Case Law Database

Trafficking in persons

United States v. Theresa Mubang

Fact Summary

The defendant Mubang, a naturalized US citizen, originally from Cameroon, kept a minor girl from Cameroon in involuntary servitude for approximately 2 years. The defendant took the girl from her parents in Cameroon, promising them that the girl, E.C., would receive an American education, and would lead a better life than in Cameroon. She then transported the girl through London using a false passport for E.C.. Once at the defendant's home in Greenbelt, Maryland, E.C. was forced to serve as a nanny to the defendant's sons, was required to cook and clean, and was isolated from the Maryland community, and never allowed to speak with her family back in Cameroon. E.C. slept on the floor and cared for the children around-the-clock. Mubang prohibited her from opening the door of the house, or from leaving the house for any reason other than the completion of specific household tasks. E.C. was never sent to school or allowed to communicate with children her age. Mubang subjected E.C. to continued verbal and physical abuse, often beating her with belts and high-heel-shoes to the extent that the girl would start bleeding, or the girl's skull would ooze fluids from the hits with the high-heel shoe. E.C. escaped from the house while Mubang was at a weekend conference. Notably, about a year prior to E.C.'s enslavement, the defendant had similarly enslaved another young girl from Cameroon. However, she had sent her back to Cameroon, because the girl had started calling the police.  Additionally, after E.C. escaped, Mubang brought over another girl from Cameroon, enslaving her as well. That victim managed to escape as well.

Mubang fled the United States after she was convicted before sentencing took place. She was sentenced to 17.5 years in prison in absentia. In May, 2005, she was caught in Cameroon and sent back to the United States to serve her sentence.

Sentence Date:
2005-02-28
Author:
Human Trafficking Database of the University of Michigan Law School

Keywords

Trafficking in Persons Protocol:
Article 5, Trafficking in Persons Protocol
Acts:
Recruitment
Transportation
Harbouring
Means:
Threat or use of force or other forms of coercion
Abuse of power or a position of vulnerability
Purpose of Exploitation:
Forced labour or services
Servitude

Cross-Cutting Issues

Gender Equality Considerations

Details

• Female principal offender

Procedural Information

Legal System:
Common Law
Latest Court Ruling:
Court of 1st Instance
Type of Proceeding:
Criminal
 

Victims / Plaintiffs in the first instance

Victim:
E.C.
Gender:
Child
Nationality:
Cameroonian
Victim:
2 additional anonymous
Gender:
Child
Nationality:
Cameroonian

Defendants / Respondents in the first instance

Defendant:
Theresa Mubang
Gender:
Female
Legal Reasoning:

On February 28, 2005, Mubang was sentenced in absentia to concurrent terms of 210 months of imprisonment (on count one), and 120 months of imprisonment (on count two), along with three years of supervised release.

Charges / Claims / Decisions

Defendant:
Theresa Mubang
Legislation / Statute / Code:
18 U.S.C. 1584
Charge details:
Involuntary servitude
Verdict:
Guilty
Charge details:
Harboring an illegal alien for financial gain
Verdict:
Guilty
Term of Imprisonment:
17 years 6 Months
With an additional 3 years of supervised release
Compensation / Payment to Victim:
Yes  100000  USD  (50,000-100,000 USD)
Restitution
Fine / Payment to State:
Yes  200  USD  (Up to 10,000 USD) Special assessment
Appellate Decision:

Mubang’s counsel filed a notice of appeal to the United States Court of Appeals for the Fourth Circuit two days after the judgment against Mubang had been entered. In April 2005, the fourth circuit denied the motion to stay, and dismissed the appeal, but granted Mubang leave to file an appeal, as long as Mubang surrendered herself to federal custody within 30 days. Mubang did not do so. On November 21, 2005, the fourth circuit denied the defendant’s motion to reinstate the case.

Court

United States District Court for the District of Maryland