Currently, two states – Georgia and Connecticut – have introduced legislation to decriminalize prostitution for minors. Critics question whether this effort will reduce the number of children in commercial sexual exploitation: While decriminalization of prostitution for minors does not make pimps and johns innocent of a crime, it does nothing to end demand and may in fact increase it.
Most people will agree that a sexually exploited minor child is a victim. People also agree that many people and factors aid the victimization. They are victims of the pimps and traffickers who force them to sell their bodies. They are victims of the adults who pay to have sex with them. They are victims of the circumstances that force them to sell their bodies for necessities such as food, clothing, and shelter (also known as “survival sex”). Moreover, some are victims of their own bad judgment when they make the decision to sell their bodies for money to buy luxury items. Others are victims because they run away from home and are vulnerable to those who prey on children who hang out at the malls or are stranded at the bus stations.
Within the anti-sex trafficking coalition there is agreement that without the demand for commercial sex, there would be no sex trafficking. The buyers, so-called “johns,” drive the commercial sex industry. The purchasers of commercial sex services are mostly men, and they think there is nothing wrong with buying another human being’s orifice(s) for a certain time. But in today’s culture, finding sex outside of marriage is not difficult. So why would men have to buy sex? Some want the “girlfriend” experience without the actual girlfriend to pay attention to and romance. Some want to act out what they see in pornography, and their wives or girlfriends will not perform those acts. Others act out their anger on the women whose services they buy. No matter the reason, johns are responsible for the exploitation of women and children in the commercial sex industry. If johns stopped buying sex, pimps and sex traffickers would be out of business overnight.
While all can agree that children caught up in the commercial sex industry need help, there are many differing views about how best to help sexually exploited children.
Those who push legislation that decriminalizes prostitution for minors contend that arresting these victims further traumatizes them. Proponents of decriminalization want to totally remove the possibility of arrest. They argue that what the children need are services directed towards restoring their dignity and rehabilitating them out of a life of selling sex. They want this accomplished outside the juvenile justice system.
Others strenuously argue that removing the discretion of law enforcement, district attorneys, and judges from the process takes away one of the most effective means of rescuing children; they say that taking law enforcement out of the picture is not the answer. These children’s advocates argue that a comprehensive approach is necessary and accomplished by leaving every available option on the table to help these children, including arrest and detention, to ensure the evaluation and handling of their situations on a case-by-case basis.
The issue is complex, encompassing not only the legal and social service systems, but also cultural attitudes. Public awareness and understanding of the issue is a necessary step towards helping minors trapped in prostitution.
What are the terms used to discuss this issue?
Abolition: Abolitionists believe all prostitution is harmful and strive for the eradication of prostitution and sex trafficking. Abolitionists target the demand, for without demand there would be no prostitution and therefore no sex trafficking (which occurs when demand exceeds the supply of women and children).
Criminalization: Criminalization makes it illegal to buy and sell sex. Except for several rural counties in Nevada, prostitution is criminalized in the United States. At the federal level, the Trafficking Victims Protection Act and its subsequent reauthorizations criminalize pimping and procuring and take an abolitionist approach towards demand while providing assistance for victims.
Decriminalization: Decriminalization changes that which is currently illegal into something that is no longer a crime. The proposals in Georgia and Connecticut seek to recognize all minors in prostitution as victims, not criminals. It would still be a crime to pimp, traffic, or buy a child in prostitution. New Zealand decriminalized adult prostitution in 2003, and since then, street prostitution has increased, as has the prostitution of children.1 Sweden targeted demand by going after the johns, thereby criminalizing the buying of sex and decriminalizing the selling of sex.
Legalization: Legalization makes prostitution legal and entails government regulation and taxation of those involved. Germany and The Netherlands have legalized prostitution. In both countries sex trafficking increased and organized crime is prevalent. Germany had hoped to see an increase in tax revenues, but that did not happen. 2 (Apparently, those in organized crime do not believe in paying taxes.)
Sex trafficking: The Trafficking Victims Protection Act of 2000 (Public Law 106-386) breaks sex trafficking down into two categories – severe sex trafficking and sex trafficking. The definitions, which also include a definition for forced labor, read:
SEVERE FORMS OF TRAFFICKING IN PERSONS. – The term ”severe forms of trafficking in persons” means –
(A) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age; or
(B) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
SEX TRAFFICKING. – The term ”sex trafficking” means the recruitment, harboring, transportation, provision, or obtaining of a person for the purpose of a commercial sex act.
It is important to note that where there is prostitution, there will be sex trafficking. When the supply of prostitutes cannot meet the demand for prostitutes $mdash; as is typical in the more developed nations where girls and women have attractive schooling and career options – vulnerable people are forced into sex slavery. The vulnerable ones include children because pimps/traffickers can now earn even more money by supplying younger girls to fill the johns’ demands for girls that they believe are free of diseases and their appetite for younger and younger girls. The only solution for the increased demand that leads to sex trafficking is abolition, ending the commercial sex industry.
Those who advocate decriminalization have much to learn from those countries that have tried decriminalization or legalization.
After legalization in Victoria, Australia, there was a 300 percent increase in illegal brothels. 3 The Dutch saw an increase in trafficking victims from 716 in 2007 to 809 in 2008; almost 40 percent of those victims were Dutch girls pimped out by their boyfriends. 4 Approximately 63 percent of the estimated 400,000 prostitutes in Germany are migrants, meaning German women do not want to prostitute, so they have to bring in women from other countries, an environment ripe for sex traffickers to exploit. 5 In 1995, Spain decriminalized prostitution. By 2008, Spain’s Equality Ministry said 80 percent of prostitutes in Spain came from places including China, Romania and Latin America – many coerced by gangs. 6
The United States does not fare much better in those Nevada counties where prostitution is legal. As shown above, where there is legal prostitution, illegal prostitution flourishes. In 2009, Nevada’s Governor Jim Gibbons signed Assembly Bill 380 into law, which establishes the toughest punishments in the nation for child prostitution and pandering. The Las Vegas Metro Police handled 150 cases of child prostitution in 2008 – and the prostitution of adults is not legal in Las Vegas, much less children. 7 Johns are drawn to Nevada’s adult prostitution, but pimps cater to all their whims.
There are few concrete numbers detailing the extent of the child prostitution industry in the United States, but one of the places containing arrest data for minors in prostitution is the Federal Bureau of Investigation’s Uniform Crime Reports (UCR). One of the reports breaks down arrests in prostitution and commercialized vice by state into two categories – those over the age of 18 and those under 18. 8 A more detailed report goes further by breaking the categories down to under 15 and under 18. 9 These reports do not specify who is arrested – whether the arrestee is the pimp, the john, or the prostitute. However, Concerned Women for America (CWA) crafted an amendment in the Trafficking Victims Protection Reauthorization Act of 2008 that mandates the disaggregation of these arrest figures into categories representing john, prostitute, and pimp. 10
CWA believes that when these numbers are broken out, it will show a disproportionate number of prostitutes are arrested, some johns, and very few pimps/traffickers. This arrest strategy is not effective in ending the demand for prostitution. Arresting and shaming johns will go a long way towards ending demand. In fact, a recently released study in England, “Men Who Buy Sex,” asked johns what would deter them. Their answers were prison time, public exposure, or being issued an Anti-Social Behavior Order (ASBO). 11
While it does not break down the Prostitution and Commercialized Vice category into john, pimp, and prostitute, the 2008 Uniform Crime Report (UCR) does break down the arrests by sex and by age. According to the arrest table by sex, 12 about 31 percent of the arrests were males, while females made up almost 70 percent. It would seem that arrested prostitutes far outnumber pimps and johns. When the breakdown is by age, 13 1,158 minors under the age of 18 were arrested for prostitution (two percent of all arrests for prostitution), and of those, 129 were under the age of 15. The arrest by state table shows Georgia had 31 arrests of minors under 18 and Connecticut had four. California had the most with 487, Texas followed with 139, Nevada had 63, the state of Washington had 54, and Florida rounded out the top five with 53. 14
Those who advocate the decriminalization of prostitution for minors do not want any child arrested for prostitution. Given that only two percent of all arrests for prostitution are minors, it appears law enforcement officers are not arresting great numbers of minors. The UCR does not detail what happened to those minors after arrest. The officers may have arrested them to separate them from their pimps but handled the issue within the department and released them or, if they were repeat offenders, perhaps put them into the juvenile court system.
Oakland, California, has the reputation for being a hub of underage sex trafficking. The way they currently handle the prostitution of minors is for the Oakland Police Department (OPD) to arrest them, temporarily incarcerate them, and offer them social services. The OPD has had a Child Exploitation Unit since 1999, and its Commander, Lieutenant Kevin Wiley, explains the reasoning for the process, “Most are sent to Juvenile Hall as a protective measure, since it is our experience these victims run back to their pimps or at least back to the streets or the ‘game.’” 15
Ursula Dickson, an Alameda County deputy district attorney, says that once minors are sent to Juvenile Hall they are paired with an advocate. Probation officials determine how to process the case; they can close it and refer the girls to support services or send it on to the District Attorney’s office for charging. 16
The District Attorney’s (DA) office received authorization to create a pilot program that would be a diversion program for sexually exploited youth, away from incarceration and into counseling and support services. This is not decriminalization, though, because not every minor will qualify. Judicial discretion is part of the process. The program would begin after a minor’s arrest, and if juveniles qualify for the program, they would be released into their parents’ home, foster care, or a group home and be required to attend classroom instruction two days a week for twelve weeks. Minors with multiple arrests will more than likely remain in Juvenile Hall because DA office experience has shown that pimps will send girls to foster homes and group homes to recruit others. Dickson said, “For lack of a better word, we don’t want this to become recruiting grounds.” 17
One argument, as referenced above, for keeping the law against minors involved in commercial sex in place is that sometimes arresting a minor for prostitution and putting them into the system separates them from their pimp long enough for them to realize they need help. Pimps are master manipulators, and they seek out vulnerable children, who often come from broken homes. They start out slowly with the girls and pretend to be boyfriends. Over time, they groom them to prostitute. By that time, the girl looks at the pimp as the only person who loves her, cares for her, and provides for her.
Another argument for keeping the law in place is that it sets a community standard that prostitution is not acceptable. In recent years, stories have appeared that talk about teens selling themselves for sex to earn money for shopping, drugs, and luxury goods. In Hong Kong, it is called “compensated dating,” and teens are trading sex for money. 18 A story last year discussed British schoolgirls working shifts at escort agencies to earn money to buy designer clothes, CDs, iPods, alcohol, and cigarettes. 19 Sharlene Azam has a documentary and book, Oral Sex is the New Goodnight Kiss, wherein she explores the recent emergence of teen prostitution in affluent suburbs in Canada. 20 If it is happening in Hong Kong, Britain, and Canada, it could be happening here.
A recently released study from the University of New Hampshire found that of the juvenile cases studied, thirty-one percent of the cases were solo prostitution, meaning they had no pimp. Fifty-seven percent of cases involved a third-party exploiter and twelve percent of the cases involved child abuse with payment. 21 Some of the thirty-one percent with no pimp are most likely runaways that engage in survival sex or drug addicts in need of money to support their habit and some have a history of child sexual abuse that leaves them at risk for prostitution. However, some choose to do it for other reasons.
Decriminalization for minors sends a message to those thirty-one percent who may choose to prostitute, saying that their behavior is acceptable and without legal consequences. Teenagers can make some terrible decisions due to their youth and inexperience, and the law should not make it easier for them to experiment in this dangerous world of commercial sexual exploitation.
There are always johns out there who will pay to have sex with a minor. To reiterate, johns are criminals who should be arrested and prosecuted every time they are caught. A teen may start out as a solo participant, but all it takes is a pimp to find them, and then they are trapped. Decriminalization also sends a message to the pimps that it is less risky to pimp minors; they will coach their girls to say they are under 18, and the police will not pursue it further. Pimps are very deft at locating vulnerable children and drawing them into their web of destruction; decriminalization for minors hands them yet another recruiting tool.
How are other states handling the issue of minors in prostitution?
In 2008, New York passed the Safe Harbor for Exploited Children Act. 22 The bill recognized that most minors in prostitution are victims and declares them “persons in need of services” (PINS) instead of criminals. The law goes into effect on April 1, 2010, but there are questions as to how many beds are available statewide for victims. The law requires each local social service district to provide a short-term safe house for victims – if funds are available. Funding is scarce in this economy, and this may not be a priority for localities.
New York’s Safe Harbor Act presumes a person under the age of 18 charged with prostitution is a severely trafficked person according to the TVPA definition. However, the law gives discretion to judges. If the judge determines the minor does not meet the definition of a severely trafficked person, has previously committed a prostitution offense, has previously been placed with a local social service commissioner as a PINS, or is not willing to participate in services ordered by the court, the judge may continue with a Juvenile Detention petition.
Allowing judges to have the discretion enables them to assess individual cases and choose the course they think will best assist the minor found in prostitution. For many, that path will lead to services and rehabilitation when available. For some, that path will lead to juvenile detention for reasons that could include the fact that they do not see themselves as victims and may need time in detention, separate from their pimp, to see things differently and prevent them from running back to their pimp. For some, it may be a case like those discussed in Oral Sex is the New Goodnight Kiss, where girls prostitute to afford luxuries. These girls need to learn that prostitution for any reason is a wrong and harmful decision and that there are consequences for engaging in this behavior. Others need separation from other victims because they are using their time in contact with them to recruit for their pimp, or they may be violent towards the other girls.
There is no one-size-fits-all solution to the problem, and keeping the laws in place that criminalize prostitution gives one more tool to law enforcement and the judiciary to combat prostitution and sex trafficking and find help for the victims. It gives the police the right to investigate suspected prostitution offenses, giving them access to victims. Prosecutors can utilize prosecutorial discretion in handling the cases brought to them by law enforcement; they may choose not to prosecute every case.
Rhode Island recently passed a law that closes the loophole on indoor prostitution and adds a provision that helps those who are pimped or trafficked. Since the 1980s, the Rhode Island law made outdoor prostitution illegal, but indoor prostitution legal. With the closing of the loophole, Rhode Island added an affirmative defense for those charged with prostitution who are under the control of a pimp/trafficker. At least two other states, New Jersey and Minnesota, also have affirmative defense in their laws. Section 11-34.1-2 (d) of the Rhode Island General Laws23 reads,
“In any prosecution for a violation under this section it shall be an affirmative defense if the accused was forced to commit a commercial sexual activity by:
Being threatened or, subjected to physical harm; Being physically restrained or threatened to be physically restrained Being subject to threats of abuse of law or legal process; Being subject to destruction, concealment, removal or confiscation, of any passport or other immigration document, or any other actual or purported governmental identification document; or Being subject to intimidation in which the accused’s physical well being was perceived as threatened.”
In addition, the new law adds a section which, at the court’s discretion, 24 allows for the criminal records for persons convicted under Section 11-34.1-2 (Prostitution) or 11-34.1-4 (Loitering for prostitution) to be expunged after one year. This means that an arrest for prostitution will not follow people for the rest of their lives if they have escaped and been rehabilitated. Both the affirmative defense and the expunging of records are tools that help those victimized in the commercial sex industry and keep judicial discretion in the process.
Connecticut proposed new legislation this year that offers an affirmative defense for adults who are coerced, but it went a step further with minors. “In any prosecution of a person under the age of seventeen for an offense under this section, there shall be a presumption that the actor was coerced into committing such offense by another person in violation of section 53a-192a.” 25
According to an article about this, the state Judicial Branch reports that between 2001 and 2008 only two 15-year-old girls were charged, and neither was convicted. Francis Carino, the state’s supervisory juvenile prosecutor said, “I don’t ever recall prosecuting a minor for prostitution. It’s just not something we see in juvenile court.” 26
Georgia recently introduced Senate Bill 304, 27 which in its first format decriminalized prostitution outright for minors 16 and under. When opposition to this move increased, substitute language was introduced that removes judicial discretion from the matter, deems minors under 18 subjected to sexual exploitation to be “unruly children” under the corresponding Georgia code (section 15-11-2), and places them straight into the Governor’s Office for Children and Families’ system of care (Georgia Care Connection). What this substitute bill language does is in essence decriminalize prostitution for minors under 18 as it bypasses the judicial system.
Georgia deserves praise for establishing a system of care; victims of sex trafficking and sexual exploitation need medical services, a safe shelter and counseling, to name a few things. However, by excluding the judicial system from all minors found in prostitution, the Georgia Care Connection will be responsible for providing complete services for these minors. It is not clear how the children will remain in the system if they do not wish to be in care. They are not charged with a crime, so completion of the program is not conditional on anything, especially getting rid of a charge. The bill language also does not address what happens to repeat offenders or those who are violent.
In December 2009, the Governor’s Office for Children and Families announced that the Georgia Care Connection does not have sufficient funding.
“One of the first milestones for this state initiative was the establishment of the Georgia Care Connection Office, designed to connect victims to essential services and support. However, a challenge has emerged in maintaining adequate funding so that these girls can remain in a safe house treatment setting as long as needed to receive the services vital for recovery. To address this challenge, the Georgia Care Connection Office has established the Safety Gap Fund with Community Foundation for Northeast Georgia to cover the gap for girls who need residential care but have no other source of funding. The Georgia Care Connection Office is asking for community partners to make a contribution in an effort to raise $1.6 million to match what GOCF has already budgeted to address the needs of victims. GOCF supports this public-private partnership in ensuring that all victims receive the services and care they need, and believes that any monetary contribution can make a significant impact.” 28
According to the same article, they estimate that 374 girls are sexually exploited in Georgia each month. Through this program, they have identified 25 girls as needing help; half of these girls are in the custody of their parents. At a cost of $5,600 a month for safe residential treatment, they will need almost $1.7 million a year to support these 25 girls. They have created the Safety Gap Fund to ask for donations to support the care of these girls. 29 If Georgia Senate Bill 304 passes, where will the funds come from to support more victims?
New York also confronts a funding challenge. The Safe Harbor Act went into effect April 1, 2010. It is not clear how many beds are available in New York. No one knows the answer. The Safe Harbor Act makes the provision of shelters in localities dependent on available funding. There is at least one residential shelter in New York, Girls Educational and Mentoring Services (GEMS), founded by Rachel Lloyd. Miss Lloyd recently gave testimony at the Senate Judiciary Committee, Subcommittee on Human Rights and the Law. 30 She addressed the issue of available beds nationally when she said, “Currently there are less than 50 beds specifically for victims of commercial sexual exploitation and domestic trafficking and approximately a dozen specialized service providers. Many states do not have any specialized services at all, and those of us who are directly serving victims do so with a scarcity of resources and support. Monies allocated in the TVPRA for services for domestic victims have yet to be appropriated.”
A 2007 study done for Health and Human Services echoed the same number. The study identified only four residential facilities in the United States that help children who survive commercial sexual exploitation. They are GEMS with nine beds, Standing Against Global Exploitation (SAGE) in San Francisco with six beds, Children of the Night in Van Nuys, California, with twenty-four beds, and Angela’s House in Georgia with six beds. 31
The Trafficking Victims Protection Act of 2005 (Public Law 109-164) authorized funding for shelters for minors, but the money has never been appropriated. 32 The bill authorized $10 million for fiscal year (FY) 2006 and $10 million for FY 2007 to establish grant programs to assist U.S. citizens who are victims of human trafficking. The bill also authorized $5 million for FY 2006 and $5 million for 2007 to establish a pilot program for residential treatment facilities in the United States for juvenile victims. If both of those provisions had been funded since 2006, there would be more resources available for the treatment of victims. Unfortunately, Health and Human Services will not be adding them to their FY 2011 request either. 33
The William Wilberforce Trafficking Victims Protection Act of 2008 (Public Law 110-457) authorized a new program to provide services to U.S. citizen survivors of human trafficking. 34 The program was authorized for $2.5 million in 2008, $5 million for 2009 and $7 million each for 2010 and 2011. So far, these authorizations have not been appropriated. According to the Department of Health and Human Services, the funds they appropriate are for international victims located in the United States, not U.S. citizens or legal aliens who have been victims of human trafficking. 35
So how do we best help minors involved in prostitution and sex trafficking?
First and foremost, go after demand and arrest johns. If there were no johns paying for commercial sexual exploitation, there would be no sex trafficking. In the “Men Who Buy Sex” study on johns, the johns admitted that being arrested and convicted of purchasing sex would deter them from further action, as would the possibility of being exposed publicly. Posting photos of convicted johns on police websites would go a long way towards ending demand. Shielding johns from public scrutiny of their shameless choice to exploit someone must end.
In addition to arresting and prosecuting johns, why not make them testify against pimps and traffickers if they are arrested during the same bust? Johns may have observed the pimp threatening the prostitute. Or in a brothel, the john may have seen evidence of slavery. Prostitutes are often made to give evidence and/or testify against their pimps/traffickers, so why not require testimony from the other party to the crime?
Training for law enforcement on how to recognize victims and interview them is also a priority. Law enforcement officers are more likely to come across victims than most people are. A culture shift must occur: Instead of blaming the women and children involved in prostitution, the pimps deserve the blame. It is not a normal response to think it is okay to buy or sell another human being. The police should be looking to arrest exploiters in droves.
The federal government should fund the shelters authorized in the Trafficking Victims Protection Acts. Localities need to make shelters a priority if they have identified child prostitution in their area. Without a system of care in place, how can you help victims? Laws written to help victims should establish and fund the support system for them; there should be no unfunded mandates.
Shelters will not be appropriate for every minor found in prostitution. Many victims do not self-identify as victims and will head right back to their pimp upon release or will run away from the shelter. Some will be sent into systems to recruit other victims for their pimp. Some will be violent and need special care. For those cases, keeping the option of juvenile detention allows for judicial discretion in each individual case.
The TVPRA of 2008 added a section36 that gives victims of sex trafficking the right to receive restitution from their exploiters in the form of assets forfeited in trafficking cases. Such laws are in addition to another provision that expands a victim’s right to bring civil action against his or her perpetrators, as established in the TVPRA of 2003 (Public Law 108-193), 37 to being able to bring a civil action against anyone who knowingly benefits from participating in trafficking.
Restitution provisions are important for several reasons. First, any assets forfeited by traffickers render the business of trafficking less profitable. It reduces the incentives and increases the risk of engaging in trafficking. Second, it transfers the wealth made off the backs of victims to the victims, which helps in their restoration process. It is empowering to victims to receive restitution from their exploiters. The third reason it is important is that it signifies the arrest and conviction of a pimp/trafficker. Catching, prosecuting, convicting, and disgorging pimps/traffickers’ ill-gotten gains would send a strong signal to others that they are no longer safe from arrest and prosecution.
It is also up to the public to stop buying into the normalization and glamorization of prostitution and pimping. Movies and television shows make light of these crimes and, in fact, portray them as a glamorous way of life. Children absorb these messages, and adults do not disabuse them of the notion that it is not normal or acceptable. How many movies and TV shows make jokes of a boy going to a prostitute or watching pornography as a rite of passage into manhood? The message should be that real men do not buy sex or watch the exploitation of women and children.
There is no one-size-fits-all solution to the problem of commercial sexual exploitation of children. Keeping the laws on the books, training law enforcement, and creating shelters for victims should all be part of the plan to help get minors out of prostitution. Arresting minors in prostitution and sex trafficking but not making counseling and support services available to them will leave them without help to create a better future. Decriminalizing prostitution for minors will leave them at the mercy of pimps and johns and without the judicial system to advocate for their treatment and rehabilitation. The system in Oakland, California, shows that, with proper training, law enforcement can be compassionate, understanding, and provide resources to help; the District Attorney’s office can use its discretion as to which cases to charge and which to go to support services outside of the juvenile detention system; and the juvenile detention system can provide counseling and support services for the minors in it.
Lieutenant Wiley of the Oakland Police Department sums up the emerging attitude best. He said, “It has changed from the old days of just ‘Hook em up, lock em up, don’t look back,’ to ‘Hey, we may have a victim here.’” 38
Melissa Farley, “What really happened in New Zealand after prostitution was decriminalized in 2003?” Prostitution Research and Education, undated, http://www.prostitutionresearch.com/Report%20on%20NZ%2010-29-2008.pdf, (accessed March 18, 2010). Margreet Strijbosch, “Legalised prostitution: a dying trade,” Radio Netherlands Worldwide, October 31, 2006, http://www.rnw.nl/english/article/legalised-prostitution-dying-trade, (accessed March 23, 2010), and Donna M. Hughes, “Prostitution: Causes and Solutions,” presentation given in Santiago de Compostela, Galicia, Spain, July 1-3, 2004, http://www.uri.edu/artsci/wms/hughes/prostitution_spain_july04.pdf, (accessed March 23, 2010). Melissa Farley, “Myths and Facts about Trafficking for Legal and Illegal Prostitution,” Prostitution Research and Education (March 2009), http://www.prostitutionresearch.com/Myths%20&%20Facts%20Legal%20&%20Illegal%20ProstitutionMelissaFarley3-09.pdf, (accessed March 18, 2010). “More Victims of People Trafficking Recorded,” DutchNews.nl, (February 6, 2009), http://www.dutchnews.nl/news/archives/2009/02/more_trafficking_victims_found.php, (accessed March 18, 2010). CBC News, “German Brothels Raided in Trafficking Probe,” February 3, 2010, http://www.cbc.ca/world/story/2010/02/03/germany-trafficking.html, (accessed March 18, 2010). Sharon Smyth, “Spain Targets Sex Traffickers with Aid to Prostitutes,” Bloomberg.com, December 19, 2008, http://www.bloomberg.com/apps/news?pid=newsarchive&sid=aSFKnVv0hINA, (accessed March 18, 2010). Jeff Pope, “New law levies harsher child prostitution punishment,” Las Vegas Sun, June 22, 2009, http://www.lasvegassun.com/news/2009/jun/22/new-law-levies-harsh-punishments-child-prostitutio/, (accessed March 18, 2010). Department of Justice, Federal Bureau of Investigation, Uniform Crime Report, 2008 Crime in the United States, Table 69, “Arrests, by State, 2008,” September 2009, http://www.fbi.gov/ucr/cius2008/data/table_69.html, (accessed March 18, 2010). Department of Justice, Federal Bureau of Investigation, Uniform Crime Report, 2008 Crime in the United States, Table 38, “Arrests, by Age, 2008,” September 2009, http://www.fbi.gov/ucr/cius2008/data/table_38.html, (accessed March 18, 2010). The amendment can be found in Section 237(b) of the William Wilberforce Trafficking Victims Protection Act of 2008. Melissa Farley, Julie Bindel and Jacqueline M. Golding, “Men who buy sex, Who they buy and what they know,” Eaves, London and Prostitution Research & Education, San Francisco, December 2009. Department of Justice, Federal Bureau of Investigation, Uniform Crime Report, 2008 Crime in the United States, Table 42, “Arrests, by Sex, 2008,” September 2009, http://www.fbi.gov/ucr/cius2008/data/table_42.html, (accessed March 18, 2010). Department of Justice, Federal Bureau of Investigation, Uniform Crime Report, 2008 Crime in the United States, Table 41, “Arrests, Persons Under 15, 18, 21, and 25 Years of Age, 2008,” September 2009, http://www.fbi.gov/ucr/cius2008/data/table_41.html, (accessed March 18, 2010). Department of Justice, Federal Bureau of Investigation, Uniform Crime Report, 2008 Crime in the United States, Table 69, “Arrests, by State, 2008,” September 2009, http://www.fbi.gov/ucr/cius2008/data/table_69.html, (accessed March 18, 2010). Mary K. Flynn, “As more Oakland youth join the sex trade, law enforcement explores alternatives to incarceration,” Oakland North, March 14, 2010, http://oaklandnorth.net/2010/03/13/as-more-oakland-youth-join-the-sex-trade-law-enforcement-explores-alternatives-to-incarceration/, (accessed March 18, 2010). Ibid. Ibid. Pauline Chiou, “Girls sell sex in Hong Kong to earn shopping money,” CNN, October 13, 2009, http://edition.cnn.com/2009/WORLD/asiapcf/09/24/hongkong.teenage.prostitution/, (accessed March 23, 2010). John Marrs, “Scandal of Playground Prostitutes,” Daily Star, February 27, 2009, http://www.allbusiness.com/society-social-assistance-lifestyle/sex-gender-issues/11984121-1.html, (accessed March 23, 2010). Sharlene Azam’s website for the documentary and book is http://www.thenewgoodnightkiss.com/index.html (accessed March 23, 2010). Kimberly J. Mitchell, David Finkelhor, and Janis Wolak, “Conceptualizing Juvenile Prostitution as Child Maltreatment: Findings from the National Juvenile Prostitution Study,” Child Maltreatment 15, no. 1, February 2010. New York Consolidated Laws, Article 6, Title 8-A, http://public.leginfo.state.ny.us/menugetf.cgi?COMMONQUERY=LAWS (accessed March 22, 2010). Rhode Island General Laws, Title 11, Chapter 11-34.1-2, http://www.rilin.state.ri.us/Statutes/TITLE11/11-34.1/11-34.1-2.HTM, (accessed March 22, 2010). Rhode Island General Laws, Title 11, Chapter 11-34.1-5, http://www.rilin.state.ri.us/Statutes/TITLE11/11-34.1/11-34.1-5.HTM, (accessed March 22, 2010). State of Connecticut, Raised Bill No. 153, “An Act Providing Safe Harbor for Exploited Children,” February Session 2010 http://www.cga.ct.gov/2010/TOB/S/2010SB-00153-R00-SB.htm, (accessed March 23, 2010). Christian Nolan, “A Move To Decriminalize Teen Prostitution,” Connecticut Law Tribune, March 8, 2010, http://www.ctlawtribune.com/getarticle.aspx?ID=36513, (accessed March 18, 2010). Georgia General Assembly, Senate Bill 304, January 2010, http://www.legis.state.ga.us/legis/2009_10/fulltext/sb304.htm, (accessed March 18, 2010). “Unprecedented Private-Public Collaboration to Support Victims of Child Prostitution in Georgia,” Governor’s Office for Children and Families, press release, December 29, 2009, http://children.georgia.gov/gta/mcm/content/article_print_front/0,2089,113927404_113969896_154679596,00.html, (accessed March 18, 2010). Interfaith Children’s Movement webpage link to information about the Safety Gap Fund, http://icmma.org/LinkClick.aspx?fileticket=E%2B6%2BwvrW09o%3D&tabid=149, (accessed March 18, 2010). Rachel Lloyd, testimony before Senate Judiciary Committee, Subcommittee on Human Rights and the Law, In Our Own Backyard: Child Prostitution and Sex Trafficking in the United States, 111th Cong., 2nd session, 24 February 2010, http://judiciary.senate.gov/pdf/10-02-23Lloyd’sTestimony.pdf, (accessed March 22, 2010). Heather J. Clawson and Lisa Goldblatt Grace, September 2007, “Finding a Path to Recovery: Residential Facilities for Minor Victims of Domestic Sex Trafficking.” Part of a larger project, Study of HHS Programs Serving Human Trafficking Victims, prepared for the Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services, http://aspe.hhs.gov/hsp/07/humantrafficking/ResFac/ib.pdf, (accessed March 22, 2010). 22 U.S.C. 7105, http://www.law.cornell.edu/uscode/22/usc_sec_22_00007105—-000-.html, (accessed March 22, 2010). U.S. Department of Health and Human Services, Administration for Children and Families, Justification of Estimates for Appropriations Committee, “Significant Items,” 397, http://www.acf.hhs.gov/programs/olab/budget/2011/significant_items.pdf, (accessed March 22, 2010). 22 U.S.C. 7110, http://www.law.cornell.edu/uscode/html/uscode22/usc_sec_22_00007110—-000-.html, (accessed March 22, 2010). U.S. Department of Health and Human Services, Administration for Children and Families, Justification of Estimates for Appropriations Committee, “Refugee and Entrant Assistance,” 236, http://www.acf.hhs.gov/programs/olab/budget/2011/ORR.pdf, (accessed March 22, 2010). The William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Section 221, codified in 18 U.S.C. 1593. The Trafficking Victims Protection Reauthorization Act of 2003, Section 4(a)4(A), codified in 18 U.S.C. 1595. Mary K. Flynn, “As more Oakland youth join the sex trade, law enforcement explores alternatives to incarceration,” Oakland North, March 14, 2010, http://oaklandnorth.net/2010/03/13/as-more-oakland-youth-join-the-sex-trade-law-enforcement-explores-alternatives-to-incarceration/, (accessed March 18, 2010).