The federal policy and legislation covering domestic minor
trafficking is comprehensive. It imposes harsh penalties on traffickers
while maintaining a victim-centered approach to the problem. The
effectiveness of the federal legislative framework is best illustrated
through successful prosecutions invoking the aforementioned laws.
B. Successful prosecution under the TVPA
Between 2011 and 2012, the U.S. Department of Justice
charged 120 defendants in human trafficking cases.84 This represents
a record-high number of cases in recent years.85 The TVPA is vital to
the continued prosecution of traffickers and the protection of victims.
Two district court cases, United States v. Robinson86 and United
States v. Evans,87 are examples of successful prosecutions of
domestic child sex traffickers under the TVPA. These cases provide
significant facts and circumstances surrounding issues that include
intrastate applicability of the TVPA, mistake of age as no defense to
domestic minor sex trafficking, and the gravity of sex trafficking
offenses. In addition, these cases assist in understanding the
complexity of domestic minor sex trafficking.
1. United States v. Robinson
Devon “Da-Da” Robinson (“Robinson”) was indicted on
three counts of child sex trafficking under U.S. Code Section 1591.
Only two of these counts proceeded to trial, both related to one child
victim who was not named during the trial to protect her
anonymity.88 The child, Jane Doe, was a runaway in her early teens
and had also dropped out of high school.89 Jane Doe was seventeen
years old when she met Robinson.90 After becoming involved with
Robinson, Jane Doe was arrested “several times for and convicted of
84 U.S. Attorney’s Office, FBI and Yale Law School Host Human Trafficking
Symposium, U.S. ATTORNEY’S OFF.–DISTRICT CONN. (Apr. 12, 2012),
86 United States v. Robinson, 702 F.3d 22 (2d Cir. 2012).
87 See United States v. Evans, 476 F.3d 1176 (11th Cir. 2007).
88 See Schwartz, supra note 58, at 268 n.163 (explaining that “under the TVPA, the
federal government is able to conceal the [victims’] identities . . ..”).
89 See Robinson, 702 F.3d at 27.