Cosby v. United States

CourtDistrict Court, N.D. Indiana
DecidedJune 17, 2022
Docket2:20-cv-00326
StatusUnknown

This text of Cosby v. United States (Cosby v. United States) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cosby v. United States, (N.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA HAMMOND DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) NO. 2:15CR31-PPS ) RONNIE CORNELL COSBY, ) ) Defendant. ) OPINION AND ORDER Ronnie Cosby was charged in a seven-count indictment based on allegations that, between December 2014 and February 2015, he pimped several underage girls and produced explicit images of them that he used to market their sexual services. T.L. was a 15-year-old girl who had run away from home and was trafficked by Cosby both in his apartment in Hammond, Indiana and in a hotel across the state border in Illinois. Cosby took photos of T.L. displaying her genitalia, and posted them to a website called Backpage to advertise her availability for prostitution. A.C. was a 14-year-old orphan when she met Cosby on a dating site and offered to have sex with him for money. Instead, Cosby recruited A.C. to sell herself to other johns, and posted sexually explicit photos of her on Backpage, by which he arranged for approximately 30 appointments during which A.C. engaged in oral sex, anal sex, and sexual intercourse for money. The government also charged that Cosby exploited a heroin addict, G.P., by supplying her with heroin in exchange for her services as a prostitute, from which Cosby kept all the money that men paid for having sex with G.P. in Cosby’s living room. The efforts of T.L.’s family to locate her eventually resulted in the arrival of the Hammond police, and a federal indictment against Cosby. After a six-day trial, a jury found Cosby guilty of sex trafficking T.L. (Count 1),

two counts of transportation of a minor (again, T.L.) for prostitution (Counts 2 and 3), and two counts of production of child pornography, one count involving images of T.L. and the other of A.C. (Counts 4 and 7). [DE 147.] Cosby was acquitted on Count 5, a charge of sex trafficking G.P. by coercion, and Count 6, a charge of transportation of minor A.C. in interstate commerce for prostitution. [Id.] I sentenced Cosby to

concurrent life sentences on Counts 1, 2 and 3, and concurrent prison terms of 30 years on Counts 4 and 7. [DE 182, 183.] Cosby took a direct appeal, and the Seventh Circuit affirmed his convictions and sentence. [DE 206.] Now before me, fully briefed and ripe for ruling, is Cosby’s motion to vacate, set aside or correct sentence filed pursuant to 28 U.S.C. §2255.

Section 2255(a) authorizes a federal court to grant relief where a federal prisoner’s sentence “was imposed in violation of the Constitution or laws of the United States, or [if] the court was without jurisdiction to impose such sentence, or [if] the sentence was in excess of the maximum authorized by law.” The Seventh Circuit has observed that this is a high bar: “Relief under §2255 is available ‘only in extraordinary

situations, such as an error of constitutional or jurisdictional magnitude or where a fundamental defect has occurred which results in a complete miscarriage of justice.’”

2 United States v. Coleman, 763 F.3d 706, 708 (7th Cir. 2014) (quoting Blake v. United States, 723 F.3d 870, 878-79 (7th Cir. 2013)). Ground One: Brady Violation

Cosby’s first ground for relief is a claim that the prosecution violated the doctrine of Brady v. Maryland, 373 U.S. 83, 87 (1963), which forbids the government from suppressing evidence that is favorable and material to the defense in a criminal prosecution. United States v. King, 910 F.3d 320, 326 (2018). Cosby contends that he “was prejudiced at the critical stage of pretrial preparation when the government failed

to completely comply with the defense discovery motion.” [DE 226 at 4.] The argument pertains to Count 4, the charge of production of child pornography based on images of victim T.L. found on Cosby’s cell phone. T.L. testified at trial that Cosby used his phone to take two photos of her (Gov’t Trial Exhibits 51A and 51B) as she bared her anus and genitalia. [DE 192 at 67 (Trial

Transcript at 707).] She testified that Cosby determined that he would take the photos with his phone and how T.L. would pose. [Id. at 69 (T.T. at 709).] Cosby told T.L. he would “send them to people he was trying to get to come have sex with (her).” [Id.] In his trial testimony, Cosby contended that those two photos were taken by Davonne Hargrave using Cosby’s phone, and that Hargrave had taken other photos of T.L. using

his own phone. [DE 194 at 122 (T.T. at 1302).] T.L. testified to the contrary — that no one else was present in Cosby’s apartment at the time he took the photos of her. [DE 192 at 147 (T.T. at 787).] 3 Cosby’s first argument is that the government withheld evidence that Davonne Hargrave’s phone had the same two images on them, and the defense could have relied on that evidence to suggest that it was not Cosby who had taken the photos. [DE 231 at

2-3.] According to Cosby, a warrant was issued on Hargrave’s cell phone but the defense never received the extraction report on that phone, or any summary of what was found. [Id. at 3.] The problem is that the application Cosby relies on is not for a warrant to search the contents of Hargrave’s phone, but instead for an order directing T-Mobile to

provide customer or subscriber account information and usage records for a particular time period. [DE 235 at 8.] Cosby provided only the first page of the document as his Exhibit 3 [DE 231 at 24], but the government has provided the full document. [DE 235- 1.] The government represents that it never sought or obtained a warrant to search the contents of Hargrave’s phone. [DE 235 at 8.] So the exculpatory evidence Cosby claims

the government suppressed was never in the government’s possession to begin with. Under these circumstances, there can be no Brady violation. United States v. Thomas, 835 F.3d 730, 734 (7th Cir. 2016) (to prove a Brady violation, defendant must show favorable evidence was suppressed). The second category of Brady material relating to Count 4 that Cosby claims was

suppressed relates to the contents of T.L.’s phone. This claim is perplexing. Cosby argues that the government obtained two warrants to search the contents of T.L.’s phone based on two different phone numbers, but that the defense never received any 4 information or data relating to February 8 or 9, 2015, the first two days covered by one of the orders. [DE 231 at 3.] The government responds that it did in fact make available to the defense the entire forensic report received on one of T.L.’s phone numbers, and

produced in discovery the more limited subscriber information, call logs and IP addresses it obtained from AT&T for T.L.’s previous phone number. [DE 235 at 9; DE 101-1 at 10; DE 101-3 at 4.] To the extent that the extraction report contained no data for February 8 or 9, the government reasonably suggests that none could be recovered because, as T.L. testified at trial, she removed her phone’s SIM card on February 8, and

Cosby later replaced it with a new one. [DE 192 at 54-55, 143, 228 (T.T. at 694-95, 783, 868).] So there was no Brady violation because the government did not have, nor was it aware of, the supposedly exculpatory material in the first place. In sum, Cosby’s Brady claims do not identify information or evidence that actually existed, and which the government possessed but did not provide to the defense. As a result, there is no Brady

violation.

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