Background
Nawomi Awoga and her adult daughters, Marina Oke and Assiba Lea Fandohan, arranged for two girls, ages 11 and 14, to travel from Benin to the United States in 2014 using false identities and a fabricated story for immigration officials. The girls’ families had been promised educational and work opportunities, but the girls did not attend school after arriving in Illinois.
According to testimony the jury credited, the defendants instead required the girls to perform extensive housework and childcare, subjected them to physical and psychological abuse, restricted their movements and communications, and concealed them from outsiders and law enforcement. After the girls separately escaped, a federal jury convicted all three defendants of conspiring to harbor and shield unauthorized aliens, harboring and shielding unauthorized aliens, and forced labor. The jury also found the financial-gain enhancement applicable to Oke and Fandohan. The district court imposed prison terms of 102 months for Awoga, 94 months for Oke, and 80 months for Fandohan.
The Court’s Holding
The Seventh Circuit affirmed. Reviewing the denial of the defendants’ acquittal motions under the highly deferential sufficiency-of-the-evidence standard, the court held that the victims’ testimony was not incredible as a matter of law. Inconsistencies, possible motives arising from immigration and government benefits, and other impeachment evidence were presented through cross-examination and proper jury instructions, leaving credibility for the jury to decide. The testimony was also supported by falsified identification documents, travel records, photographs, and other witnesses.
The evidence permitted a rational jury to find that the defendants intended to shield the girls from authorities, including by directing them to hide, limiting their outside contact, withholding school and medical care, and moving one girl after officers searched for her. The evidence of unpaid household labor and childcare also supported the financial-gain findings against Oke and Fandohan. Challenges to the conspiracy and forced-labor convictions were waived because the defendants did not develop them on appeal, as was any challenge to the denial of their motions for a new trial.
The court also held that the sentences were substantively reasonable. Awoga’s sentence fell within her Guidelines range, while Oke’s and Fandohan’s were below their respective ranges. The district court adequately considered the defendants’ mitigation arguments and reasonably balanced them against the crimes’ duration, planning, multiple minor victims, and other aggravating circumstances. It did not abuse its discretion by declining to treat asserted Beninese cultural norms as mitigating conduct governed by United States law.
Key Takeaways
- Attacks on witness credibility ordinarily cannot establish insufficient evidence when impeachment was fully presented and the jury nevertheless credited the testimony.
- Instructions to hide, restrictions on movement and communication, denial of school and medical care, and relocation after police scrutiny supported an inference of intent to shield unauthorized immigrants from detection.
- Free household labor and childcare can constitute private financial gain even when defendants provide food, clothing, lodging, or limited compensation.
- A disagreement with how a sentencing judge weighed mitigating and aggravating factors does not establish substantive unreasonableness.
Why It Matters
The decision illustrates the demanding standard for overturning convictions on sufficiency grounds, particularly when an appeal asks the court to revisit credibility determinations entrusted to the jury. Testimony does not become incredible as a matter of law merely because it was impeached or contained inconsistencies.
The opinion also confirms that harboring liability can rest on a broader course of concealment and exploitation rather than simple sheltering, and that the economic value of unpaid domestic work may support a statutory financial-gain enhancement.