United States v. Todd

Jerome Eugene Todd (defendant) turned his girlfriend Kelsey Kirschman into a prostitute, controlling her through psychological domination backed by beatings whenever she broke his rules. He later recruited a second woman, Whitney T., who was trained by Kirschman and witnessed Todd beat Kirschman for disobedience; a third woman, Whitney E., worked under Todd's cousin, who threatened physical enforcement, and Todd himself beat her once; a fourth woman, Jemelle L., was threatened and shoved by Todd, who also beat Kirschman in front of her to intimidate her into staying. Charged under the TVPA for enticing these women into prostitution while "knowing" force, fraud, or coercion would be used, Todd was convicted and appealed, arguing the government never proved he actually knew, in advance, that he would use force or coercion against each woman.