Roe v. Howard

Filing 125

MEMORANDUM OPINION. Signed by District Judge Liam O'Grady on 1/3/2018. (awac, )

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division

Sarah Roe.

Plaimiff,
Civil Action No. l:16-cv-562

Hon. Liam O'Grady
Linda Howard,

Hon. John F. Anderson

Defendant.

MEMORANDUM OPINION

This mailer comes before the Court on three of Defendant's Motions for Judgment as a
Matter of Law. Diet. Nos. 98, 99, and lOL The Motions are fully briefed and the Court heard oral

arguments October 20, 2017. Defendant Linda Howard argues she is entitled lojudgment as a

matter of law for three reasons - first, because the statute of limitations on the Trafficking
Victims Protection Act (TVPA) at the time of the relevant conduct would have barred the suit;
second, as to Count III of the complaint, because the sexual abuseof Plaintiff Sarah Roe, a
domestic worker, did not cause Ms. Roe "to engage in a commercial sex act" as defined under 18

U.S.C. § 1591; and third, because the '1VPA proscriptions cannot be applied to Howard's 2007

extraterritorial conduct. For the reasons stated below, the Court DENIES Ms. Howard judgment
as a matter of law on all points. A separate order has issued. Dkt. 107.
Facts ofthe Case

Sarah Roe brought this case under 18 U.S.C. § 1595, which provides a civil remedy for
violations of the 'frafllcking Victims Protection Act (TVPA). On July 31,2017, after a four-day