About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

43 Geo. Wash. Int'l L. Rev. 201 (2011)
Re-Trafficked Victims: How a Human Rights Approach Can Stop the Cycle of Re-Victimization of Sex Trafficking Victims

handle is hein.journals/gwilr43 and id is 203 raw text is: NOTE

RE-TRAFFICKED VICTIMS: HOW A HUMAN RIGHTS
APPROACH CAN STOP THE CYCLE OF RE-VICTIMIZATION
OF SEX TRAFFICKING VICTIMS
Cherish Adams*
I. INTRODUCTION
Eighteen-year-old Anu grew up in a small village in an underdeveloped
country, the oldest daughter in a very poor family.1 When Bellina, a family
friend, offered her a job as a maid in Europe she took it to provide for her
family. To her surprise, when she arrived in Europe her employer forced
her to work as a prostitute to repay the cost of the trip and her living
expenses. The trafficker collected any money she made, effectively binding
her in servitude until she paid off her ever-increasing debt. Anu was
trapped-afraid to leave because of threats to her and her family, without
her travel documents, and terrified to go to the police because they were
corrupt in her home country.
After two years of servitude, the police raided her house and arrested her
and other trafficking victims as prostitutes. She. was held in an immigra-
tion detention center, since she did not have correct documentation. When
the police interviewed Anu, she was very cautious and did not reveal much
information because she feared the police and retribution to herself and to
her family. The police suspected that she might be a victim of human traf-
ficking, but because Anu was too afraid to help with an investigation or
prosecution, especially testifying in trial, she was quickly deported back to
her home country without any aid or counseling.
When she returned home, Anu not only faced all the same problems that
had placed her at risk before she was trafficked, but she also had new con-
cerns. She returned with no money, and had not been able to send money
home as she had promised. As a result, she faced mockery from the village
and the anger and disappointment of her family. Soon after her return,
* Law Clerk, Florida Fifth District Court of Appeal. J.D. 2011, The George Washing-
ton University Law School; A.B. 2008, Elmira College.
1. This is a fictional story based on real victim accounts. For examples of human
trafficking cases, see ATT'y GEN., ATTORNEY GENERAL'S ANNUAL REPORT TO CONGRESS AND
ASSESSMENT OF U.S. GOVERNMENT AcTRIVITIES TO COMBAT TRAFFICKING IN PERSONS FISCAL
YEAR 2008 app. B (2009) [hereinafter AG REPORT], available at http://www.justice.gov/
archive/ag/annualreports/tr2008/agreporthumantrafficing2008.pdf.
201

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Contact us for annual subscription options:

Already a HeinOnline Subscriber?

profiles profiles most