In US v. Todd, No. 08-30360, the court affirmed defendant's conviction of three counts of sex trafficking, holding that 1) defendant knew, in the sense of being aware of an established modus operandi, that his conduct would in the future cause a person to engage in prostitution; and 2) the evidence of defendant's knowledge of his own modus operandi in securing an income from prostitution by a pattern of coercion was sufficient to support the jury's verdict.
As the court wrote: "Jerome Eugene Todd appeals his conviction of three counts of sex trafficking in violation of 18 U.S.C. § 1591(a)(1) and one count of conspiracy to engage in sex trafficking in violation of 18 U.S.C. § 371. We affirm the convictions."