Case Law Database

Trafficking in persons

United States v. Linda O'Connor

Fact Summary

S.O. testified that she was sexually abused by her mother, her mother's sex partner, George Lang (or “George” or “Lang”), Sacco, and by two strangers in encounters arranged by her mother.

The defendant O'Connor sold her daughter to her landlord, defendant Sacco, in exchange for rent owed by O’Connor to Sacco. Evidence at the trial revealed that Sacco produced pornographic images from the sexual assaults. The victim also testified that O'Connor had also prostituted her at local hotels. The victim was trafficked for a period of approximately two years, when she was between the ages of 12 and 14.

Sentence Date:
2008-09-30
Author:
Human Trafficking Database of the University of Michigan Law School

Keywords

Acts:
Transportation
Receipt
Means:
Abuse of power or a position of vulnerability
Giving or receiving payments or benefits to achieve the consent of a person having control over another person
Purpose of Exploitation:
Exploitation of the prostitution of others or other forms of sexual exploitation
Form of Trafficking:
Internal
Sector in which exploitation takes place:
Commercial sexual exploitation

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

After an 18-day trial, the jury found O’Connor guilty on three of the five counts against her, and she was sentenced to 30 years imprisonment, to be followed by supervised release for life. Sacco was convicted on all five of the counts against him, and was sentenced to life imprisonment.

Both defendants appealed the judgment to the United States Court of Appeals for the Second Circuit. The Second Circuit affirmed the judgment on June 16, 2011.

 
 

Victims / Plaintiffs in the first instance

Victim:
S.O.
Gender:
Child
Nationality:
American

Defendants / Respondents in the first instance

Defendant:
Linda O'Connor
Gender:
Female
Defendant:
Dean Sacco
Gender:
Male

Charges / Claims / Decisions

Defendant:
Linda O'Connor
Legislation / Statute / Code:
18 U.S.C. § 1591
Charge details:
Sex trafficking of a child
Verdict:
Guilty
Charge details:
Selling a child for the purpose of producing child pornography
Verdict:
Guilty
Charge details:
Permitting her child to be used for the production of child pornography
Verdict:
Guilty
Charge details:
Coercing S.O. to engage in sexual conduct for the purpose of producing child pornography
Verdict:
Not Guilty
Charge details:
Possession of child pornography
Verdict:
Not Guilty
Term of Imprisonment:
30 years
with supervised release for life
Fine / Payment to State:
Yes  100  USD  (Up to 10,000 USD) Special assessment
Appellate Decision:
Upheld

Linda O’Connor argued that the evidence was insufficient to support her conviction on any count, and that the district court had deprived her of a fair trial by denying her motion to provide her with a separate trial from that of Sacco. Sacco contended that the district court had deprived him of a fair trial by denying his attorney’s request to withdraw from the case, because his self-titled autobiography gave an account of his past thoughts and conduct, and by denying his request for a continuance following unexpected testimony from a government witness.

The Court of Appeals found no merit in any of defendants’ contentions and affirmed the judgments.

Defendant:
Dean Sacco
Charge details:
Sex trafficking of a child
Verdict:
Guilty
Charge details:
Buying a child for the purpose of producing child pornography
Verdict:
Guilty
Charge details:
Coercing a child to engage in sexually explicit conduct for the production of child pornography
Verdict:
Guilty
Charge details:
Travel in interstate commerce with intent to engage in illicit sexual conduct with a minor
Verdict:
Guilty
Charge details:
Possession of child pornography
Verdict:
Guilty
Life imprisonment
Fine / Payment to State:
Yes  500  USD  (Up to 10,000 USD) Special assessment
Appellate Decision:
Upheld

Ibidem Defendant 1

Court

United States District Court for the Northern District of New York

Sources / Citations

http://www.law.umich.edu/clinical/HuTrafficCases/Pages/CaseDisp.aspx?caseID=120

http://caselaw.findlaw.com/us-2nd-circuit/1570871.html