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Name: People v. Guyton
Case #: G053662
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 02/14/2018

There was substantial evidence that defendant restricted a person’s individual liberty sufficient to sustain a human trafficking conviction when he isolated her, constantly monitored her, and kept her financially dependent. Guyton was arrested after a woman reported that he had forced her to work as a prostitute for 5 months, collected most of her earnings, and kept her toddler son away from her, granting short visits only when he permitted based on how much money she earned. A jury convicted Guyton of human trafficking (Pen. Code, § 236.1) and related charges. On appeal, he challenged the human trafficking conviction, arguing that there was insufficient evidence that he violated the woman’s personal liberty. Held: Affirmed. A person who deprives or violates the personal liberty of another with the intent to obtain forced labor or services is guilty of human trafficking. (Pen. Code, § 236.1, subd. (a).) Deprivation or violation of an individual’s personal liberty includes substantial and sustained restriction accomplished through force, fear, fraud, deceit, coercion, violence, duress, menace, or threat of unlawful injury to the victim or another person. (Pen. Code, § 236.1, subd. (h)(3).) Guyton argued that the woman was not abducted and could have walked away at any time. However, the Court of Appeal determined that the various restrictions Guyton placed on her (such as isolating her, constantly monitoring her, requiring her to stay in contact with him, depriving her of the financial means to live, and keeping her baby away from her) constituted substantial evidence of Guyton’s sustained restriction of her liberty accomplished through force, fear, fraud, deceit, duress, and menace. The court also included there was no basis for an instruction on the lesser included offense of attempted human trafficking.

The full opinion is available on the court’s website here: