United States Ninth Circuit

In a certified interlocutory appeal involving the scope of the Trafficking Victims Protection Act (TVPA), 18 U.S.C. section 1589 et seq., certified questions are answered as follows: 1) the TVPA permits recovery of punitive damages because it creates a cause of action that sounds in tort; and 2) the TVPA does not apply retroactively to conduct that occurred before its effective date.

Appellate Information

• Decided 11/07/2011
• Published 11/07/2011

Judges

• B. FLETCHER

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Darryl L. Jones, W. Sherman Ernouf