United States v. Rita Law


In the United States Court of Appeals For the Seventh Circuit ____________________ No. 19-2345 UNITED STATES OF AMERICA, Plaintiff-Appellee, v. RITA LAW, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Indiana, Hammond Division. No. 2:14-cr-00004 — Joseph S. Van Bokkelen, Judge. ____________________ SUBMITTED OCTOBER 28, 2020 — DECIDED MARCH 11, 2021 ____________________ Before RIPPLE, WOOD, and BRENNAN, Circuit Judges. BRENNAN, Circuit Judge. A jury convicted Rita Law of sex trafficking which the district court described as “a modern- day form of slavery.” On appeal, Law challenges several evi- dentiary rulings at trial, the sufficiency of the evidence for her convictions, and her sentence of 360 months’ imprisonment. We find no errors by the district court, so we affirm. 2 No. 19-2345 I. Background Rita Law owned and operated three massage spas which also offered sex services to customers in northwest Indiana.1 HV and XC were two of Law’s “employees” providing these services to clients. 2 HV was born in Vietnam, where she met Law in 2004. Soon after their meeting, Law introduced HV to Gary Toma and encouraged them to marry. HV did not know at the time that Toma was not only Law’s friend but also a customer at Law’s Duneland spa. Without this knowledge, HV agreed to marry Toma. Their engagement allowed her to obtain a fiancée visa to come to the United States. By the time HV arrived in Chicago, she was pregnant with Toma’s child, spoke limited English, and knew no one else. Law met and drove HV to one of her spas in Indiana. Once at the spa, she forced HV to provide sex services to customers. Law did so in part by claiming Toma owed her a debt and that HV would have to work at the spa to repay it. Like HV, XC was living abroad when she first heard about Law. A friend told XC that she could make $25 to $30 an hour working for Law in the United States. So XC traveled from China to Chicago with few personal contacts, almost no money, and knowing little English. When XC first arrived at one of Law’s spas, she thought she would be providing 1 We present the facts from the record in the light most favorable to the government. United States v. Wilson, 879 F.3d 795, 798 n. 1 (7th Cir. 2018). 2 We continue the district court’s practice of identifying the victims by their initials. No. 19-2345 3 nonsexual massages. But Law soon bullied XC into providing sex services and demanded money for room and board. Law intimidated HV and XC into working at the spas un- der brutal conditions. At trial, HV testified she serviced six to nine men over a fifteen-hour workday. Law prevented the women from leaving the spa unaccompanied, declined to pay them hourly wages, and provided only one meal each day. To maintain control over HV and XC, Law confiscated their pass- ports and monitored their activities by observing …

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