DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
173592P.pdf 12/18/2018 United States v. Clark Betts, Jr.
U.S. Court of Appeals Case No: 17-3592
U.S. District Court for the Southern District of Iowa - Des Moines
[PUBLISHED] [Shepherd, Author, with Loken and Benton, Circuit Judges]
Criminal case - Criminal law. The district court did not err in limiting
defendant's cross-examination of one of the victims in this sex
trafficking prosecution as defendant was able to get across the crux of
his defense in the questions which were permitted; further, the victim
admitted there were inconsistencies between her trial testimony and her
prior interviews, and further cross-examination would not have given the
jury a significantly different impression of the witness's credibility;
the court did not err in excluding, under Rule 412, evidence that the
victims of defendant's sex trafficking continued to exchange sex for crack
after his arrest; defendant failed to file the Rule 412(c) motion giving
notice of his intent to introduce the evidence and the evidence was
inadmissible as it was irrelevant to the issue of whether defendant
trafficked the victims; in any event, evidence concerning the matter was
presented; no error in admitting other bad acts evidence as the evidence
was necessary to place his conduct with the victims, such as grooming, in
context.