Sufficiency of Evidence-Sentencing Reasonableness

7^th Circuit Court of Appeals

Case Name: United States of America v. Marina Oke

Case No.: 24-2977

Officials: Easterbrook, Lee, and Maldonado, Circuit Judges.

Focus: Sufficiency of Evidence-Sentencing Reasonableness

In 2014, three women orchestrated a scheme to bring two girls, ages 11 and 14, from Benin to the United States under false pretenses. The girls’ families were told that the children would attend school and have opportunities to earn money. To facilitate their entry, the women obtained fraudulent identification and travel documents and presented immigration authorities with a fabricated account of the girls’ circumstances. After the girls arrived in Illinois, the women subjected them to forced labor in their homes, prevented them from attending school, denied them adequate medical care, and subjected them to physical and psychological abuse. Over the ensuing years, both girls eventually escaped and cooperated with law enforcement.

A federal grand jury in the Northern District of Illinois indicted the women for conspiracy to harbor and shield unauthorized aliens, harboring and shielding unauthorized aliens, and forced labor. After the first trial ended in a mistrial, the case was retried. The government presented extensive testimony from the victims, along with corroborating evidence from other witnesses and documents. The defense challenged the victims’ credibility, pointing to inconsistencies in their accounts and asserting that they had motives related to obtaining immigration benefits. The jury nevertheless found all three defendants guilty on all counts. The jury also determined that two defendants had committed their offenses for financial gain, resulting in enhanced sentences. The district court denied the defendants’ post-trial motions for acquittal or a new trial, emphasizing that assessing witness credibility was the province of the jury.

The Seventh Circuit reviewed the sufficiency of the evidence and the reasonableness of the defendants’ sentences and concluded that the victims’ testimony, together with corroborating documentation and other evidence, provided sufficient evidence for a rational jury to find the defendants guilty of the harboring and forced-labor offenses. The court also determined that the sentences, which fell within or below the applicable Guidelines ranges, were reasonable.

Affirmed.

Decided 08/13/26

Full Text