Lavellous Purcell v. United States

Whether a search warrant ordering Facebook to hand over the defendant’s entire account to law enforcement for review, without limiting either Facebook or law enforcement as to what to look for or seize, is a plainly unconstitutional “[I]nternet-era version of a general warrant.” United States v. Blake, 866 F.3d 960, 974 (11th Cir. 2017).

Whether a defendant “transports an[] individual” in interstate commerce for prostitution, in violation of the Mann Act, 18 U.S.C. § 2421(a), merely by arranging job opportunities for the victim that she then availed herself of by crossing state lines of her own accord, as the court below and the Fifth and Ninth Circuits have held, or whether the defendant (or an agent) must be involved in arranging the victim’s interstate transportation, as the D.C., First, and Eighth Circuits have held.

Whether a witness’s prior out-of-court “statement,” which contradicts the witness’s trial testimony, is nonetheless admissible as a “prior consistent statement” under Federal Rule of Evidence 801(d)(1)(B), because the contradictory statement was embedded in a broader narrative that was “largely consistent with” the story the witness told at trial.