The Court granted in part and denied in part Defendants Terrance Williams and Eric Hayes’ motion to exclude the expert testimony of Dr. Sharon W. Cooper pursuant to, inter alia, Rule 702 of the Federal Rules of Evidence and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).
Defendants Terrance Williams and Eric Hayes and fourteen other individuals were named in a thirty-two count indictment alleging a multi-year, nationwide conspiracy to engage in the interstate sex trafficking of women, including juveniles. As part of its case-in-chief, the Government proposed to call Dr. Sharon W. Cooper as an expert witness to offer opinion testimony in three general areas: (1) the societal and criminal justice implications of prostitution and the sexual exploitation of women; (2) the medical and mental-health aspects of prostitution, including general testimony on victim risk and vulnerability factors and on common methods of grooming and deterrents to escape; (3) and the medical and mental-health impact that life as a prostitute had on certain women involved in this case.
First, the Court found that the first category of evidence that the Government intended to offer through Dr. Cooper – evidence about the societal and criminal justice implications of prostitution – was inadmissible as a matter of law, as it was irrelevant under Federal Rule of Evidence 401.
Next, the Court considered Dr. Cooper opinions regarding: (1) the medical and mental-health aspects of commercial sexual exploitation of women and juveniles; and (2) the specific risk factors, medical conditions, and mental-health issues, if any, that are present in the women allegedly exploited as part of the interstate conspiracy charged in the superseding indictment.
Based on the Court’s review of Dr. Cooper’s educational background, professional experience, and academic credentials, the Court found that Dr. Cooper possessed the specialized knowledge to qualify her as an expert on the commercial sexual exploitation of adults and juveniles, as well as the medical and mental-health aspects of prostitution. The Court also found that Dr. Cooper’s proffered testimony met the Daubert requirement of reliability regarding the health aspects of prostitution, as she reached her conclusions based on review of facts that were generally accepted in the field. Next, the Court held that Dr. Cooper’s opinions related to the health aspects of prostitution met the “fit” requirement, as it was both relevant and would assist the trier of fact. The Court found that the background information Dr. Cooper could provide would assist the jury to understand the dynamics of exploitation, to explain why the women did not leave their pimps, and to generally demystify the relationship between pimp and prostitute.
The Court also found that Dr. Cooper’s proffered testimony about the medical and mental-health effects specific to the women involved in the alleged prostitution conspiracy failed to meet the Daubert standards, finding that her methodology was unreliable, in that she diagnosed the various women with physical and mental-health ailments based upon telephone conversations lasting approximately one hour, without reviewing the victim’s medical records. The Court also found that the medical and mental-health effects on the individual women were relevant to the charges being brought against Defendants Williams and Hayes, and did not satisfy the “fit” requirement.