United States v. Chen, 1:22-cr-00158

Siyang Chen was indicted and convicted by a jury of multiple counts related to his leadership role in a violent commercial sex ring, including a count for sex trafficking conspiracy under 18 U.S.C. § 1591.
The prosecution presented extensive evidence showing Chen's organization violently assaulted and robbed prostitutes working for rival rings, as a means of market control.
Prior to and during trial, Chen pled guilty to several non-sex-trafficking charges but not to the sex trafficking conspiracy charge that is the subject of this decision.
After conviction, Chen moved under Rule 29 for acquittal on the sex trafficking conspiracy count (Count 1), arguing the evidence did not meet the statutory requirement of coercing prostitution.
The Court found that while the evidence showed brutal assaults, it did not show that violence was used to force anyone into or to continue sex work; violence was aimed at restricting competitors, not coercing sex acts.
The Court granted Chen’s Rule 29 motion, vacating the sex trafficking conspiracy conviction, but left his convictions on other violent and racketeering charges in place.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for sex trafficking	Chen's organization used violence to coerce sex workers, satisfying §1591.	Violence was to drive out competitors, not compel prostitution.	Evidence insufficient; acquittal granted.
Statutory interpretation of § 1591	Any use of force in commercial sex setting meets causality under §1591.	Statute requires force used to induce or compel sex acts, not just violence.	Court agrees statute requires causation; force was anti-competitive, not coercive.
Application of legislative history	Congress intended broad protection, including anti-competitive violence.	Legislative history shows intent to target coercive, involuntary sex work.	Court agrees with Chen: §1591 targets coercion, not competition.
Necessity of causality element	Proximity of violence to commercial sex work is sufficient.	Must prove violence intended/caused sex acts to be performed.	Causality not met on facts; acquittal warranted.

United States v. Reifler, 446 F.3d 65 (2d Cir. 2006) (standard for Rule 29 acquittal and evidentiary review)
United States v. Hamilton, 334 F.3d 170 (2d Cir. 2003) (burden on defendant for Rule 29 motion)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for judging sufficiency of evidence)
United States v. Guadagna, 183 F.3d 122 (2d Cir. 1999) (threshold for Rule 29 acquittal)
United States v. Graham, 707 F. App’x 23 (2d Cir. 2017) (causation as essential element for §1591 offense)
United States v. Rivera, 799 F.3d 180 (2d Cir. 2015) (coercion standard in sex trafficking context)