By: WISCONSIN LAW JOURNAL STAFF//March 4, 2024//
7th Circuit Court of Appeals
Case Name: United States of America v. Benjamin Biancofiori
Case No.: 21-3372
Officials: Sykes, Chief Judge, and Easterbrook and St. Eve, Circuit Judges.
Focus: 18 U.S.C. §1591-Sex Trafficking
A jury convicted Biancofiori of sex trafficking by force, in violation of 18 U.S.C. §1591, and he was sentenced to 360 months in prison plus supervised release for life. The evidence permitted the jury to find that, between 2007 and 2016, Biancofiori compelled nine adult women to engage in prostitution, beating them if they tried to escape or failed to hand over their receipts. Biancofiori contended that §1591 covers only the sex trafficking of minors or is unconstitutional. The Circuit determined that the statute’s rule is well-defined. Biancofiori’s argument relies on statements in the legislative history, not on the statutory language. Many a statement by many a legislator is vague, or does not match the enacted statute, but that does not render invalid an enacted text whose meaning is ascertainable. The Seventh Circuit does not perceive any other plausible constitutional argument against the statute’s application to Biancofiori.
Affirmed.
Decided 02/28/24