Article by Christian A. Lobello
Jaimian Rashaad Sims, colloquially known as “Sauce Lean,” is a Houston-based rap artist and “pimp” associated with the group “The Sauce Factory” (TSF). Between 2016 and 2017, Sims became involved with co-defendant Gary Shawn Haynes, Jr., a college football player interested in joining Sims’s profession. Sims was charged with various sex crimes, including sex trafficking of a minor and sex trafficking by force, fraud, or coercion. At trial, Sims objected, inter alia, to the admission of video recordings of his rap songs and associated TSF acts, “which graphically depicted and glorified guns, drugs, prostitution, pimping, and misogyny.” The United States Court of Appeals for the Fifth Circuit held that the district court did not abuse its discretion in admitting these videos because Sims performed in all three videos, the lyrics described events closely related to the charged crimes, and although the music video evidence may have been cumulative in light of the rest of the prosecution’s case against Sims, the depictions of weapons and violence were relevant nonetheless.
The admissibility of rap music videos was an issue of first impression before the Fifth Circuit. Although the court formulated its decision by referencing case law from its sister circuits, its application in the noted case is both inconsistent and incomplete. This Note aims to supplement the court’s analysis of the admissibility of rap music videos by framing the discussion of this type of evidence not only in terms of unfair prejudice, but also impermissible character evidence that is often found within rap videos.
About the Author
Christian A. Lobello, J.D. candidate 2023, Tulane University Law School; B.S. 2020, The Ohio State University.
Citation
96 Tul. L. Rev. 1003 (2022)