rating methodology,126 and in 2011, Shared Hope International gave
Washington state, along with four other states, an overall grade of
“B.”127 Under the Shared Hope International grading methodology,
no state has received an “A” to date.128 Accordingly, where New
York law fails to meet the standards set forth by Shared Hope
International and the Polaris Project, Washington state law should be
applied as a gap-filler.
A. The New York policy landscape
New York has numerous legal provisions to protect the
victims of domestic minor sex trafficking.129 In 2006, Mayor
Bloomberg established an interagency Human Trafficking Task
Force.130 The Task Force coordinates the work of various agencies
and reports on issues, including the status of human trafficking in the
state, the availability of victim assistance programs, and “the
progress of the state in preventing trafficking, protecting and
providing assistance to victims of trafficking, and prosecuting
persons engaged in trafficking.”131
In 2007, New York enacted the New York State Trafficking
Act132 (“NY Trafficking Act”). The NY Trafficking Act was the first
legislation in the state to define sex and labor trafficking as crimes
within the New York Penal Code.133 Additionally, New York
maintains the New York’s Safe Harbor for Exploited Children Act
126 Majority of States Actively Passing Laws to Combat Human Trafficking, supra
127 PROTECTED INNOCENCE CHALLENGE, supra note 5, at 11.
129 ELIZABETH G. HINES & JOAN HOCHMAN, THE N. Y. WOMEN’S FOUND., SEX
TRAFFICKING OF MINORS IN NEW YORK: INCREASING PREVENTION AND
COLLECTIVE ACTION 17 (2012), http://www.nywf.org/wp-
130 N. Y. SOC. SERV. LAW § 483-ee (McKinney 2013).
131 N. Y. SOC. SERV. LAW § 483-ee(b)(1)-(7), (c); see also HINES & HOCHMAN,
supra note 129, at 18 (describing the New York Human Trafficking Task Force).
132 N. Y. PENAL LAW § 230.34 (McKinney 2013). Because this Article is focused on
the issue of sex trafficking, the New York labor trafficking statutory provision will
not be discussed.