By: Derek Hawkins//September 10, 2018//
7th Circuit Court of Appeals
Case Name: United States of America v. Jaboree Williams
Case No.: 18-1002
Officials: MANION and BARRETT, Circuit Judges, and GETTLEMAN, District Judge.
Focus: Court Error – Expert Testimony
Jaboree Williams argues that his conviction was tainted by improperly admitted expert testimony. He maintains that the government violated the expert disclosure rules by giving him inadequate notice of what its expert planned to say at trial. Moreover, he says that the government used the expert’s testimony to make an argument that the Federal Rules of Evidence prohibit: that he had the character of a sex trafficker and was therefore likely to have committed sex‐trafficking crimes.
While the government did not violate the rules prohibiting the use of character evidence, it probably did violate the expert disclosure requirement. Nonetheless, we affirm Williams’ conviction because any error was harmless. The evidence of his guilt was so overwhelming that the jury would surely have convicted him even if the government’s expert had not testified.
Affirmed