The defendants, Waquita Wallace and April Chaney, are sisters who lived together in St. Louis. In June 2008, Wallace and Chaney went to the victim’s counsin’s apartment and observed the victim, an 18-year-old woman with mental disabilities, there. Wallace persuaded to victim to move in with them, by telling her that she would help her get her babies back and would take care of her. However, once the two defendants and the victim got back to Wallace and Chaney's house, Wallace told the victim that the victim’s cousin owed Wallace money, that the cousin’s debt was now the victim’s debt, and that she would have to pay it back by giving up her monthly social security disability check. Wallace threatened to hurt the victim, her mother and grandmother if the victim did not comply. Wallace took the victim out at night to work as a prostitute on the streets and arranged for men to come to the house and have sex with the victim. Wallace also ordered the victim to do housework and to massage Wallace's back and feet. Wallace engaged in other abuse, including leaving the victim in the backyard without clothes on, burning her, beating her, threatening her with a knife, making her drink a cup of urine and lick a dog's genitals, and tying her to a chair, gagging her, and leaving her. Chaney participated in some of this abuse.
Wallace pleaded guilty to sex trafficking by fraud, force, or coercion and was sentenced to 20 years imprisonment and 5 years supervised release and fined $100. She appealed her sentence because it was an upward departure from the mandatory minimum. The Eighth Circuit affirmed the sentence (more details in legal reasoning section).
Chaney pled guilty to conspiracy to commit sex trafficking. She admitted that she helped pick up the victim from the victim’s cousin's house. She said she was aware that the victim was being beaten and forced into prostitution, and she admitted helping tie her up in a garage behind the house. Chaney was sentenced to 60 months imprisonment and 2 years of supervised release.
Richard Marquis Harper, another resident of the house and defendant in a related case, pushed the victim's head under water in the bathtub. Harper pled guilty to misprision of felony (8 U.S.C. 4) under a separate case number and with a different judge, and was sentenced to 27 months imprisonment and 1 year supervised release and fined $100.
1st Instance:
Court: U.S. District Court for the Eastern District of Missouri
Location: St. Louis, Missouri
Date of decision: July 22, 2009
Reference: Docket number 08-CR-00461
2nd Instance:
Court: U.S. Circuit Court for Eighth Circuit
Date of decision: May 13, 2010
Reference: U.S. v. Wallace, 605 F.3d 477 (8th Cir. 2010)
3rd Instance: Wallace appealed the decision of the 8th Circuit Court before the Supreme Court of the United States. The Supreme Court denied the petition for writ of certiorari on December 13, 2010. This effectively leaves the sentence as affirmed by the 8th Circuit Court.
Reference: Wallace v. United States, 131 S.Ct. 840 (2010)
Victim suffers from mental disabilities.
The defendant entered a guilty plea.
18 USC 1591
The defendant was sentenced to 240 months and 5 years of supervised release.
Wallace appealed the sentence imposed by the district court judge. The mandatory minimum sentence for the sex trafficking charge that Wallace pled guilty to was 180 months imprisonment. The judge sentenced her above the minimum, to 240 months, under federal sentencing guidelines.
Wallace argued that the sentence was procedurally and substantively incorrect. Procedurally, Wallace argued that the sentence was “greater than necessary” and that the court did not consider “mitigating evidence” of Wallace’s own child abuse. Wallace also argued that the court did not articulate the reasons for the higher sentence.
The Circuit Court disagreed with Wallace and affirmed the sentence on procedural grounds. The appellate court reasoned that the sentencing judge does not need to use specific language at sentencing but only has to “set forth enough to satisfy the appellate court that [the judge] considered the parties’ arguments and has a reasoned basis for exercising . . . legal decision-making authority.” Because the sentencing judge in this case gave reasons for the sentence-- including noting that Wallace’s background and abuse gives insight into her character but does not excuse her conduct towards the victim in this case-- the appellate court rejected Wallace’s procedural challenges.
Wallace’s arguments that the sentence was substantively unreasonable were also rejected. Wallace argued that her sentence was higher than sentences that defendants in other cases received for the same charge of human trafficking. The appellate court rejected this challenge, however. The court noted that sentencing judges may increase sentences above the guideline range when the conduct was “unusually heinous, cruel, brutal, or degrading to the victim.”
Because Wallace used a knife and cigarette lighter to injure her victim’s exposed breasts, tied the victim to a chair and left her with a rag in her mouth, forced her victim to drink a cup of urine and perform acts of bestiality, the court agreed with the sentencing judge that these actions were “extreme” and warranted a sentence above the guidelines. Therefore, the appellate court ruled that the sentencing judge did not abuse discretion by sentencing Wallace to a longer prison term than the guidelines suggested.
8 USC 371
The defendant was sentenced to 60 months of imprisonment and 2 years of supervised release.
The defendant entered a guilty plea.
U.S. Circuit Court for Eighth Circuit
US DOJ press release: http://www.justice.gov/opa/pr/st-louis-woman-sentenced-20-years-prison-federal-sex-trafficking-charge
Michigan Database link for Wallace: http://www.law.umich.edu/CLINICAL/HUTRAFFICCASES/Pages/CaseDisp.aspx?caseID=680
Michigan Database link for Harper: http://www.law.umich.edu/clinical/HuTrafficCases/Pages/CaseDisp.aspx?caseID=683
St. Louis News Article about all three defendants: http://www.stltoday.com/news/abuser-of-disabled-teen-gets-years/article_984a3a82-ce6d-5484-95c1-363d09c6faab.html
All three defendants pled guilty. Only one of the defendants, Wallace, appealed her sentence; she did so, in part, by arguing that the sentencing judge had imposed a harsher sentence on her than on other defendants convicted of human trafficking.