⚖ Oral Arguments, with Context

The Second Circuit asks whether withheld evidence could have changed Napoleon Scott's guilty plea. Prosecutors accused Scott of trafficking Jane Doe on Brooklyn's Penn Track. After Scott was jailed, the government says his co-defendant, James Mangham, watched Jane Doe, tried to stop her from cooperating with police, and discussed retaliation. Scott pleaded guilty in December 2023 to sex-trafficking conspiracy under Section 1594(c). Scott says that before the plea, Mangham told prosecutors the men ran separate operations, recruited different women, and did not pay one another. The government gave those statements to Scott eight days before sentencing, not before his plea. Scott did not withdraw the plea and received 160 months, but later said he would have gone to trial if he had known. The appeal asks whether Mangham's statements were favorable and material under Brady—enough to create a reasonable probability of a different plea decision.

United States of America v. Scott (No. 25-1587) — U.S. Court of Appeals for the Second Circuit, argued September 16, 2026.