United States v. Mi Sun Cho
United States Court of Appeals for the Second Circuit
713 F.3d 716 (2013)
Mi Sun Cho (defendant), prosecuted for transporting a woman in interstate commerce for prostitution under the Mann Act, arranged for a contact -- who turned out to be a government informant -- to offer Mei Hua Jin, a woman she knew from a prior brothel job, employment at a Manhattan brothel and to specify the exact date and time Jin should travel from Atlantic City. Jin traveled to Queens by bus and subway at her own expense, where the informant then drove both Jin and Cho into Manhattan, dropping Cho off along the way before delivering Jin to the brothel, which ultimately rejected her for being too old. Cho was convicted and challenged the sufficiency of the evidence that she transported, or caused the transportation of, Jin in interstate commerce.
Whether a defendant can be convicted for sex trafficking even if he used a third party to carry out the offense.