Fighting Modern-Day Slavery: Justice in Human Trafficking Cases Requires a Victim-Centered Approach

Tragically, the headline on October 26, 2020, read: “Ohio’s largest ever anti-human trafficking operation results in 154 rescues, 179 arrests—more than 150 women and children were rescued.” This is hardly unique, with multiple headlines of a similar nature across the United States in 2020.

Although slavery and involuntary servitude were abolished by President Abraham Lincoln in 1865, in 2021, human trafficking remains a form of modern-day slavery, recognized as the biggest human rights violation of our time. Within this despicable practice, perpetrators profit from the control and exploitation of men, women, and children through force, fraud, or coercion for sex, labor, or both. Human trafficking cases have been reported in every state in America.¹

The reason there are so many cases is simple: Human trafficking is one of the most profitable criminal enterprises in the world. Ranking it as the second most profitable criminal industry behind the drug trade, the International Labor Organization (ILO) estimates forced labor and human trafficking to be a $150 billion industry worldwide² and estimated that in 2016, approximately 40.3 million people were trapped in modern slavery—one out of four of whom are children.³

Presiding over Human Trafficking with a Victim-Centered Mission

As Dr. Martin Luther King Jr. said, “Morality cannot be legislated but behavior can be regulated. Judicial decrees may not change the heart, but they can restrain the heartless.” Put less eloquently, the United States is a country of laws, which is what allows law enforcement and prosecutors to act. Surprisingly, laws that directly address human trafficking did not exist until the year 2000, when the Trafficking Victims Protection Act passed, followed by state laws in each state of the United States. Over the last 20 years, prosecutors have been learning how to effectively fight human trafficking and hold traffickers and criminal buyers accountable while protecting the dignity and safety of the victims. This article is dedicated to all the victims and survivors of human trafficking who taught judges, prosecutors, defense attorneys, and community partners about the power and resilience of the human spirit despite being subjected to unspeakable cruelty.

Handling cases involving human trafficking is complex for everyone in the justice system, including judges. It requires special training, skill, knowledge, and strategy, in terms of both accommodating victims and witnesses as well as navigating through the ever-changing myriad laws and evidentiary rules that may apply. Judges should be aware that the overarching theme for prosecutors who have brought human trafficking charges is a victim-centered prosecution, but not one that is centered on the testimony of the victim. It is trauma-informed and victim-centered, but the case is built in a fashion that does not put the burden on the victim’s shoulders to carry the caseload because of the relational dynamics with the perpetrator, as well as other challenges faced by victims.

In presiding over human trafficking cases, judges are influential in promoting best practices on the part of both the prosecution and the defense. Their understanding of the law, as well as current best practices in law enforcement investigation, victim advocacy, and prosecution, can help elevate justice for victims.

Human trafficking is a historic threat internationally and in the United States to the dignity and safety of humans and communities. There are, however, an increasing number of laws designed to define, combat, and punish trafficking activity.

State and Federal Laws

Section [1] of the Preamble to the ABA Model Code of Judicial Conduct states, “An independent, fair and impartial judiciary is indispensable to our system of justice,” and that our U.S. legal system is based on the principle that judges “will interpret and apply the law that governs our society.” Understanding the challenges and complexities of the laws governing human trafficking will promote the judicial function stated in section [1], recognizing that “the judiciary plays a central role in preserving the principles of justice and the rule of law.”

Laws to effectively deal with human trafficking activity, including definitions, appropriate punishment, and deterrence, are relatively new. Here are some simple definitions that are similar across the United States:

• Sex trafficking is the exploitation of a person by means including coercion or deceit to engage in commercial sexual activity, prostitution, exotic dancing, or pornography. (When the victim is a minor under the age of 18 years old, sex trafficking does not require force or coercion. Minors cannot legally consent to sexual activity[.])
• Labor trafficking is the exploitation of a person by means including coercion or deceit for labor services. Labor trafficking victims are often forced into domestic servitude, construction, restaurant, agricultural, massage parlors, or sweatshop factory work with little or no pay.⁴

Although specific elements of trafficking statutes vary from state to state, the National Conference of State Legislatures (NCSL) recognizes that many are consistent.⁵ They note that most states require prosecutors to prove traffickers compelled their victims into engaging in labor or sexual servitude. They further note that the majority of laws include elements of “force, fraud, and coercion,” but that definitions are subject to significant variation among states. As an example, they note that some states use a definition that focuses primarily on the use of physical force, while other states have adopted a broader definition, which includes psychological control, legal harassment, financial threats, and drug addiction.

Human trafficking–related laws also cover the common practice of traffickers working together, as reflected in the indictment of Jeffrey Epstein’s female co-conspirator Ghislaine Maxwell, which identified her role in helping Epstein recruit, groom, and abuse victims.⁶

Enhanced Penalties Addressing Demand

Judges handling human trafficking cases are aware that one of the persistent challenges surrounding the fight against human trafficking is addressing demand. Many jurisdictions impose significantly different penalties on traffickers versus commercial sex consumers. This discrepancy exists despite the fact that demand drives trafficking activity.

The NCSL notes that some states have attempted to level the playing field, imposing the same penalties on offenders who purchase sex that apply to traffickers—usually at the felony level.⁷ Other states, however, punish solicitation or buying sex as misdemeanors.⁸ The NCSL notes that a third group of states have attempted to find a middle ground, creating a crime consisting of a more serious version of solicitation or a less serious type of human trafficking.⁹

Pandemic Profit

As indicated by an increased number of cases on many court calendars, human traffickers have capitalized on the pandemic to further their insidious trade. As reported by Reuters,¹⁰ Morgane Nicot, a team leader in the Trafficking and Migrant Smuggling Section of the United Nations Office on Drugs and Crime, explains that the pandemic has driven human trafficking increasingly underground, “fueling fears of more violent means of control” used against exploited victims. Nicot also explains how traffickers have expanded their reach, misusing the internet and other types of communication technology “to advertise, recruit and exploit persons, and especially lure children whom they groom for sexual online exploitation.”

Reuters also quotes Ryna Sherazi, spokeswoman for Anti-Slavery International, who notes that not everyone is equally affected by COVID-19. She explains that sudden job losses “leave communities vulnerable to exploitative work” and force people “to make risky choices, just to make ends meet and support their families.” Regarding reporting suspected trafficking activity, Sherazi also notes that pandemic restrictions have caused a halt to many workplace inspections, resulting in fewer chances to report labor trafficking.

Nicot and Sherazi both recognize the tie-in between lockdowns and survivor access to needed care, noting that the pandemic has adversely impacted the ability of governments and nongovernmental organizations (NGOs) to provide essential services to victims in need.

Gang Involvement in Human Trafficking

Judges handling human trafficking cases should be aware of the fact that one of the trends in human trafficking is the increasing involvement of gangs. In 2010, the National Institute of Justice funded the Urban Institute’s Justice Policy Center for the purpose of determining the structure and size of what they termed the “underground commercial sex economy” in eight major U.S. cities.¹¹ Regarding their results, they found that in five of the sites they studied, the involvement of gangs in human trafficking appeared to be increasing.

This very real involvement of dangerous gangs in human trafficking requires a level of organized crime expertise by judges, investigators, and prosecutors, as well as detailed care in prioritizing the safety of victims and witnesses in these cases. Such involvement may also require judges to decide whether to admit expert testimony on the subject of gangs, as well as trafficking activity.

Trafficking Victims Are Hiding in Plain Sight

Presiding over human trafficking cases involves insight into how this insidious crime occurs, which involves a level of knowledge that extends beyond the courtroom. The first step in addressing the problem of human trafficking is identifying where it is taking place. Unfortunately, the answer to that question is: everywhere. As illustrated by notorious, high-profile cases such as Jeffrey Epstein, trafficking activity can occur in any neighborhood and in any zip code, from low-income to upscale. Where there is a market, there will be trafficking activity.

Victim Myths Fuel Misidentification

One of the many tasks facing judges handling human trafficking cases is distinguishing between defendants and victims—regardless of how they are labeled in criminal complaints. This analysis involves examining the subtle coercive relational dynamics and power imbalance between parties in trafficking cases, which often cause them to fly under the radar in the first place.

In the community, victims are often overlooked because community members, and even some members of law enforcement, do not know what to look for or where to look. Dramatic media images of young women bound together with chains, gagged, confined in cages or branded with bar codes, while unfortunately reflective of some severe cases, are not an accurate portrayal of most instances of human trafficking. A significant number of human trafficking victims are bound by invisible chains of shame, love, and loyalty. Some relationships between human traffickers and victims masquerade as consensual romantic relationships, paraded out in the open, right under the noses of citizens who fail to recognize the subtle relational dynamics of manipulation and coercion.

Labor trafficking victims sometimes fly under the radar because authorities are focused on detecting the sex trafficking of minors.¹² Identifying labor trafficking cases is further complicated by victim unfamiliarity with the elements of the crime, resulting in an inability to accurately classify their employment situation.¹³

Complicating the identification procedure further is the fact that some charged defendants are also victims. Judges are in a good position to observe and detect defendants who may more appropriately be viewed as victims. As they listen to witness testimony and review the evidence, they may detect signs of duress, extortion, undue influence, or other factors that indicate other charged defendants bear greater culpability, and they may even be in a position to consider the issue of having separate counsel for charged defendants to explore separate defenses. Multiple suspects may be rounded up in a human trafficking case, but at the lower rungs, some defendants, particularly those in a “recruiting” position, might be more appropriately viewed as victims whose behavior was performed under threat of physical harm or duress.

Special Courtrooms and Vertical Prosecution

Judges should recognize the value of consistency in handling human trafficking cases due to the unique issues involved. Having specialty courtrooms with expert judges handling those cases can have a great benefit. At a minimum, if there isn’t the ability to have a dedicated courtroom, having specific judges who develop expertise in human trafficking handle those cases and serve as trainers to other judges can yield trust in the justice system. It is imperative on the prosecution side to have prosecutors with expertise handle human trafficking cases in a vertical manner so the same prosecutor is with the victim throughout the court journey. When it works best is when dedicated courtrooms have consistency with the same judge, prosecutor, and defense attorney working in specialty courts. In San Diego County, the juvenile specialty court is called RISE, and it has the benefit of consistency and expertise by the justice partners.

Providing stability through vertical prosecution builds victim confidence and trust—relational qualities that are lacking in most trafficker-victim relationships, which are characterized by uncertainty and fear. Vertical case prosecution also helps victims regain self-confidence, which in turn can enhance their willingness to cooperate. As a case moves forward, trafficking victims are able to express their feelings about what they have endured, often for the first time. Most victims will find it easier to open up when they are working with a consistent set of trained professionals. This team building also results in victims’ acquiring faith in the criminal justice system itself, which can empower them to become survivors and role models for other victims.

In San Diego County, I had the honor to pioneer one of the first sex crimes and human trafficking specialized units in the nation and learned many of the best practices shared here from that firsthand experience and from learning from and sharing with other federal and state prosecutor offices. We learned to prioritize cases that don’t match any of the media stereotypes, like this case:

A trained nurse and loving mother suffered through these psychological kidnap tactics when her daughter became the target. Cathy did not worry when she saw the changes in her 15-year-old daughter until she went missing one morning. Mom tracked her Facebook and saw that an older Romeo had been seducing her daughter for months. He promised a life of love in Las Vegas but not before she could make a little money “just this one time” so that they can rent a nice place. The rest of the story is familiar except this tenacious mom insisted to police that this was more than another runaway but that her daughter was in danger of being trafficked. Police rescued the victim and took her for a Sexual Assault Response Team examination that added to the evidence against the trafficker. Victim had been using an iPod to communicate with the suspect and Cellbrite analysis recovered over 4,000 text messages.

We learned to look beyond the stereotype victims from the film Taken, which is about a young kidnapping victim who was taken to be a sex slave in a foreign country. Pretty Woman is another mythical portrayal of prostitution with a glamorous ending. In the real world, many prostitution circumstances begin with a 16-year-old runaway who is escaping sex abuse at home only to be lured by a trafficker offering to be a father figure. The trafficker offers protection so long as the girl meets her daily quota of $1,000 per night. If she doesn’t, she’s threatened, starved, and abused. Although cisgender girls tend to be the typical example of human trafficking victims, boys, homosexuals, and transgender youth are also exploited.

We learned what human trafficking really looks like in our region by supporting a local landmark study. We tapped into the research-rich environment of our universities to get to the truth. The National Institute of Justice funded a $500,000 study called “The Nature and Extent of Gang Involvement in Sex Trafficking in San Diego County,” which showed us that:

• There are about 3,417 to 8,108 trafficking victims per year.
• The average age of entry is 16.
• About 80 percent of victims are U.S. citizens.
• About 90 percent of the high schools in the study had documented cases of their students as victims.
• Homeless and foster youth are at the greatest risk for recruitment.
• About 85 percent of trafficking is controlled by gangs.

We learned the despicable role of demand and heartless buyers—mostly men able to pay to buy flesh as if it’s a slice of pizza, which translates into a 14-year-old child in a hotel room with a 42-year-old man who paid a pimp $250 to sexually abuse the girl. For too many people, paying to have sex with a 14-year-old child is despicably seen as a consensual sexual encounter instead of child molestation. Unfortunately, this scenario repeats itself every day throughout San Diego County and the country. Only a few things change—the ages of the victims and the name of the hotel, motel, or casino.

Using Victim Advocates

Courts often permit victim advocates to accompany victims to court proceedings and remain in the courtroom for support during testimony. Advocates add value to human trafficking cases due to their unique role in the process. Human trafficking victims often present with a wide range of needs and concerns, including legal, physical, emotional, and financial issues. Trained prosecutors are skilled at working through the legal issues involved but must enlist the services of experienced victim advocates to assist with victim nonlegal needs and concerns.

In addition, many victims require immediate attention, which can include medical treatment, psychological counseling, and necessities such as food and shelter. Victim advocates can assist with providing these services immediately, once an investigation is underway. Addressing a victim’s basic and immediate needs at the beginning of a case will build victim trust in the prosecution team as well as the criminal justice system, which will promote victim cooperation.

Cultural Competence

Human trafficking victims come from many different cultures, bringing different experiences and cultural practices. Even if they grew up in the United States, many have been sheltered or literally confined for most of their lives, immersed in a cultural lifestyle that is very different from our own. Many do not speak English.

Some populations are vulnerable to becoming victims of human trafficking for a variety of reasons. High-profile trafficking prosecutions have publicly recognized this reality, such as the Jeffrey Epstein case where the indictment actually included the information that several of the victims were vulnerable to exploitation.¹⁴ Some are vulnerable due to mental illness, homelessness, drug addiction, or immigration status. Other vulnerable populations include individuals who are lesbian, gay, bisexual, transgender, queer, or questioning (LGBTQ), or under the age of 18—which raises a host of other issues, both practical and legal. From maturity to educational and occupational stage in life, minor victims require an entirely different skillset than adults.

Judges are in the best position to set the tone for addressing the parties in the courtroom. Because words matter, judges can require the parties to refer to both defendants and victims using words that distinguish persons from behavior. Victims who have been charged with prostitution can be referred to as “persons engaged in prostitution,” not as “prostitutes.” Similarly, defendants charged with engaging in criminal behavior should not be identified using derogatory labels. Unfortunately, in the area of human trafficking, there are hybrid situations where an individual is both a victim and a perpetrator, so a deeper understanding of the issues is critical to the administration of justice.

Trial Issues and Courtroom Strategies

Human trafficking cases require unique investigative techniques due not only to the sensitive nature of the subject matter, but also the technology involved in modern trafficking activity. Investigation techniques include modern methods of evidence collection designed to detect and monitor trafficking activity both online and offline that are effective as well as ethical. Judicial proficiency regarding the most recent case law governing the admissibility of electronic evidence permits judges to make timely, informed evidentiary rulings within this rapidly evolving field of law.

In addition, with the existence of modern specialty courts, when parties arrested in human trafficking investigation cases are brought to court, they face options. Drug court, domestic violence court, veterans court, and courts dealing with mental health or substance abuse issues are often in the best position to address issues underlying the criminality with an eye toward rehabilitation. The ABA Model Code of Judicial Conduct Application section recognizes these types of “problem solving” courts in Comment [3], noting that in many jurisdictions that have them, judges are “authorized by court rules to act in nontraditional ways.”

In addition, courts that have a deeper understanding of how the threat of violence, duress, and other emotional dynamics which complicate relational attachments in human trafficking cases are in the best position to consider requests for restraining orders and other methods of protecting the community.

Voir Dire

Most jurors are totally unfamiliar with human trafficking, only having been exposed to the stereotypes. Judges should consider broadening the scope of voir dire to explore how jurors might hold preconceived notions about trafficking victims and trafficking activity that might compromise their ability to judge the case fairly and impartially.

In permitting voir dire questions, judges should also consider the fact that most jurors will be completely unfamiliar with the relationship dynamics between traffickers and victims. This is particularly true when victims remain loyal and emotionally tied to the traffickers. Similar to domestic violence cases, trauma bonding and recantation are common and thus are issues that need to be explored with prospective jurors.

Testimony and Self-Incrimination

One of the hallmarks of human trafficking cases is the fact that the victim has been forced to illegally perform sex work. In addition to constituting a basis for refusing to testify or being reluctant to cooperate with law enforcement, trafficking activity brings up the issue of when it might be appropriate for a court to consider advising witnesses of their rights against self-incrimination.

In a trafficking case, although the victim’s illegal activity was performed under duress, there may be other witnesses involved in the case the prosecutor wants to call, for which such a defense would not lie. In this circumstance, judges want to be familiar with ABA Criminal Justice Standards, which may be instructive.

The ABA Criminal Justice Standards for the Prosecution provide guidance regarding the interaction between prosecutors and witnesses. Standard 3-3.4 advises in paragraph (g):

The prosecutor should advise a witness who is to be interviewed of his or her rights against self-incrimination and the right to independent counsel when the law so requires. Even if the law does not require it, a prosecutor should consider so advising a witness if the prosecutor reasonably believes the witness may provide self-incriminating information and the witness appears not to know his or her rights. However, a prosecutor should not so advise, or discuss or exaggerate the potential criminal liability of, a witness with a purpose, or in a manner likely, to intimidate the witness, to influence the truthfulness or completeness of the witness’s testimony, or to change the witness’s decision about whether to provide information.

This standard also covers the situation where the defense attorney seeks to interview the victim between the discovery of the offense and trial. Standard 3-3.4 advises in paragraph (h): “The prosecutor should not discourage or obstruct communication between witnesses and the defense counsel, other than the government’s employees or agents if consistent with applicable ethical rules. The prosecutor should not advise any person, or cause any person to be advised, to decline to provide defense counsel with information which such person has a right to give.”

Subsection (h) goes on to explain, “The prosecutor may, however, fairly and accurately advise witnesses as to the likely consequences of their providing information, but only if done in a manner that does not discourage communication.”

Sentencing

Judges are in the best position to ensure sentences are justified in human trafficking cases because they are able to review the criminal conduct in context, considering all of the surrounding facts and circumstances. Weighing potential factors in mitigation does not automatically absolve defendants who were also victimized and does not render them unaccountable for their behavior. But through understanding the coercive relational dynamics and the history of the parties involved, judges are able to craft sentences that reflect underlying causes of the behavior through having a more accurate portrait of motivations behind the charged conduct.

Vacatur

Judges might consider the fact that, in some cases, it may be appropriate to proactively seek to address the victim’s criminal record, which reflects not their criminality, but victimization. In combination with carefully addressing victim reluctance due to the nature of the activity they were forced to engage in, taking steps to vacate criminal records of victims related to their trafficking builds trust and truly represents a victim-centered approach. There is hardly anything that helps victims regain their sense of humanity, dignity, and freedom like acknowledging their victimization by clearing their criminal records that were a result of their victimization. This allows them to gain lawful employment, or regain custody of their children, along with many other advantages.

Expert Testimony

Judges may consider the admission of expert testimony in human trafficking cases because the vast majority of jurors are not familiar with the reality of human trafficking. Without a frame of reference, they lack a foundation upon which to place the testimony and evidence presented in trial. Accordingly, the use of expert witnesses may be a key part of presenting a human trafficking case to explain the meaning and significance of the language, lingo, and lifestyle. An expert can explain the significance of language and slang that is meaningful in the sex trade but beyond the comprehension of judges and juries.

Community Partners

Judges, by virtue of their important role in the process, can be leaders in promoting community education and crime prevention. Along with prosecutors, criminal defense attorneys, and law enforcement professionals, they can support and participate in local community efforts to proactively combat human trafficking. The 2018 U.S. Department of State Trafficking in Persons Report recognizes that local communities are most affected by human trafficking and also provide the first line of defense.¹⁵

The National Center for State Courts promotes best practices in handling the prosecution of human trafficking in the court system through the judiciary.¹⁶ Emphasizing the importance of both prevention and prosecution, it provides a wealth of resources for handling human trafficking cases, including individual case studies, manuals, and handbooks.

Combatting human trafficking is also a priority for prosecutors’ offices around the nation. In 2015, the Office of the Alameda County (California) District Attorney created the statewide research-based think tank Human Exploitation and Trafficking (H.E.A.T.) Institute designed to end human trafficking in California.

The San Diego District Attorney’s Office has been a national leader in combatting human trafficking, combining the efforts of law enforcement, prosecutors, and community partners in efforts to raise community awareness. This includes engaging hotel and motel staff about how to detect and report suspected human trafficking, as well as a systematic effort to educate school staff, medical professionals, and law enforcement about mandatory reporting laws for child abuse, which include the commercial sexual exploitation of children.

The National Association of Women Judges (NAWJ) in 2010 adopted human trafficking as its worldwide priority issue with consistent and effective efforts such as releasing a key program manual in 2015. In 2020, the NAWJ Human Trafficking Committee co-chaired by Judge Ann Breen-Greco and DA Summer Stephan, working with extraordinary national experts, provided three webinars that included a discussion of the historic inequities in victimization to indigenous persons and other persons of color.

These types of partnerships further the language in Section [1] of the Preamble to the ABA Model Code of Judicial Conduct, recognizing that “the judiciary plays a central role in preserving the principles of justice and the rule of law,” and is also consistent with Section [1]’s reminder that all of the rules contained in the code reflect the precepts that “judges, individually and collectively, must respect and honor the judicial office as a public trust and strive to maintain and enhance confidence in the legal system.”

Conclusion

Presiding over human trafficking cases is a challenging and rewarding task that requires specialized legal knowledge, along with compassion and understanding of the complex interpersonal dynamics between traffickers and victims.

In the continuing efforts to combat the human trafficking pandemic, the cure depends on the tenacity, courage, and collaborative work within our respective communities. The vaccine to the human trafficking pandemic is for us to love justice more than the exploiters and traffickers crave power and money. Understanding all the ways in which human trafficking impacts victims, defendants, and the community at large ensures that justice from the bench translates to safety on the streets.

Endnotes

1. 2017 Human Trafficking Statistics, Human Trafficking Search (Mar. 20, 2018), http://humantraffickingsearch.org/human-trafficking-statistics-2017.

2. Myths, Facts, and Statistics, Polaris, https://polarisproject.org/human-trafficking/facts.

3. Forced Labour, Modern Slavery and Human Trafficking, Int’l Lab. Org., https://www.ilo.org/global/topics/forced-labour/lang--en/index.htm.

4. Human Trafficking FAQs, San Diego Cnty. Dist. Att’y (Sept. 11, 2014), https://www.sdcda.org/preventing/human-trafficking/human-trafficking-faqs#what_is_it.

5. Human Trafficking State Laws, Nat’l Conf. of State Legislatures (NCSL), https://www.ncsl.org/research/civil-and-criminal-justice/human-trafficking-laws.aspx.

6. Caroline Hallemann, Everything We Know So Far About the Case Against Ghislaine Maxwell, Town&Country (Oct. 20, 2020), https://www.townandcountrymag.com/society/money-and-power/a33076249/ghislaine-maxwell-arrest-case-details.

7. NCSL, supra note 5.

8. Id.

9. Id.

10. Christopher Johnson, How Are Human Traffickers Taking Advantage of the Pandemic?, Reuters (Oct. 17, 2020), https://www.reuters.com/article/us-global-trafficking-expertview/how-are-human-traffickers-taking-advantage-of-the-pandemic-idUSKBN27300T.

11. Estimating the Underground Commercial Sex Economy in the U.S., Nat’l Inst. of Just. (Aug. 31, 2016), https://www.nij.gov/topics/crime/human-trafficking/Pages/estimating-underground-commercial-sex-economy.aspx.

12. Amy Farrell & Rebecca Pfeffer, Policing Human Trafficking: Cultural Blinders and Organizational Barriers, 653 Annals of Am. Acad. of Pol. & Soc. Sci. 46 (2014).

13. Id. at 50.

14. Barbara McQuade, The Jeffrey Epstein Case Shows What Sex Trafficking Really Looks Like, The Cut (July 19, 2019), https://www.thecut.com/2019/07/jeffrey-epstein-case-shows-how-sex-trafficking-really-works.html.

15. U.S. Dep’t of State, Trafficking in Persons Report (June 2018), https://2017-2021.state.gov/reports/2018-trafficking-in-persons-report/index.html.

16. Anti-Human Trafficking, Nat’l Ctr. for State Cts., https://www.ncsc.org/Topics/International/Judicial-Reform-Around-the-World/Home/AntiHuman-Trafficking.aspx.