A northern Indiana woman convicted of sex trafficking in a case a federal court called “a modern form of slavery” lost an appeal of her conviction 30-year sentence Thursday.
Rita Law operated three massage parlors in northwestern Indiana that offered sexual services to customers, including the since-closed Duneland Spa in Gary. Law enticed a Vietnamese woman, H.V., to marry her friend Gary Toma, who H.V. didn’t know was also a Duneland customer. After married Toma, she came to Chicago and was was forced into prostitution, according to the record.
A Chinese woman, X.C., came to the country after a friend told her she could make $25 to $30 an hour working for Law. “But Law soon bullied XC into providing sex services and demanded money for room and board,” as she had with H.V., Judge Michael Brennan wrote for the 7th Circuit Court of Appeals.
“Law intimidated HV and XC into working at the spas under brutal conditions,” Brennan wrote. “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 passports and monitored their activities by observing them using security cameras installed throughout the spas. Law also exerted psychological control over the women by falsely claiming they would be arrested if they were discovered and by physically intimidating them. For example, one time after XC and Law argued, Law did nothing in response to XC enduring violent treatment by a spa customer during a sex act. Another example of Law’s cruelty is when HV called Law and told her she was experiencing severe bleeding and feared a miscarriage, Law did nothing and told her to return to bed. The next day when a doctor confirmed the miscarriage and suggested HV rest, Law forced her back to work at the spa that afternoon.”
After a human trafficking investigation, Law was charged with and ultimately convicted of one count each of trafficking XC and HV for involuntary servitude, one count of transporting XC for the purpose of prostitution, and one count of using an interstate facility to promote prostitution. Her sentence of 30 years fell well below the guidelines of range of life imprisonment.
The 7th Circuit rejected her appeal challenging the Northern District of Indiana’s rulings concerning the admission of evidence and its sufficiency in USA v. Rita Law, 19-2345.
The panel found Law’s “most prominent” argument concerned the admission of hearsay evidence from Homeland Security agents concerning statements others made to them during interviews with the victims. However, the district court gave a proper limiting instruction to jurors and found “any error in admitting this evidence was likely harmless because of its cumulative nature” to the testimony of the victims themselves, which was sufficient to support the convictions.
Turning to Law’s 360-month sentence, the 7th Circuit found an enhancement for obstruction of justice was proper because she supplied an affidavit that “claimed her businesses were not engaged in prostitution and that she instructed her workers not to engage in prostitution. Overwhelming trial evidence contradicts these statements.”
“The district court did not abuse its discretion in imposing Law’s 360-month sentence. Law faced an uphill battle because a below-Guidelines sentence is entitled to the presumption of reasonableness,” Brennan wrote. “… The court determined that Law had engaged in a ‘modern-day form of slavery,’ but it reduced the sentence when considering all the other factors and the parties. Given these circumstances, including the much higher Guidelines range that could have applied, the district court pronounced a reasonable sentence for Law.”