Federal Prosecutors Research Articles

Caremark's Irrelevance

In re Caremark Int’l Inc. Derivative Litig. is commonly held out as the iconic corporate law case on liability for a failure of legal compliance, but the true source of corporate law as to legal compliance is the higher standard established by other sources of law. The expected cost of liability, both criminal and civil, for violations of federal healthcare regulations, for example, is a far stronger determinant of corporate compliance systems than potential liability under Caremark. Other areas of industry-specific regulation, such as for financial services, telecommunications and energy, similarly play a greater role than state corporate law in the design and operation of corporate compliance systems, as do regulations in the form of federal sentencing guidelines and employment and environmental law. The common exaggeration of Caremark’s significance illustrates a flawed pedagogical overemphasis on state corporate law as a legal determinant of corporate compliance and a broader misconception about the influence of regulatory law in corporate affairs. This article shows that federal regulatory law is a far more determinative source of law than Caremark in the design and operation of corporate compliance systems. Part II of this article compares Caremark to the parallel federal criminal prosecution of the firm to illustrate the influence of federal law in the design and operation of corporate compliance systems. Part III further discusses the determinative role of healthcare regulation in corporate compliance systems and regulatory trends, and uses recent litigation involving Pfizer Inc. to further elucidate the role of healthcare regulation. Part IV broadens the discussion by considering the role of prosecutorial and sentencing guidelines in corporate compliance generally. Part V suggests that corporate law pedagogy would be well-served by reducing its focus on state corporate law and giving greater prominence to the actual legal determinants of corporate conduct. Part VII concludes.

A Case Study Of Crisis Communication, Image Restoration And Utilitarian Ethics: A Recall Of Contaminated Peanut Butter Examined

In a publicized crisis, the goal to ethically and restoratively regain public trust is paramount to most corporations. In 2009, the food industry in the USA was thrust into a crisis when the Peanut Corporation of America (PCA), a small peanut processing company in Georgia, was linked to a salmonella outbreak resulting in illness, fatalities, and the recall of close to 4,000 products. Many large food product companies bore the economic impact, though they were not the cause of the problem. Consumers became confused about which products were safe. The oversight stewardship abilities of the Food & Drug Administration (FDA) became suspect. PCA went bankrupt and its owners face federal prosecution. To fully understand the public communication decisions made by PCA, principles of Image Restoration Theory are used to examine and evaluate PCA’s responses to this event. To render generalizable knowledge for others from this historic case, Utilitarian Ethics are applied to the actions of PCA, the FDA, and the peanut industry as a whole. This analysis of past events may serve to empower business leaders and corporate communicators faced with correcting future food borne illness problems and communicating with their key constituencies of regulators, business partners and consumers.

A Tilted Playing Field? The Release-Dismissal Asymmetry and Interplay Plea Bargaining

Though Judge Learned Hand famously wrote in 1923 that “[u]nder our criminal procedure the accused has every advantage,” more recent scholarship has persuasively argued that the playing field in a criminal prosecution is tilted against, rather than for, the defendant. In federal criminal prosecutions where there is, beyond the immediate criminal liability risk, a future threat of the government also bringing civil claims against the same defendant, the defendant faces increased uncertainty and vulnerability. This vulnerability is made worse by an asymmetry in options available to the parties in a criminal prosecution, an asymmetry that has been hesitantly but repeatedly ratified in the case law and by prosecutors themselves. In particular, while the defendant can and may be compelled to give up any of his future meritorious civil claims arising out of the prosecution and thus assure the government the finality it might seek, federal prosecutors often cannot assure the defendant that the government will not pursue future civil claims against the defendant. This limit on the prosecutor’s power to bind the government from bringing future civil charges against the defendant, and its effect on the plea process in criminal cases, are both illustrated vividly in the tax interplay and immigration interplay contexts. The ultimate effect of this power imbalance within the contractual model of plea bargaining is to increase the defendant’s vulnerability during the plea process, to strengthen the government’s already substantial leverage, and to create a harsh trap for the unwary and unsophisticated defendant who erroneously thinks he has bargained for finality.

Reframing the Right: Using Theories of Intangible Property to Target Honest Services Fraud After Skilling

Few federal criminal statutes have been as widely charged --- and widely criticized --- as the honest services statute, 18 U.S.C. § 1346. Primarily, this is because federal prosecutors have used the statute to charge corrupt officials with mail or wire fraud for denying citizens the intangible right to their impartial services, regardless of whether those citizens suffered any financial or proprietary loss --- an element typically required under the traditional mail and wire fraud statutes. Recently, in Skilling v. United States, the Supreme Court dealt a blow to the honest services theory when it interpreted § 1346 to reach only bribery or kickback schemes. Scholars and commentators predict the decision will mark the end of federal prosecutions for more inchoate forms of fraud, such as undisclosed self-dealing and hidden conflicts of interest. Fearing as much, members of Congress have proposed legislation to criminalize undisclosed self-dealing expressly and thereby retain the full anti-corruption enforcement power of the mail and wire fraud statutes. In response, this Note argues that initial reactions to Skilling have overstated the extent to which federal prosecutors are now hindered in their ability to prosecute honest services misconduct. Just as they have done for decades, prosecutors can and should continue to target honest services misconduct using the traditional mail and wire fraud statutes, 18 U.S.C. §§ 1341 and 1343, by reframing the victim’s right as an intangible property right. This Note provides a framework for how prosecutors can do so while largely replicating the sweep and targets of pre-Skilling § 1346 honest services prosecutions and concludes that such an exercise of prosecutorial discretion is both appropriate and desirable.

Research Report on Criminal Prosecution in California Courts of Former President George Bush for Conspiracy to Commit Murder and Murder

With the end of the War in Iraq announced by sitting President Barack Obama in 2011, another opportunity arises for accountability for instigating that war.An unexplored avenue for accountability for a former American President in the American structure is the state criminal prosecution. This alternative path conducted in appropriate circumstances appears to be foreseen in our constitutional structure. This alternative path is a means for assuring the double protection of the rights of the People as was envisioned by Alexander Hamilton and James Madison. Originally prepared at the invitation of Vincent Bugliosi, this research report explores the opportunities and hurdles for a state (as opposed to federal) criminal prosecution of former President George W. Bush for ordinary state crimes of conspiracy to commit murder and murder for the deaths of American soldiers in the War in Iraq.This research report examines the dual nature of a former President defendant, federalism tensions, separation of powers tensions, state criminal jurisdiction for these crimes, federal officer removal, habeas and other possible interventions in state and federal courts, likely defenses such as federal exclusive domain, federal preemption, state secrets privilege (national security), executive privilege, supremacy clause immunity, qualified immunity, the political question doctrine, the act of state doctrine, self-defense or necessity defenses, sitting President or governor interventions, the innocent agent doctrine, limitations on Presidential War Power including whether there is a possibility of taking the country to war under false pretenses, Curtiss-Wright and the Youngstown trilogy and the United States international law obligations.The research report concludes that, while recognizing the difficulties, such a state criminal prosecution can be done and, as a normative matter with regard to the deaths of American soldiers in the War in Iraq, should be done.The hope is that the research report can serve as a template. The report fleshes out an expressive domestic alternative path to accountability for high-level federal officials that complements federal criminal prosecution, impeachment for political liability, electoral accountability for political liability in our domestic structure, as well as foreign or international tribunal criminal prosecution.

Uma "morte suave": valores religiosos e laicos nos discursos sobre ortotanásia

Este artigo aborda a controvérsia em torno da gestão do término da vida, a partir da análise da ação civil pública provocada pelo Ministério Público Federal, com o intuito de revogar a Resolução 1805/2006 do Conselho Federal de Medicina sobre a ortotanásia. Consideram-se aqui os argumentos médico e jurídico, em suas articulações com valores religiosos. A reflexão acerca dos discursos no processo judicial, em defesa de cada posicionamento (favorável e contrário à autorização legal da ortotanásia) possibilita uma compreensão das tramas e dos atores sociais envolvidos nos debates contemporâneos sobre os limites da vida, sobre as possibilidades de intervenção médica e acerca dos direitos de autonomia individual, diante da faculdade de tomada de decisões no último período de vida, no caso de pessoa com doença crônico-degenerativa, em fase terminal.

Prosecutors in the boardroom: using criminal law to regulate corporate conduct

Acknowledgments Introduction Anthony S. Barkow and Rachel E. Barkow 1 The Causes of Corporate Crime: An Economic Perspective Cindy R. Alexander and Mark A. Cohen 2 Deferred Prosecution Agreements on Trial: Lessons from the Law of Unconstitutional Conditions Richard A. Epstein 3 Removing Prosecutors from the Boardroom: Limiting Prosecutorial Discretion to Impose Structural Reforms Jennifer Arlen 4 Potentially Perverse Effects of Corporate Civil Liability Samuel W. Buell 5 Inside-Out Enforcement Lisa Kern Griffin 6 The Institutional Logic of Preventive Crime Mariano-Florentino Cuellar 7 Collaborative Organizational Prosecution Brandon L. Garrett 8 The Prosecutor as Regulatory Agency Rachel E. Barkow 9 What Are the Rules If Everybody Wants to Play? Multiple Federal and State Prosecutors (Acting) as Regulators Sara Sun Beale 10 Reforming the Corporate Monitor? Vikramaditya Khanna Conclusion Anthony S. Barkow and Rachel E. Barkow Contributors Index

SOPA and the Future of the Internet

The US legal system reflects the world within which it was designed to operate: law (by and large) respects borders. The Internet (by and large) does not, however: How do we bring law to this border-disrespecting place? The Stop Online Piracy Act (SOPA) was meant to reduce access to foreign Internet sites that infringe US copyright. SOPA would have authorized federal prosecutors, and private rightsholders in certain circumstances, to bring in rem actions against the domain names associated with infringing sites—allowing the court, in effect, to “seize” the domain names. SOPA is unworkable because the network architecture virtually guarantees that evasion will be widespread and rather simple to accomplish. It is unjust because a principle undergirding the US legal system is that you may not deprive anyone of life, liberty, or property without due process of law. Moreover, what gives the Internet its extraordinary and transformative power is precisely the fact that it has no borders, that it is a single global network that connects everyone as peers. Chopping it up into pieces would destroy it. Copyrighted works are important and worth protecting. They are not, however, sacred objects that we should protect at any cost. The damage SOPA would have done to the technical and legal infrastructure of the Internet is immense, and its benefits would have been negligible.

Constitutionalizing Anarchy: Liberalism, Lynching, and the Law

Overall review of Supreme Court cases regarding racial violence suggests that while the Court did rule in favor of acquitting lynchers of federal prosecution, it did not completely strip all authority for federal rights enforcement. This essay reassesses the Supreme Court’s handling of racial violence and formulates a theory of law that can account for how lynchings could exist as a tacitly accepted practice without being explicitly sanctioned by the law. Rather than cracking down on lynchers and/or the states that failed to deal with lynchers, the Supreme Court decided to create “zones” wherein questionable activities like lynchings could occur unhampered. Lynchings for the most part were situated within a constructed zone of permissiveness that was contingent not upon the sanctioning of political authorities per se, but rather upon political authorities choosing to maintain an active policy of non-interference. Drawing from Ernst Fraenkel’s model of the dual state and Gerald Neuman’s concept of anomalous zones, constitutional anarchy illuminates how the U.S. carved out legally bounded regions of lawlessness. Implications of existentially demarcated spaces can be seen in a variety of arenas and highlight the commensurability of illiberalism and liberalism via the distinction between content and scope of law.

Crime, Immigration, and Ad hoc Instrumentalism

Criminal law and immigration law, once separate fields of governance in the United States, are rapidly growing less distinct. Immigration crimes now account for a majority of all federal prosecutions; deportation is widely seen as a key tool of crime control; immigration authorities run the nation’s largest prison system; and state and local law enforcement officers work hand-in-hand with federal immigration officials. This article traces these trends and assesses their significance. The rise of an intertwined regime of “crimmigration” law has generally been attributed to some combination of nativism, overcriminalization, and a cultural obsession with security, but it also exemplifies, and has helped to reinforce, a crucial and underappreciated development in U.S. legal culture—a rising tendency to treat legal rules and legal procedures as interchangeable tools, to be brought to bear pragmatically and instrumentally on an ad hoc basis. Ad hoc instrumentalism of this kind has genuine strengths, but it also raises significant concerns about the rule of law and political accountability. The accountability concerns, in particular, are exacerbated by two other features of our newly merged system of immigration enforcement and criminal justice: its bureaucratic opacity and its selective application.

The Failure of the Organizational Sentencing Guidelines

In order to deter corporate crime, corporate sanctions must be structured to induce large corporations to help federal prosecutors detect and punish corporate crime. Specifically, firms must be encouraged to detect and report wrongdoing, and to cooperate with the government’s effort to identify and sanction the individuals responsible for the crime. Firms will not engage in these activities unless they face lower expected sanctions if they detect, report, and cooperate than if they do not. This Article examines whether the Organizational Sentencing Guidelines achieve this objective and shows that they do not. Although the Organizational Sentencing Guidelines offer sanction mitigation to firms that adopt effective compliance programs, self-report, and cooperate, this Article shows that these provisions offer too little mitigation to encourage firms to detect, report, and help prosecute the employees’ crimes. Indeed, the Guidelines’ mitigation provisions are particularly inadequate in the very circumstances where corporate detection and investigation is most important: in cases involving crimes committed by managers of large firms. As a result, U.S. efforts to deter corporate crime are undermined by adherence to the Organizational Sentencing Guidelines. This may partly explain why the Department of Justice adopted an alternative strategy for encouraging corporate reporting and cooperation, one that differs materially from the Organizational Guidelines. To help deter corporate crime, the Sentencing Commission should reform the Guidelines.

Re-Thinking Illegal Entry and Re-Entry

This Article traces the history of two federal immigration crimes that have long supplemented the civil immigration system and now make up nearly half of all federal prosecutions: illegal entry and illegal re-entry. Academics have written little about the historical lineage of either crime, despite the supporting role each played in enforcing America’s civil immigration laws, particularly along the U.S.–Mexico border. This Article takes a critical look at the enforcement of each crime — from when they were initially conceived as a way to deter illegal immigration, then as a way to target dangerous aliens, and most recently as a means to do both. These shifting strategies, however, have one thing in common: ineffectiveness. Enforcing the crimes has never meaningfully deterred illegal immigration, and the government’s poorly designed proxy to determine whether an alien is “dangerous” ensured that prosecutions have not made the public safer. The most recent period is particularly troubling — approximately 72,000 combined prosecutions a year, at the cost of well over a billion dollars and at the expense of foregoing more serious criminal prosecutions. Despite these huge costs and the related human carnage, the criminalization of illegal entry and re-entry is invariably left out of the discussion of comprehensive immigration reform, which reflects the silent treatment these crimes have received in the immigration and criminal law literature more generally. By reviewing eight decades of ineffective policy, this Article contends that enforcing the crimes of illegal entry and re-entry warrants both more attention as well as a fundamental re-thinking of using the criminal justice system to regulate immigration.

Med Check

Med Check

State Constitutional Rights and Federal Criminal Trials: The Hollow Promise of the New Judicial Federalism

This article explores the intersection between the New Judicial Federalism movement, where state courts interpret their states’ constitutions to provide more expansive protections of individual rights and civil liberties than the federal Constitution requires, and federal criminal law. At least as a general proposition, the United States Supreme Court has significantly narrowed the scope of criminal defendants’ federal constitutional rights in recent years, e.g., interpreting the Fourth, Fifth, and Sixth Amendments in a restrictive fashion in many recent decisions. To counter that trend - Justice Brennan called “the [Supreme] Court’s contraction of federal rights and remedies” - many state courts have “step[ped] into the breach” and held “that the constitutional minimums set by the United States Supreme Court were insufficient to satisfy the more stringent requirements of state constitutional law.” State courts, for example, are increasingly declining to interpret provisions of their state constitutions in pari materia with analogous provisions in the federal constitution, as interpreted by the U.S. Supreme Court. Many state constitutions, moreover, contain provisions that explicitly afford citizens specific rights that have no analogue in the federal constitution, creating further opportunities for the development of a rich, independent body of state constitutional law.The promise of judicial federalism, however, rings hollow in federal criminal trials, to the detriment of not only criminal defendants but our system of federalism. This article highlights a well-established, judicially blessed loophole that not only permits state and local law enforcement to ignore inconvenient state constitutional constraints but creates perverse incentives for them to do so: federal courts routinely admit evidence in federal criminal trials that has been obtained by state and local law enforcement in violation of state law, so long as that evidence is obtained consistent with federal minimum standards. As a practical matter, two salient features of federal law make this possible: the supremacy of federal law and the incredibly broad concurrent jurisdictional authority enjoyed by federal prosecutors. As Judge Richard Posner has observed, then, “State law enforcement officers who violate state law without at the same time violating federal law will often be able to turn over the fruits of their violations to federal law enforcement officers who will as it were do the state officer’s prosecuting, only in federal court.” This article posits that although federal courts do not have any constitutional or statutory obligation to enforce state constitutional rights in federal criminal trials, they have the authority to do so. And this article maintains that myriad normative and policy considerations, including principles of federalism and comity as well as rule-of-law values and the imperative of judicial integrity, militate toward the conclusion that federal courts should honor defendants’ state constitutional rights in federal criminal trials under certain circumstances.

Federal Prosecutors, Not Judges, Decide Whether Defendants Serve a Five-Year Mandatory Minimum in Certain Child Pornography Prosecutions: Further Cause for Repeal and Reform

Federal Prosecutors, Not Judges, Decide Whether Defendants Serve a Five-Year Mandatory Minimum in Certain Child Pornography Prosecutions: Further Cause for Repeal and Reform

Tribal Control in Federal Sentencing

Under the federal sentencing guidelines, each federal crime has an offense level that can go up or down depending on the crime’s circumstances. Combined with a defendant’s criminal history, the final level determines the range of sentences recommended under the guidelines. I propose that tribes alone decide offense levels for crimes committed in Indian country. This proposal aims to (1) enhance tribal sovereignty over on-reservation violence and thereby provide tribes with experience regulating felonies; (2) increase respect among tribal governments and their members for federal criminal prosecutions; and (3) decrease the racial sentencing disparity between Indians and non-Indians.

Corporate Investigations - Challenges in Corporate Governance

One of the effects of this historic financial crisis and its spotlight on corporate conduct is likely to be an increased pressure to allocate blame. That pressure is bound to be directed toward identifying culpable employees within a firm, given the desire to spare corporations from indictment and prosecution. Thus corporate directors will have to consider the potential implications to the firm of the process required to identify such culpable employees- corporate investigations. Additionally, should the firm succeed in being spared an indictment it will likely be subject to ongoing oversight through a Deferred or Non-prosecution agreement (“DPA” and “NPA,” respectively). This paper will trace the tortured trail of the Department of Justice (“DOJ”) in creating various iterations of Principles of Federal Prosecutions of Corporations. Notwithstanding nearly a decade of memoranda addressing these issues the DOJ has left the corporation vulnerable to undermining important legal protections and ethical principles. Furthermore, should a corporation succeed in avoiding indictment and entering into a deferred or non-prosecution agreement its directors need to be aware of the unchartered waters in which they may be operating. This paper will also address the specific governance issues surrounding such agreements.

Google, Gadgets, and Guilt: Juror Misconduct in the Digital Age

Improper use of new technology by jurors inside and outside the courtroom has become so pervasive that commentators have coined new phrases to describe it: “Google Mistrials,” the “Twitter Effect,” and “Internet-Tainted Jurors.” Yet, despite the attention garnered, few legal scholars, to date, have examined this area in-depth. The articles addressing this topic primarily focus on the benefits of technology and how to harness it to assist juror comprehension. This dearth of legal scholarship may be due in large part to the fact that the Digital Age is fairly new and still evolving and juror misconduct is historically an under-examined area of the law. This article attempts to fill the current void by analyzing the detrimental impact of the Digital Age on sitting jurors and how it might be lessened. While many of the issues examined in this article apply equally to civil cases, the primary focus of this article is on jurors deciding criminal cases. This article begins, in Part I, by discussing the influence of the Digital Age on juror research and communications. Here, the article examines the traditional reasons for juror research. The article then discusses how the Information Age has created new rationales for jury research while simultaneously affording jurors greater opportunities to conduct such research. This section also examines how new technology has altered juror to juror communications and juror to non-juror communications. This section concludes by analyzing the rationales for why jurors violate court rules about discussing the case. In Part II, the article analyzes possible steps to limit the negative impact of new technology on juror research and communications. While no single solution or panacea exists for these problems, this article focuses on several reform measures that could address and possibly reduce the detrimental effects of the Digital Age on jurors. The four remedies discussed in this article are: (1) penalizing jurors; (2) investigating jurors; (3) improving juror instructions; and (4) allowing jurors to ask questions. During the discussion on jury instructions, this article analyzes two sets of jury instructions to see how well they adhere to the suggested changes proposed by this article. This is followed by a draft model jury instruction. As part of the research for this article, this author conducted one of the first surveys (“Jury Survey”) on jury service in the Digital Age. Jury Surveys went to federal judges, prosecutors, and public defenders throughout the country. The questions in the survey focused primarily on juror research but briefly touched upon juror communications. Although the responses were anonymous, the Jury Surveys were written in such a way as to distinguish responses from judges and practitioners. Of the responses received, approximately half were from judges and the other half were from either a federal public defender or prosecutor.

The Prosecution of George W. Bush for Murder , and: JFK and the Unspeakable: Why He Died and Why It Matters (review)

Reviewed by: The Prosecution of George W. Bush for Murder, and: JFK and the Unspeakable: Why He Died and Why It Matters David Lempert, Ph.D., J.D., M.B.A., E.D.(Hon.) (bio) Vincent Bugliosi, The Prosecution of George W. Bush for Murder (Vanguard Press 2008) 532 pages, ISBN 9781593154813; James W. Douglass, JFK and the Unspeakable: Why He Died and Why It Matters (Orbis Books 2008) 510 pages, ISBN 9781570757556. Over the past thirty years, there are few works in the social sciences that explain how systems of power and punishment or control of leadership work in the major empires of our time—the US and Russia/Soviet Union. Moreover, those works that do exist are mostly outside the social sciences (or outside any discipline) because of what historian James Douglass refers to as “the Unspeakable;” the taboos and controls that prevent us from writing directly about these issues. Two new books that try to do that are Douglass’ work published by a Catholic press, not a university press, and lawyer-prosecutor Vincent Bulgiosi’s work documenting mass murder by President Bush, a topic he says no other book publisher or editor would touch other than Vanguard. Despite the different disciplines and approaches, what links these two books is their discussion of power of the US president in relation to the military-industrial complex-national security state, and whether the US legal system will or can hold these leaders or institutions accountable for murder. Douglass focuses on murders that he attributes to the national security state of a US president and other Americans “they” consider “traitors” (a threat to their goals of assassination, state terrorism and war overseas). In Bugliosi’s book, the murders are those committed by the president and his staff through use of the state apparatus in violation of national (and international) law. From a scholarly perspective, Bugliosi’s book is thin and disappointing. The book offers little more than a potential dissertation topic—a study of how prosecutors, at levels from county and state [End Page 773] attorneys to federal district prosecutors, have been unwilling as of January 2009 to prosecute George W. Bush, Dick Cheney, Condoleezza Rice, Donald Rumsfeld, Karl Rove, and members of the “White House Iraq Group”; how other institutions hire these individuals and publish their writings; how the public has been silent; what it means for the US and international legal systems when clear legal violations of murder are not used for impeachment and not enforced; and under what circumstances and at what levels leaders can commit murder with no consequence. Despite similar books that appeared asserting similar legal charges, Richard Nixon, Henry Kissinger, Bill Clinton, Madeleine Albright, and others have followed a ritual script of fortune and fame after their government jobs. Although Bugliosi lays out a clear case for legal prosecution, and provides interesting data on prosecutor’s blind spots and on how US media functions, there is little new in Bugliosi’s book. He begins with the startling statement that Bush’s actions constitute “the most serious crime ever committed in American history.”1 In his view, the death of 4,000 US soldiers in a war against Saddam Hussein who “was not an enemy of the United States”2 makes this a crime. By contrast, the Native American genocides, enslavement and genocides of Africans, imperial wars that have killed millions in Asia, Latin America, and elsewhere, are not criminal activity. The book is mostly a vitriolic against Bush, whom Bugliosi derides as “this punk who hid out during the Vietnam War (sic)”3 and who, with Dick Cheney, has “the gonads of 10,000 elephants.”4 There is something reminiscent of Camus’ voice in L’Etranger here, where Bugliosi’s anger seems to stem from Bush’s lack of emotion and concern over the US deaths. He seems to fault Bush and his “co-conspirators” for the robotic pathology of modern leaders who treat wars like video games while simultaneously appearing “reluctant” to send people to their deaths. Although Bugliosi raises many of the right questions about what has gone “wrong” or “changed” in US culture, in the last chapter of the book, he never...

Shift Sex-Trade Focus Away From Victims, Advocates Urge

Shift Sex-Trade Focus Away From Victims, Advocates Urge