Background
Coffman was convicted in 2005 of raping and sodomizing two young girls and was required to register as a sex offender for life. In 2023, while in a polyamorous relationship with two women, he groomed their minor daughters—girls who viewed him as a father figure—into engaging in sex acts with him. Coffman offered each victim $200 Nike Air Jordan shoes as payment for sex, explicitly telling them he would purchase the shoes if they complied. He also hosted a slumber party where he provided minors with alcohol, marijuana, and prescription pills, resulting in several girls becoming ill. During the party, an assistant principal learned of the drug and alcohol use and reported the incident to law enforcement.
Investigators discovered that Coffman maintained a “sex book” documenting his sexual partners, in which he had numbered the victims—noting one victim was “#68” and the other would be “#69.” Coffman used his cell phone to search Nike.com for the shoes and coordinated their purchase through the victims’ mothers using money he provided. The government charged him with two counts of commercial sex trafficking of children under 18 U.S.C. § 1591(a)(1) and one count of committing a felony offense involving a minor while required to register as a sex offender under 18 U.S.C. § 2260A.
At trial, the victims testified about the grooming, sexual assaults, and shoe payments. Coffman testified falsely that he never had sexual contact with the minors and purchased the shoes as birthday gifts, not as enticements for sex. A jury convicted him on all counts, and the district court sentenced him to 480 months imprisonment, applying a two-level obstruction-of-justice enhancement based on his perjured testimony.
The Court’s Holding
The Sixth Circuit affirmed all convictions and the sentence. The court rejected Coffman’s sufficiency-of-evidence challenge to the § 1591(a)(1) convictions, particularly his argument that the interstate-commerce element was not satisfied because all communications and sexual acts occurred at his Kentucky home. The court held that the phrase “in or affecting interstate or foreign commerce” signals Congress’s intent to regulate to the outer limits of its Commerce Clause authority and extends to purely local activities that substantially affect interstate commerce.
The court found sufficient evidence of interstate commerce because: (1) both pairs of Nike shoes were manufactured outside the United States, purchased via the internet from Nike.com, and shipped to Kentucky in interstate commerce; (2) Coffman used a cell phone—an instrumentality of interstate commerce—to facilitate the shoe purchases; and (3) Coffman provided the money specifically for the shoes’ purchase and coordinated their selection and ordering, thereby participating in an interstate transaction. The court drew a parallel to United States v. Willoughby, where a defendant’s use of a foreign-made cell phone and purchase of out-of-state items to facilitate sex trafficking satisfied the interstate-commerce requirement.
The court also upheld the obstruction-of-justice sentencing enhancement, holding that the district court made sufficient factual findings to support a perjury-based enhancement. The court identified the specific false testimony (Coffman’s denials of sexual contact and claims the shoes were birthday gifts), found it was false based on contradictory evidence including the sex book and victims’ testimony, determined it was willful based on Coffman’s active effort to mislead the jury, and found it material because it directly concerned the central elements of the charged offenses.
Key Takeaways
- Federal sex trafficking charges under § 1591(a)(1) satisfy the “in or affecting interstate commerce” requirement when items provided in exchange for sex acts travel in interstate commerce, even when all contact occurs in one location.
- Online purchases and cell phone use constitute instrumentalities and channels of interstate commerce for purposes of establishing federal jurisdiction over sex trafficking offenses.
- A defendant’s constitutional right to testify in his own defense does not shield him from an obstruction-of-justice enhancement if the testimony is false—the enhancement requires specific factual findings about falsity, willfulness, and materiality.
- Circumstantial evidence of grooming, coordination, and payment—including maintenance of a “sex book” and intercepted communications—can support convictions for commercial sex trafficking of minors.
Why It Matters
This decision clarifies and expands federal prosecutors’ ability to pursue sex trafficking charges under § 1591(a)(1) by confirming that interstate commerce can be established through the purchase and shipment of items exchanged for sex acts—even when the sexual exploitation occurs locally. For sex trafficking investigations involving minors, the ruling means prosecutors do not need to prove that the defendant transported victims across state lines or engaged in nationwide schemes. The simple fact that items purchased online travel in interstate commerce suffices. This has significant implications for digital-age sex trafficking cases, where many predators use online shopping to facilitate exploitation.
The decision also reinforces that false testimony at trial carries serious sentencing consequences through obstruction-of-justice enhancements. By upholding the enhancement despite Coffman’s exercise of his trial right to testify, the court signaled that defendants cannot use perjury as a defense tactic without exposure to enhanced sentencing. Finally, the case demonstrates courts’ willingness to use circumstantial evidence—such as coded communications, documentation of victims, and coordination patterns—to establish the deliberate, transactional nature of commercial sex trafficking involving minors.