Notes of Decisions
Cited in
1,255
cases (
669 in the last 5 years), 2004–2026 · leading case:
United States v. Robinson, 702 F.3d 22 (2d Cir. 2012).
United States v. Robinson, 702 F.3d 22 (2d Cir. 2012).
· cites it 34× “Defendant-appellant Devon Robinson appeals from the January 26, 2011 judgment of the United States District Court for the Eastern District of New York (John Gleeson, Judge), convicting him, following a jury trial, on two counts of sex trafficking of a minor in violation of 18…”
Noble v. Harvey Weinstein, Robert Weinstein, the Weinstein Co., 335 F. Supp. 3d 504 (S.D. Ill. 2018).
· cites it 25× “Defendants Harvey Weinstein ("Harvey") and Robert Weinstein ("Robert") have moved under Federal Rule of Civil Procedure 12(b)(6) to dismiss the Amended Complaint of plaintiff Kadian Noble ("Noble" or "Plaintiff") alleging violations of the Victims of Trafficking Victims…”
United States v. Abdullahi Afyare, 632 F. App'x 272 (6th Cir. 2016).
· cites it 23× “In this appeal, the government challenges three in limine rulings, arguing that the district court misinterpreted 18 U.S.C. § 1591 (a) and Federal Rule of Evidence 701(c) to improperly exclude certain evidence.”
Geiss v. Weinstein Co. Holdings LLC, 383 F. Supp. 3d 156 (S.D. Ill. 2019).
· cites it 14× “Sex Trafficking Claims Under 18 U.S.C. §§ 1591 , 1595 The TWC Subclass brings claims against H.”
United States v. Todd, 627 F.3d 329 (9th Cir. 2010).
· cites it 22× “OPINION NOONAN, Circuit Judge: Jerome Eugene Todd appeals his conviction of three counts of sex trafficking in violation of 18 U.S.C. § 1591 (a)(1) and one count of conspiracy to engage in sex trafficking in violation of 18 U.”
United States v. Abdullahi Farah, 766 F.3d 599 (6th Cir. 2014).
· cites it 44× “§ 401 (3), for willfully disobeying an order requiring his testimony by deposition for use in a separate criminal prosecution and for violating 18 U.S.C. § 1591 (d), which prohibits the obstruction, or the attempt to obstruct the enforcement of §1591(a), a child sex trafficking…”
United States v. Jermayne Whyte, 928 F.3d 1317 (11th Cir. 2019).
· cites it 10× “WILLIAM PRYOR, Circuit Judge: The main issue presented by this appeal is whether the government may prove sex trafficking of a minor, 18 U.S.C. § 1591 , by establishing only that a defendant had a reasonable opportunity to observe the minor victim instead of proving that he knew…”
G.G. v. Salesforce.com, Inc., 76 F.4th 544 (7th Cir. 2023).
· cites it 7× “18 U.S.C. § 1591 (a) (2015). 3 The referenced chapter is Chapter 77 of Title 18, which also includes criminal prohibitions on peonage, slavery, forced labor, and other forms of human trafficking, so Section 1595 offers a civil remedy for victims of those crimes, as well.”
United States v. Wei Lin, 841 F.3d 823 (9th Cir. 2016).
· cites it 25× “§ 1594 (c), and several counts of sex trafficking, in violation of 18 U.S.C. § 1591 (a). Lin pled guilty to the conspiracy count, which carried no mandatory minimum.”
United States v. Estrada-Tepal, 57 F. Supp. 3d 164 (E.D.N.Y 2014).
· cites it 38× “Currently before the Court is Defendant Ricardo Estrada-Tepal’s (“Defendant”) motion to dismiss all counts brought pursuant to 18 U.S.C. § 1591 on the basis that the law is unconstitutionally overbroad.”
United States v. Raniere, 55 F.4th 354 (2d Cir. 2022).
· cites it 12× “On appeal, Raniere challenges his convictions for sex trafficking crimes, in violation of 18 U.S.C. § 1591 . At the center of his appeal is the meaning of “commercial sex act,” which Section 1591 defines as “any sex act, on account of which anything of value is given to or…”
United States v. Duong, 848 F.3d 928 (10th Cir. 2017).
· cites it 15× “See 18 U.S.C. §§ 1591 , 1594 (2008). 1 The superseding indictment asserted only one basis by which the government would seek to prove mens rea as to the child victim’s 2 age — that Defendants had a reasonable opportunity to observe the child before engaging in a commercial sex…”
United States v. Lavont Flanders, Jr., 752 F.3d 1317 (11th Cir. 2014).
· cites it 8× “Conspiracy Charges (Counts 1 and 13) To prove conspiracy in Counts 1 and 13, the Government had to establish (1) the existence of an agreement between Flanders and Callum to violate 18 U.S.C. § 1591 (a)(1) (sex trafficking by force, fraud, or coercion); (2) Flanders’s knowing…”
United States v. David Pennington, 78 F.4th 955 (6th Cir. 2023).
· cites it 29× “Pennington’s § 1594(c) charge alleged that he participated in a conspiracy to engage in human trafficking in violation of 18 U.S.C. § 1591 (a)(1), 1591(b)(1). The government then charged Pennington with witness tampering, in violation of 18 U.”
United States v. Purcell, 967 F.3d 159 (2d Cir. 2020).
· cites it 9× “§ 371 (Count Four); and sex trafficking by force, fraud, and coercion, in violation of 18 U.S.C. §§ 1591 (a)(1), (a)(2) and 2 (Count Five).”
United States v. Thompson, 896 F.3d 155 (2d Cir. 2018).
· cites it 8× “), Thompson challenges his convictions for violating 18 U.S.C. § 1591 ("Sex trafficking of children or by force, fraud, or coercion") and 18 U.”
United States v. Roach, 896 F.3d 1185 (10th Cir. 2018).
· cites it 8× “into prostitution in violation of 18 U.S.C. § 1591 (a)(1). Mr. Roach recruited D.”
United States v. Marcus, 538 F.3d 97 (2d Cir. 2008).
· cites it 14× “On February 9, 2007, the government filed a superceding indictment, charging Marcus with violating the sex trafficking statute, 18 U.S.C. § 1591 (a)(1), [2] and the forced labor statute, 18 U.”
United States v. Brooks, 610 F.3d 1186 (9th Cir. 2010).
· cites it 7× “A federal grand jury returned a superseding indictment against Brooks, Fields, and Fonteneaux, charging each of them with two counts of child sex trafficking, 18 U.S.C. §§ 1591 (a) & 2, and two counts of interstate transportation of minors for purposes of prostitution, 18 U.”
United States v. Deion Lockhart, 844 F.3d 501 (5th Cir. 2016).
· cites it 7× “Finding that the district court’s jury instructions regarding 18 U.S.C. § 1591 (Sex Trafficking of Children) constructively amended the indictment, we VACATE and REMAND Appellant McCullouch’s conviction as to that count.”
Demond L. Osley v. United States, 751 F.3d 1214 (11th Cir. 2014).
· cites it 7× “We granted a certificate of appealability concerning whether Osley’s trial counsel was ineffective for failing to advise him during plea negotiations that a violation of 18 U.S.C. § 1591 (b) carried a statutory mandatory minimum sentence as well as a potential life term of…”
United States v. James Mozie, 752 F.3d 1271 (11th Cir. 2014).
· cites it 9× “§ 1594 (c), eight counts of child sex trafficking in violation of 18 U.S.C. § 1591 (a), and one count of producing child pornography in violation of 18 U.”
United States v. Antonio Rivera, 799 F.3d 180 (2d Cir. 2015).
· cites it 10× “2012) (“[Defendants] wanted to suggest that having already been a prostitute she would not have been deceived by [Defendant] and therefore her testimony that she was coerced into working for him—an element of one of the charged offenses when the prostitute is not a minor, 18…”
United States v. Dontavious M. Blake, 868 F.3d 960 (11th Cir. 2017).
· cites it 6× “After the execution of those four warrants, a third superseding indictment charged Blake and Moore with six violations of 18 U.S.C. § 1591 : substantive child sex trafficking of T.”
United States v. Willie Mickey, 897 F.3d 1173 (9th Cir. 2018).
· cites it 11× “MICKEY SUMMARY ** Criminal Law The panel affirmed convictions for two counts of sex trafficking by force, threats of force, fraud, or coercion in violation of 18 U.S.C. §§ 1591 (a) and (b)(1). The panel held that the district court did not err by refusing to give a specific…”
Ditullio v. Boehm, 662 F.3d 1091 (9th Cir. 2011).
· cites it 8× “18 U.S.C. § 1591 (a). In 2003, Congress reauthorized appropriations for the TVPA and amended it in order to "enhanc[e] provisions on prevention of trafficking, protection of victims of trafficking, and prosecution of traffickers.”
United States v. McKenzie Carson, 870 F.3d 584 (7th Cir. 2017).
· cites it 5× “18 U.S.C. § 1591 (a). The government charged Carson with trafficking Fratto under both the coercion and age provisions.”
United States v. Beleal Garcia-Gonzalez, 714 F.3d 306 (5th Cir. 2013).
· cites it 6× “Garcia was charged with three counts of child sex trafficking, in violation of 18 U.S.C. § 1591 (a)(1), one count of conspiring to harbor illegal aliens, in violation of 8 U.”
United States v. Michael Maynes, Jr., 880 F.3d 110 (4th Cir. 2018).
· cites it 5× “*112 WILKINSON, Circuit Judge: Michael Maynes raises various assignments of error arising from his trial and convictions for four counts of sex trafficking by use of force, fraud, or coercion in violation- of 18 U.S.C. § 1591 (a) and one count of conspiracy to commit sex…”
United States v. Justin Evans, 476 F.3d 1176 (11th Cir. 2007).
· cites it 7× “BOWMAN, Circuit Judge: Justin Evans appeals his convictions for enticing a minor to engage in a commercial sex act in violation of 18 U.S.C. § 1591 (a)(1), and enticing a minor to engage in prostitution in violation of 18 U.”
United States v. Tynisha Hornbuckle, 784 F.3d 549 (9th Cir. 2015).
· cites it 12× “OPINION CHRISTEN, Circuit Judge: Tynisha and Tamrell Hornbuckle are sisters who each pleaded guilty to two counts of sex trafficking of children under *551 18 U.S.C. § 1591 . They challenge their sentences in these consolidated appeals.”
United States v. Laron Carter, 907 F.3d 1199 (9th Cir. 2018).
· cites it 4× “CARTER SUMMARY** Criminal Law The panel vacated the defendant’s convictions on one count of violating 18 U.S.C. § 1591 (sex trafficking of a minor or by force, fraud, or coercion) and one count of violating 18 U.”
United States v. Jeremy Mack, 808 F.3d 1074 (6th Cir. 2015).
· cites it 7× “or in reckless disregard of the fact, that means of force, threats of force, fraud, coercion .”
United States v. Anthony Donte Collier, 932 F.3d 1067 (8th Cir. 2019).
· cites it 8× “Anthony Donte Collier was convicted in the district court 1 of five counts of sex trafficking and attempted sex trafficking, in violation of 18 U.S.C. §§ 1591 (a)(1), 1591(b)(1), and 1594(a) ; and one count of conspiracy to commit an offense against the United States,…”
United States v. Raniere, 384 F. Supp. 3d 282 (E.D.N.Y 2019).
· cites it 15× “¶ 45 ); and sex trafficking offenses, in violation of provisions of 18 U.S.C. § 1591 ("Count Eight," "Count Nine," and "Count Ten") ( id.”
United States v. Raymond Valas, III, 822 F.3d 228 (5th Cir. 2016).
· cites it 5× “HIGGINSON, Circuit Judge: A jury convicted Raymond Valas of engaging in a commercial sex act with a minor in violation of 18 U.S.C. § 1591 . Valas argues on appeal that the district court improperly instructed his jury on § 1591’s scienter requirement.”
United States v. Irey, 612 F.3d 1160 (11th Cir. 2010).
· cites it 2× “1 covers three crimes: 18 U.S.C. §§ 1591 (sex trafficking of children), 2251 (sexual exploitation of children), and 2260 (production of child pornography for importation to the United States).”
United States v. Malcom Copeland, 820 F.3d 809 (5th Cir. 2016).
· cites it 6× “HIGGINSON, Circuit Judge: A jury convicted Malcom Deandre Copeland 1 of sex trafficking of children in violation of 18 U.S.C. § 1591 . The questions on appeal are (1) whether the statute imposes “strict liability” on the defendant regarding the victim’s age, and (2) if so, does…”
United States v. Johnelle Bell, 761 F.3d 900 (8th Cir. 2014).
· cites it 7× “18 U.S.C. § 1591 (a) (emphasis added). “Coercion” is further defined as “threats of serious harm to or physical restraint against any person,” “any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or…”
United States v. Maurice Smith, 719 F.3d 1120 (9th Cir. 2013).
· cites it 7× “OPINION IKUTA, Circuit Judge: Maurice Lerome Smith appeals several sentencing enhancements that he received in connection with his conviction for sex trafficking of children by force, fraud, or coercion under 18 U.S.C. § 1591 (a) and (b)(1). We affirm.”
United States v. Anthony, 942 F.3d 955 (10th Cir. 2019).
· cites it 5× “But neither section under which Anthony was convicted—18 U.S.C. §§ 1591(a)(1) and 1594(c)—falls within the categories of crimes for which the MVRA mandates restitution.”
United States v. Omar Taylor, 44 F.4th 779 (8th Cir. 2022).
· cites it 16× “” 18 U.S.C § 1591(e)(3). Congress’s use of the term “any” prior to the term “sex act” is noteworthy.”
United States v. Willoughby, 144 F. Supp. 3d 935 (N.D. Ohio 2015).
· cites it 5× “1 at 2), whereas this Court’s Order denying Wil-loughby’s request for a Bill of Particulars listed the charge as a violation of “18 U.S.C. § 1591(a)(1) and (b)(1) and (2)” (Doc.”
United States v. Taylor Jordan Wardlow, 666 F. App'x 861 (11th Cir. 2016).
· cites it 3× “This statement was consistent with the sex trafficking statute—18 U.S.C. § 1591(a)— under which Wardlow was charged.”
United States v. Cordero-Rosario, 252 F. Supp. 3d 79 (D.P.R. 2017).
“While the admissibility issue was pending before the Court, the government, on July 7, 2016, a federal grand jury returned a Second Superseding Indictment charging the defendant with one count of Sex Trafficking of a Minor, in violation of 18 18 U.S.C.§ 1591(a), and one count of…”
United States v. Martavious Keys (5th Cir. 2018).
· cites it 14× “See 18 U.S.C.§ 1591(b)(1), (2). At sentencing, the district court stated: “I’m going to sentence at the Guideline range and sentence the Defendant to life in prison.”
Jane Doe (J.N.K.) v. Red Roof Inns, Inc. (S.D. Ohio 2025).
· cites it 6× “violated 18 U.S.C §1591(a)(1) when, through the acts and omissions described throughout this Complaint, they harbored individuals (including Jane Doe (J.”
Folks (D. Vt. 2025).
· cites it 6×
Borys (D. Utah 2026).
· cites it 6×
T. (D. Nev. 2025).
· cites it 5×
Young (N.D. Ill. 2025).
· cites it 5×
S.g (E.D. Va. 2025).
· cites it 5×
United States v. Darryl Odely, Jr. (11th Cir. 2025).
· cites it 4× “Odely argues that (1) the indictment, the jury instructions, and the special verdict form all misstated the requisite mens rea, and the special verdict form did not track the specific statutory language of the force provision in 18 U.S.C. § 1591(c), and therefore (a) he was…”
C. (D. Nev. 2025).
· cites it 4×
Justis (D. Maryland 2026).
· cites it 4×
Sarah (W.D. Wash. 2026).
· cites it 4×
Birdo (S.D. Ill. 2025).
· cites it 3×
A.B. (D. Or. 2025).
· cites it 3×
United States v. Semaj Gilmore (3rd Cir. 2025).
· cites it 3× “§ 1591 (a)’s penalty provision—18 U.S.C. § 1591(b)(2)—but the Superseding Indictment charged him with only the substantive offense and did not reference the penalty provision.”
United States v. Travis Thomas (7th Cir. 2025).
· cites it 3× “Background A federal grand jury indicted Thomas in 2019 on one count of sex trafficking by force, threats of force, fraud, or coercion, in violation of 18 U.S.C. § 1591(a) and (b)(1); two counts of transporting a victim in interstate commerce with the intent that she engage in…”
Keller (D. Utah 2026).
· cites it 3×
Childs (E.D. Wis. 2025).
· cites it 2×
Doe (D. Mass. 2025).
· cites it 2×
Tripp (D. Conn. 2026).
· cites it 2×
Carter (S.D. Ill. 2026).
· cites it 2×
Crist (W.D. Okla. 2026).
· cites it 2×
Acy (N.D. Tex. 2026).
· cites it 2×
— 18 U.S.C. § 1591(a) — 14 cases
United States v. Wei Lin, 841 F.3d 823 (9th Cir. 2016).
“§ 1594 (c), and several counts of sex trafficking, in violation of 18 U.S.C. § 1591 (a). Lin pled guilty to the conspiracy count, which carried no mandatory minimum.”
United States v. Taylor Jordan Wardlow, 666 F. App'x 861 (11th Cir. 2016).
“This statement was consistent with the sex trafficking statute—18 U.S.C. § 1591(a)— under which Wardlow was charged.”
United States v. Cordero-Rosario, 252 F. Supp. 3d 79 (D.P.R. 2017).
“While the admissibility issue was pending before the Court, the government, on July 7, 2016, a federal grand jury returned a Second Superseding Indictment charging the defendant with one count of Sex Trafficking of a Minor, in violation of 18 18 U.S.C.§ 1591(a), and one count of…”
United States v. Travis Thomas (7th Cir. 2025).
“Background A federal grand jury indicted Thomas in 2019 on one count of sex trafficking by force, threats of force, fraud, or coercion, in violation of 18 U.S.C. § 1591(a) and (b)(1); two counts of transporting a victim in interstate commerce with the intent that she engage in…”
United States v. Darryl Odely, Jr. (11th Cir. 2025).
“Odely argues that (1) the indictment, the jury instructions, and the special verdict form all misstated the requisite mens rea, and the special verdict form did not track the specific statutory language of the force provision in 18 U.S.C. § 1591(c), and therefore (a) he was…”
— 18 U.S.C. § 1591(a)(1) — 7 cases
United States v. Anthony, 942 F.3d 955 (10th Cir. 2019).
“But neither section under which Anthony was convicted—18 U.S.C. §§ 1591(a)(1) and 1594(c)—falls within the categories of crimes for which the MVRA mandates restitution.”
United States v. Willoughby, 144 F. Supp. 3d 935 (N.D. Ohio 2015).
“1 at 2), whereas this Court’s Order denying Wil-loughby’s request for a Bill of Particulars listed the charge as a violation of “18 U.S.C. § 1591(a)(1) and (b)(1) and (2)” (Doc.”
Jane Doe (J.N.K.) v. Red Roof Inns, Inc. (S.D. Ohio 2025).
“violated 18 U.S.C §1591(a)(1) when, through the acts and omissions described throughout this Complaint, they harbored individuals (including Jane Doe (J.”
— 18 U.S.C. § 1591(b)(1) — 1 case
United States v. Martavious Keys (5th Cir. 2018).
“See 18 U.S.C.§ 1591(b)(1), (2). At sentencing, the district court stated: “I’m going to sentence at the Guideline range and sentence the Defendant to life in prison.”
— 18 U.S.C. § 1591(b)(2) — 1 case
United States v. Semaj Gilmore (3rd Cir. 2025).
“§ 1591 (a)’s penalty provision—18 U.S.C. § 1591(b)(2)—but the Superseding Indictment charged him with only the substantive offense and did not reference the penalty provision.”
— 18 U.S.C. § 1591(c) — 1 case
United States v. Darryl Odely, Jr. (11th Cir. 2025).
“Odely argues that (1) the indictment, the jury instructions, and the special verdict form all misstated the requisite mens rea, and the special verdict form did not track the specific statutory language of the force provision in 18 U.S.C. § 1591(c), and therefore (a) he was…”
— 18 U.S.C. § 1591(d) — 1 case
United States v. Abdullahi Farah, 766 F.3d 599 (6th Cir. 2014).
“§ 401 (3), for willfully disobeying an order requiring his testimony by deposition for use in a separate criminal prosecution and for violating 18 U.S.C. § 1591 (d), which prohibits the obstruction, or the attempt to obstruct the enforcement of §1591(a), a child sex trafficking…”
— 18 U.S.C. § 1591(e)(3) — 1 case
United States v. Omar Taylor, 44 F.4th 779 (8th Cir. 2022).
“” 18 U.S.C § 1591(e)(3). Congress’s use of the term “any” prior to the term “sex act” is noteworthy.”
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