United States v. Brooks

N.K., a 16-year-old, and R.O., a 15-year-old, escaped from an Arizona juvenile detention center and met Depaul Brooks and Uawndre Fields (plaintiffs). Fields was a pimp who worked out of San Diego. R.O. told Brooks and Fields that R.O. and N.K. were minors. Brooks and Fields bought bus tickets to San Diego for N.K. and R.O. under false names. Fields purchased provocative clothing for R.O. and N.K. and posted prostitution advertisements online for R.O. and N.K. R.O. engaged in several acts of prostitution while in San Diego. Brooks and Fields then drove R.O. and N.K. back to Arizona and dropped R.O. off in an area known for prostitution. N.K. was taken back to Brooks and Fields’s hotel room. R.O. was arrested after a patrol officer observed she was underage. Using information obtained from R.O., Arizona police located and arrested Brooks and Fields. The federal government (defendant) charged Brooks and Fields with (1) child sex trafficking; and (2) interstate transport of minors for the purpose of prostitution. During the trial, the court admitted expert testimony from Detective Christi Hein, who testified about the prostitution business and the relationship between prostitutes and pimps. Detective Hein had conducted 25 full-scale child-prostitution investigations, had extensive training on child prostitution, and frequently worked undercover to gather evidence about child prostitution and trafficking operations. Brooks and Fields were convicted after a jury trial. Brooks and Fields appealed, arguing that (1) Detective Hein’s testimony was improperly admitted; and (2) there was insufficient evidence to convict.