United States v. Rahmad Geddes
844 F.3d 983
| 8th Cir. | 2017Background
- Geddes traveled with Schreiner (Jan 6–14, 2014); during the trip he bought and distributed cocaine, and Schreiner was coerced into prostitution via ads on Backpage and a phone provided by co-defendant Funk.
- Schreiner testified she felt she could not refuse or return home; Geddes slapped her after a disputed payment and prevented her requests to go home; she later reported the events to her pastor.
- Geddes was indicted on three counts: sex trafficking by force/fraud/coercion (18 U.S.C. § 1591), transportation for prostitution (18 U.S.C. § 2421), and armed career criminal in possession of a firearm (18 U.S.C. § 922(g)).
- Pretrial motions denied: severance of firearm count from sex‑trafficking counts; exclusion of prior‑bad‑act testimony from Nicole Meyer (2010 assault/threat); exclusion of expert testimony on sex‑trafficking operations (Ann Quinn).
- Trial evidence included Schreiner and Funk testimony, limited 404(b) testimony from Meyer, expert testimony about trafficking operations and cellphone tower location analysis; jury convicted on all counts; sentence 282 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether firearm count should be severed from sex‑trafficking counts | Joinder proper because all counts arose from same trip and common facts; evidence completes the story | Geddes argued different facts/witnesses and risk of inability to compartmentalize, causing severe prejudice | Denied — joinder permissible; Schreiner's testimony completed the story and no severe prejudice shown |
| Admissibility of Nicole Meyer 404(b) testimony (2010 assault/threat) | Relevant to material issue of intent/knowledge for §1591 and §2421; admissible for non‑propensity purpose | Geddes argued it was improper propensity evidence, remote, and unduly prejudicial | Admitted — four‑part 404(b) test satisfied (relevance to intent, similarity, recency, limited prejudice with limiting instruction) |
| Admissibility of expert testimony on trafficking operations (Ann Quinn) | Expert would help jury understand pimp/prostitute dynamics and jargon; reliable given experience | Geddes argued testimony unnecessary, overbroad, unreliable, and court should have held a Daubert hearing | Admitted — district court did not abuse discretion; testimony analogous to allowed expert evidence in prior precedent |
| Sufficiency of evidence for Counts 1 (§1591) and 2 (§2421) | Government: testimony, co‑defendant accounts, expert cell‑tower data and credibility support convictions beyond reasonable doubt | Geddes: Schreiner was a willing prostitute; interstate transportation intent not proven because plan arose after entering MN | Affirmed — reasonable jury could credit prosecution evidence; cellphone tower data and testimony supported interstate transport with intent and coercion/force findings |
Key Cases Cited
- United States v. Erickson, 610 F.3d 1049 (8th Cir. 2010) (standard for joinder/severance review)
- United States v. Brown, 653 F.3d 656 (8th Cir. 2011) (other‑act evidence may "complete the story" and be admissible)
- United States v. Williams, 796 F.3d 951 (8th Cir. 2015) (four‑part 404(b) test and admissibility analysis)
- United States v. Evans, 272 F.3d 1069 (8th Cir. 2001) (expert testimony on prostitution ring operations admissible)
- United States v. Campbell, 764 F.3d 880 (8th Cir. 2014) (mens rea requirements under §1591)
- United States v. Bell, 761 F.3d 900 (8th Cir. 2014) (standard for reviewing sufficiency of evidence)