United States v. Law, No. 19-2345 (7th Cir. 2021)
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Law operated three Indiana massage spas that offered sex services. HV and XC were Law’s “employees.” HV was born in Vietnam, knew limited English, and knew no one else in this country. XC traveled from China to Chicago with few personal contacts, almost no money, and knowing little English, believing she would be providing non-sexual massages. HV testified she serviced six to nine men over a 15-hour workday. Law prevented the women from leaving the spa unaccompanied, declined to pay them hourly wages, provided only one meal each day, confiscated their passports, and monitored their activities using security cameras. Law did nothing in response to XC enduring violent treatment by a spa customer and forced HV to work hours after suffering a miscarriage. From information obtained in interviews of HV and XC after a sting operation, Hong Kong authorities arrested Law.
The Seventh Circuit affirmed her convictions for trafficking XC and HV for involuntary servitude, 18 U.S.C. 1590(a) and 18 U.S.C. 2; transporting XC for the purpose of prostitution, 18 U.S.C. 2421 and 18 U.S.C. 2; and using an interstate facility to promote prostitution, 18 U.S.C. 1952(a)(3) and 18 U.S.C. 2, and her 360-month sentence. The court rejected hearsay arguments concerning the testimony of agents at Law’s trial, noting the judge’s limiting instruction, and upheld the admission of an affidavit signed by Law.
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