Defendants Brandon Washington and Maria Georgianna Palm are charged with various crimes arising out of their scheme to recruit, entice, harbor, transport, provide, obtain, and maintain vulnerable women, and to perform commercial sex acts for their financial benefit via threats of force, fraud, and coercion.
The government retained FBI Supervisory Special Agent Steven Vienneau to testify at trial about the commercial sex industry and the commercialized sexual exploitation of victims by individuals who manipulate, coerce, entice, persuade, and control individuals to participate in prostitution.
The Defendants contended that the agent is unqualified to opine on adult consensual sex work dynamics in cases involving adult women. They argued that his professional background is “overwhelmingly” rooted in child exploitation and juvenile sex trafficking. Defendants also contended that his proposed testimony fails Fed. R. Evid. 702 reliability requirements. And last, Defendants asked the Court to exclude the testimony under Fed. R. Evid. 403 suggesting the risk of unfair prejudice given the testimony invokes emotionally charged concepts.
Law Enforcement Expert Witness
Steven Vienneau has been a Special Agent with the FBI since 2003. He supervised the squad responsible for investigating crimes against children and human trafficking including abductions homicides sexual abuse sex trafficking labor trafficking enticement child pornography and online sexual exploitation of children. He also provided training to local state federal and international law enforcement partners in conducting investigation into these matters.
Discussion by the Court
The essence of the testimony of Vienneau is to provide expert testimony about the pimp-prostitute relationship and subculture. According to the Court, such evidence will assist the jury in assessing the veracity of witness testimony who may be testifying about relationships between pimps and prostitutes. It will also assist the jury in understanding the subculture of the sex trafficking industry.
The Defendant’s allegation that the agent lacks qualifications to provide expert testimony on adult sex trafficking fails to consider the extent and depth of his experience. His experience is not limited to only minors. As explained in his disclosure, since 2004 his experience has been involved in human trafficking involving both adults and minors. His qualifications involve interviewing over 200 females involved in commercial sex, including approximately 125 adults and 75 minors. Based upon the Government submissions, Vienneau is qualified to testify as an expert on the topic of sex trafficking subculture of adults due to his knowledge, experience, training and education.
The Defendants contended that Vienneau did not meet the reliability requirement of Rule 702. The Government disclosures belie the Defendant’s assertions. The disclosures demonstrate the agent has gained his expertise through 20 years as an FBI Special Agent specializing in sex trafficking crimes. He also has honed this expertise through hundreds of hours of training and participated in over 100 investigations of sex trafficking offenses, personal interviews with over 200 victims and potential victims of sex trafficking regarding their experience with prostitution and conducted personal interviews with approximately 20 suspected traffickers.
Held
The Court denied the Defendant’s motion to exclude the testimony of Government’s expert Steven Vienneau.
Key Takeaway
Expert testimony on “the relationship between prostitutes and pimps” is relevant in a sex trafficking case as it can assist the jury in understanding a relationship which is not the subject of common knowledge of jurors.
The probative value of the agent’s testimony is great, and it goes to assisting the jury in understanding the witness’s testimony and help assess the credibility of the victims and witnesses in this case. Any risk of unfair prejudice is greatly outweighed by the probative value of the proposed evidence.
Case Details:
| Case Caption: | United States V. Washington |
| Docket Number: | 2:23cr58 |
| Court Name: | United States District Court, Washington Western |
| Order Date: | February 02, 2026 |
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