United States v. Paulin

329 F. App’x 232 (2009)

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United States v. Paulin

United States Court of Appeals for the Eleventh Circuit
329 F. App’x 232 (2009)

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Facts

Between 1999 and 2005, Maude Paulin (defendant) coerced a Haitian immigrant girl into performing arduous domestic chores under harsh and dehumanizing conditions. Paulin enforced the girl’s obedience through beatings and threats of sending the girl back to Haiti. After state authorities rescued the girl, the United States government pressed criminal charges against Paulin in federal district court. The three-count indictment charged Paulin with (1) conspiring to violate the Thirteenth Amendment, (2) violating the Trafficking Victims Protection Act (TVPA) of 2000, and (3) violating 8 U.S.C. § 1324’s prohibition against harboring aliens for financial gain. The government took care to distinguish the elements of coercion in the first two counts and also carefully distinguished between Paulin’s pre- and post-2000 conduct. The jury found Paulin guilty on all three counts. Paulin appealed to the Eleventh Circuit, arguing that (1) the government conflated the different elements of coercion needed to support the Thirteenth Amendment and TVPA charges, (2) the government violated the Ex Post Facto Clause by introducing evidence that predated the TVPA’s enactment, and (3) the district court failed to instruct the jury to consider that Paulin’s motives were not purely financial but also charitable.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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