## Facts

- A federal grand jury in the Northern District of Georgia indicted Amador Cortes-Meza and several co-defendants on charges tied to a multi-year operation involving sex trafficking, forced prostitution, and related immigration offenses.
- The operation recruited young women in Mexico through romantic overtures, job promises, or threats, arranged their unlawful entry into the United States, and housed them in locations in the Atlanta area.
- After arrival, victims were told they would work as prostitutes; each was assigned to a controlling defendant (“padrote”) and transported nightly to customers.
- Victims were required to service numerous customers per night and surrender all earnings; the defendants monitored compliance and imposed strict control over the victims’ movements and contacts.
- Multiple victims described physical violence, threats of violence toward them and their families, insults, and psychological coercion used to maintain control and compel prostitution; two victims described particularly severe abuse.
- At trial, Cortes-Meza conceded he facilitated illegal entry but argued the women voluntarily chose prostitution.
- Victims testified to coercion and abuse; their accounts were corroborated by other witnesses, including law-enforcement and medical personnel.
- Over objection, the district court admitted portions of victims’ diaries written while they were under the defendants’ control, describing contemporaneous fear, depression, and hopelessness.

## Issues

1. Whether the district court abused its discretion by admitting victims’ diary entries over objections based on hearsay, relevance, unfair prejudice, and the Confrontation Clause.
2. Whether other challenged evidentiary and trial-management rulings warranted reversal.
3. Whether the sentence imposed was substantively unreasonable under 18 U.S.C. § 3553(a).

## Decision

- The Eleventh Circuit affirmed the convictions and sentence.
- The court held the district court did not abuse its discretion in admitting the diary excerpts.
- The court concluded the diary entries fit the hearsay exception for then-existing mental or emotional condition and were relevant to whether the victims acted voluntarily or under coercion.
- The court upheld the district court’s Federal Rule of Evidence 403 determination that the probative value was not substantially outweighed by unfair prejudice.
- The court rejected Confrontation Clause objections because the diary authors testified and were subject to cross-examination.
- The court held the sentence was within the district court’s discretion given proper Guidelines calculations and consideration of § 3553(a) factors in light of the seriousness and harm of the offenses.

## Legal Principles

- Statements reflecting a declarant’s then-existing mental or emotional condition may be admitted under the state-of-mind hearsay exception when offered to show contemporaneous feelings relevant to disputed issues.
- In trafficking prosecutions, evidence bearing on coercion versus consent is relevant to proving force, threats, or coercion elements.
- Evidence is not excludable under Rule 403 merely because it is powerful; exclusion requires that unfair prejudice substantially outweigh probative value, and appellate review is deferential to the trial court’s balancing.
- The Confrontation Clause is satisfied when the declarant testifies at trial and is available for cross-examination regarding prior out-of-court statements.
- A sentence is generally upheld as substantively reasonable when the district court correctly calculates the advisory Guidelines range and reasonably applies the § 3553(a) factors to the proven offense conduct.

## Conclusion

The Eleventh Circuit upheld Cortes-Meza’s trafficking-related convictions and life-equivalent sentence, ruling that victims’ diary entries were properly admitted as contemporaneous state-of-mind evidence relevant to coercion and that the district court acted within its discretion both in evidentiary rulings and in imposing a severe sentence proportionate to the offenses.


United States v. Cortes-Meza, 685 F. App’x 731 (11th Cir. 2017)