams or his co-defendant.
- Evidence of emotional, psychological, and financial control: Williams had sexual relationships with a victim, provided money, housing plans, gifts, phones, drugs, and promises of care—creating dependency and fear of losing support.
- The Eleventh Circuit reviewed the sufficiency of the evidence de novo, viewing facts in the light most favorable to the government, and affirmed the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for substantive § 1591 counts (Counts 2–6): whether government proved Williams knew or was recklessly indifferent that force/threats/fraud/coercion would be used | Government: testimony and documentary evidence show minor victims were vulnerable and Williams used/allowed force and control; thus knowledge or reckless disregard established | Williams: evidence insufficient to prove he knew or recklessly disregarded that force/coercion would be used to cause minors to engage in commercial sex | Court: Affirmed — reasonable juror could find knowledge or reckless disregard based on victims’ vulnerability, physical violence, and psychological/financial control |
| Sufficiency of evidence for conspiracy to violate § 1591 (Count 1) | Government: evidence supports an agreement with co-defendant to use force/threats/coercion to cause minors to engage in commercial sex | Williams: no adequate proof of a conspiratorial agreement to use coercive means | Court: Affirmed — reasonable juror could conclude Williams conspired with co-defendant to use force/threats/coercion |
| Definition/application of “coercion” and “serious harm” under § 1591(e) | Government: coercion includes physical threats, schemes to cause belief of harm, and abuse of legal process; serious harm covers physical and nonphysical harms under surrounding circumstances | Williams: argued evidence did not establish coercion sufficient to compel a reasonable person to engage/continue in commercial sex | Court: Affirmed — physical violence plus emotional/financial domination met statutory coercion/serious-harm standards |
| Standard of appellate review for sufficiency | Government: appellate de novo review with evidence viewed in government’s favor supports verdict | Williams: invoked sufficiency standard to argue reversal | Court: Applied de novo review and found evidence sufficient |
Key Cases Cited
- United States v. Rodriguez, 218 F.3d 1243 (11th Cir. 2000) (standard for reviewing denial of judgment of acquittal)
- United States v. Taylor, 972 F.2d 1247 (11th Cir. 1992) (appellate standard de novo when issue preserved)
- United States v. Jiminez, 564 F.3d 1280 (11th Cir. 2009) (view evidence in light most favorable to government when assessing sufficiency)
- United States v. Williams, 144 F.3d 1397 (11th Cir. 1998) (preservation of sufficiency issue after judgment-of-acquittal motion)
- United States v. Bichsel, 156 F.3d 1148 (11th Cir. 1998) (contrast on preservation principles)