argumentative essay human trafficking

Human Trafficking Essay Topics, Outline, & Example [2024]

“People for sale” is a phrase that describes exactly what human trafficking is. It also makes for an attention-grabbing title for an essay on this subject. You are going to talk about a severe problem, so it’s crucial to hook the reader from the get-go.

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A human trafficking essay is an assignment where you discuss causes, effects, or potential solutions to the problem of modern slavery. A well-written essay can help raise awareness of this complicated issue.

In this article by our custom writing experts, you will find:

• 220 human trafficking essay topics;
• a writing guide;
• an essay sample;
• helpful info on human trafficking.
• 🔝 Top 10 Topics
• ❓ What Is Human Trafficking?
• ✍️ Topics for Any Essay Type
• 📝 Essay Outline
• 📑 Essay Sample
• ✏️ Frequent Questions

🔝 Top 10 Human Trafficking Essay Topics

• History of slavery.
• Slavery in literature.
• Human trafficking awareness.
• Modern slavery: legislation.
• Cultural background of traffickers.
• Globalization and human trafficking.
• Human trafficking vs. human rights.
• Modern slavery and kidnapping.
• Human trafficking rates by country.
• Human trafficking effects on the economy.

❓ What Is Human Trafficking?

The United Nations Convention against Transnational Organized Crime determines human trafficking as the recruitment, transportation, harboring, or receipt of persons for the purpose of sexual slavery, exploitation, forced labor, organs removal, etc.

According to the recent reports of the Council of Europe,  human trafficking rates have reached epidemic proportions . Millions of people are being trafficked for different reasons, primarily for sexual exploitation and forced labor. Women and children are the primary victims of human trafficking , which makes the problem especially acute.

One of the most worrying factors that directly impact the increase in trafficking rates is the growing number of refugees and migrants. It’s the largest seen since WWII, and it has intensified during the last years.

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Types of Human Trafficking

Before you start writing your essay, it’s essential to review the forms of human trafficking. Knowing them will help you see the bigger picture. Here are the most common ones.

Additionally, victims of human smuggling and child trafficking are often involved in various kinds of labor. While sexual exploitation is one of the major reasons for trafficking, it’s not the only one. These are also serious problems that you can focus on in your essay.

According to Polaris Project, there are 25 types of modern slavery . Among them are:

• Manufacturing in sweatshops;
• Agricultural work;
• Food and cleaning services;
• Beauty and massage salons.

Note that each of these practices has unique traits. It means there are specific methods of recruitment and control associated with them. Make sure to take all essential features of human trafficking into account when writing your essay.

The History of Human Trafficking

If we go back in time, we can see that human trafficking has a long history. Here are some of its milestones:

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As you now know, human trafficking is inextricably linked to other crimes against human rights. And the eradication of this phenomenon depends on both governments and ordinary citizens.

What Is Being Done to Stop Human Trafficking

In recent decades, a lot has been done to curb slavery. The United Nations General Assembly has established the World Day against Trafficking in Persons on July 30 . It was done to raise awareness of the situation and promote and protect victims’ rights.

One of the essential frameworks used to combat human trafficking is the 3P: prosecution, protection, and prevention .

Sometimes “ partnership ” is added as the fourth P. Since human trafficking became a pandemic, it requires a combined effort of people working together to overcome this problem. You can learn more about the 3P paradigm from this article by the US Department of State .

You may ask, “What can I do?” Here are some ways in which anyone can help fight human trafficking:

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• In each country, there is a hotline where you can report on a known case of human trafficking or an attempt at recruiting.
• Be attentive to various kinds of controversial proposals and promises of a better life.
• Try to avoid bad company.

These recommendations may seem simple, but they can help you stay away from danger, spread awareness, and even save lives.

Before you start writing a human trafficking essay, you need to find a compelling topic. Check out the following list of topics and prompts and choose a subject that interests you.

✍️ Human Trafficking Topics for Any Essay Type

Human Trafficking Argumentative Essay Topics

• We should let survivors inform the public about the dangers of trafficking.
• State laws should protect the rights of trafficking survivors.
• Victim behavior is not the reason for the actions of criminals.
• Present medical facts about the ability of humans to survive a trauma .
• What psychological techniques do criminals use to lure victims?
• School is a safe haven for children from disadvantaged families.
• High social status is not a guarantee of protection against traffickers.
• Deception as a tool for controlling victims of modern slavery.
• Family can provide significant support to a victim of human trafficking.
• Physical violence and threats are the chief tools for controlling traffickers.
• Health workers should follow safety rules when rescuing trafficking victims .
• Countries providing financial advantages for anonymous economic activities should be held accountable.
• Psychologists should comply with ethical standards when assisting victims of trafficking.
• Countries with high trafficking rates should develop maps showing hotspots.
• Victims of modern slavery are not to blame: justification from the criminal perspective.
• Whom should we hold responsible for what happens to the victims in captivity?
• Will economic support for vulnerable groups help reduce the level of human trafficking?
• Prolonged captivity reduces the chances of adaptation after release.
• Exercise and physical activity help victims of trafficking to overcome trauma .
• Medication alone is ineffective in combating PTSD among trafficking victims.

Human Trafficking Argumentative Essay Prompts & Tips

• Who is responsible for human trafficking—the government, police , or society? There is no sufficient progress in stopping human trafficking. This is mainly due to the absence of an unequivocal opinion about who is responsible for the situation. Give your own ideas in this essay.
• The need to inform the public about human trafficking. Demonstrate the necessity to convey this information to the masses. You can also suggest ways of doing it.
• Immediate assistance for the victims of modern slavery. Show why it is important to provide psychological aid to rescued victims. What is the role of nurses and community organizations in it?
• Psychological help to victims of human trafficking: group therapy . Group therapy is based on awareness and acceptance of trauma. These actions are the basis of PTSD treatment . Decide whether it’s the optimal solution for victims’ psychological rehabilitation.
• Countries with widespread human trafficking should develop appropriate laws. Legislation changes are a crucial element of an integrated approach. In this essay, provide a list of existing laws and possible new regulations.
• The devastating impact of modern slavery. Describe the disastrous consequences that victims of human trafficking face. Find stories describing their lives in various media. How did they become victims? What happened to them after release from captivity?
• Tightening police measures as a way to stop human trafficking. Women and children are especially vulnerable targets for traffickers. Demonstrate the need to enable the police to protect them better.
• The high rate of trafficking indicates a high crime rate in a country. Determine which countries have the highest human trafficking rates. What are the related crimes observed there? Is there a correlation?
• The use of technology to catch criminals and traffickers. In this essay, discuss technologies that can help officials stop traffickers. For instance, satellite imagery allows identifying places of victims’ detention.
• International financial law is one of the best ways to stop human trafficking. Would the right to disclose anonymous bank accounts help reduce such crimes? What new laws and agreements are required to allow this?

For an argumentative essay, you need to conduct extensive research and present evidence to support your claim (check out our argumentative essay guide to learn more.) Here are the main steps:

Human Trafficking Persuasive Essay Topics

• An anti-trafficking tax will help decrease the modern slavery rates.
• Is preventing new cases of slavery more critical than saving victims?
• Modern slavery is a serious problem that the CIA should address.
• Ignoring human trafficking is the same as neglecting Nazism .
• Forced labor is an economic problem as it is caused by poverty.
• Border control no longer solves the problem of forced labor.
• Should producers of weapons pay an anti-trafficking tax?
• Imprisonment for paying for escort services will stop human trafficking.
• Will stricter gun control laws help stop human trafficking?
• Victims of human trafficking should receive lifetime financial compensation.
• Human trafficking is a national problem that requires coordination of efforts.
• Treatment of human trafficking victims is a responsibility of society as well as psychologists.
• Two-year state-funded hospital treatment will help survivors to cope with the trauma.
• Are social networks a determining factor in the spread of human trafficking?
• Assess gender disparity in using the labor of human trafficking victims.
• Did the political polarization of society lead to an increase in people smuggling?
• Immigration laws are an effective means of combating modern slavery.
• Human traffickers’ family members capable of domestic violence should share responsibility with criminals.
• Civil and human rights protection laws do not sufficiently address human trafficking.
• People smuggling is not a crime from the criminals’ perspective: is this statement true?

Tips & Persuasive Essay Prompts Related to Human Trafficking

• The President must take personal responsibility. The problem of human trafficking is more acute than ever. It requires the immediate intervention of the President and Vice President. For example, they can declare the upcoming year the year of the fight against human trafficking.
• Criminals guilty of human trafficking should be kept in special prisons . The government should create special jails for rapists and human traffickers with a stricter regime. Moreover, we should prevent these criminals from becoming part of society again. Is this proposal fair?
• Trafficking should be punished with life imprisonment . Today, life imprisonment is mainly reserved for murder. Should human trafficking be penalized to the fullest extent?
• Can self-defense lessons help to avoid the risk of being captured by traffickers? Do you agree that schools should introduce a martial arts training system?
• State laws should permit surveillance in regions with high trafficking rates. Debate whether security is more important than the right to anonymity. Should the government allow the police to access people’s data ?
• Public organizations that help the survivors should take official responsibility. If non-governmental associations take it, they can receive financial support. It will help them cooperate more effectively with the police. Do you agree?
• The existence of human trafficking in a country: deontology, utilitarianism and egoism. The United States is officially a democracy . However, the human trafficking rates show that America is close to a feudal society. Criminal ties among the upper class also enforce it.
• Fines as a way to motivate social workers and patrol officers to fight human trafficking. Many activists and police officers work in areas with high human trafficking rates. Do you agree that governments should fine them? Would a system of moderate fines motivate them to be more responsible?
• People who cannot pay rent are easy targets for traffickers. The government should prevent homelessness to combat human trafficking. For instance, it can compensate for the rent of vulnerable demographics.
• Homelessness as the main reason for being captured by traffickers. Homelessness deprives a person of protection. States with the highest human trafficking rates should start building shelters for the homeless. The state should provide them with food, clothing, jobs, and education. This way, traffickers won’t capture them into slavery.

A persuasive essay aims to convince the reader to share your opinion. You can do it by citing facts and statistics (check out our persuasive essay guide for more info.) Here’s how to write it:

Human Trafficking Informative Essay Topics

• How do international organizations fight modern slavery?
• Human trafficking in developed African countries.
• Outline the demography of human trafficking in the US .
• How does society stigmatize trafficking survivors ?
• Fair trade as a way to combat modern slavery.
• Sex trafficking from a feminist perspective.
• The role of photography in the fight against forced labor.
• Fighting human trafficking on the dark web .
• Media coverage of human trafficking : ethical aspects.
• Review how anyone can help combat human trafficking .
• Association of human trafficking with social insecurity.
• How can medical institutions provide safety to victims of trafficking?
• Review the political and economic effects of human trafficking in the US.
• What lessons can the US learn from the trafficking situation in Eastern Europe?
• Forced labor and higher education in the US: programs for survivors.
• What US laws protect victims of slavery and define criminal activities?
• Review government statistics on forced labor in the US over the last five years.
• Which American states have the highest human trafficking rates?
• Modern slavery in the Arab world : from ancient times to modern days.
• Using technology to combat forced labor: the latest solutions.

Tips & Informative Writing Prompts for Human Trafficking Essays

• Measures that governments can take to reduce human trafficking. Review legal and informative measures to combat modern slavery. You can base this essay on reports from official government agencies.
• Human trafficking: types, symptoms , and effects. For this essay, present the kinds of trafficking according to the official categorization. It includes divisions according to age, gender, and type of forced labor. You can also describe the symptoms commonly found in victims.
• The history of human trafficking: from ancient times to the 21 st century. Start by describing ancient cultures that used forced labor. Alternatively, you may focus on the history of slavery in the US . Include the latest statistics on reported cases of human trafficking.
• Human trafficking and fundamental humanistic values. Outline humanistic values that are violated by forced labor. Back it up with arguments drawn from the works of famous humanists.
• What are the consequences of human trafficking for victims? Describe the trauma that people develop while in captivity. Use reports from national and global organizations. What physiological symptoms are associated with adaptation after release?
• How does the US deal with the problem of reporting on forced labor? Present ways of communicating the risks of human trafficking. Base this essay on government anti-trafficking reports. Include a list of trafficker indicators and other red flags.
• Environments that put a person in danger of becoming a victim of human trafficking. These include unemployment , homelessness, and the absence of immigration status. You can base this essay on data from governmental reports.
• Informing the population as means of reducing human trafficking rates. Does informing people actually reduce the number of potential victims? Review the best informing strategies used by community organizations.
• Why are migrants the most vulnerable population group in terms of human trafficking? In this essay, provide information on migrants’ life circumstances. Mention the aspects that make them the most vulnerable demographic. Examples include unemployment and insecurity before the law. You can also present the most common schemes by which traffickers capture migrants.
• New approaches to mitigating the effects of modern slavery in psychotherapy . Describe what methods therapists use to help slavery victims. You can present a list of optimal practices for restoring the integrity of survivors’ personalities. For this essay on human trafficking, use scientific articles and reports from practicing therapists.

An informative essay should educate the reader on something they didn’t know before. Have a look at this outline:

Topics for an Expository Essay on Human Trafficking

• Assess social adaptation methods for victims of sexual slavery.
• Social adaptation of men who worked for traffickers in captivity.
• Police memo: evidence sufficient to detain a trafficker.
• Describe how to identify a trafficker based on 7 criteria.
• Power of the image: photo reports on human trafficking.
• Anonymous story of a sexual slavery survivor.
• Present a psychological and demographic portrait of a trafficker.
• Describe the conditions of human traffickers’ detention.
• Dealing with trauma in children who have been in labor slavery.
• Human trafficking in the Southern and Northern states.
• How to restore citizenship and documents after release from captivity.
• How can human trafficking survivors get free medical care ?
• Who is more effective in stopping human trafficking: government agencies or community organizations?
• Being in captivity during the war , in forced labor, or sexual slavery: psychological consequences.
• Gender differences in human trafficking victims’ labor.
• Modern slavery’s connection to the criminal underworld in the Northern states.
• Enumerate the reasons why homeless people can end up in captivity.
• How many years does adaptation take for human trafficking survivors?
• Explore the modern meaning of the word “slavery.”
• Discuss ways of psychological support for the families of slavery victims.

Modern Day Slavery Writing Prompts & Tips for Expository Essays

• Human trafficking and modern slavery: real stories told by the media. Review several articles about falling into slavery. You can focus on press coverage from the 2010s. The stories of survivors will speak for themselves.
• Non-governmental organizations of the USA assisting victims: the power of community . Present five influential organizations from California, Texas, Florida, Ohio, and Nevada. Assess the personal contributions of staff. What is the role of local communities?
• How to help a friend if they’ve become a victim of human trafficking. In this essay, list tactics and strategies for assisting forced labor victims. Pay particular attention to compliance with safety regulations.
• What is it like to be a forced labor victim? A more creative task is to describe the situation from the inside. Can victims try to escape and free themselves from slavery? What is the role of psychological pressure from traffickers? How can an ordinary person cope with such a monstrous challenge?
• Prostitution, forced labor, and organ trafficking : a comparison. In addition, describe what forms of modern slavery prevail in different countries.
• Therapy methods in human trafficking survivors. Review what therapy practices are the most suitable for working with the survivors.
• An overview of common human trafficking schemes. These often involve vulnerable demographics, including illegal immigrants and adolescents from underprivileged communities.
• In what conditions do human trafficking victims live? In this paper, explain how life in captivity affects one’s mental health . Determine the connections between trauma and the body’s response to it.
• Ways of integration of human trafficking survivors. Review the best strategies for their adaptation to everyday life. Give examples of social adaptation that include education and employment.
• Human trafficking in the Southern and Border States. Study the situation in Texas, California, Florida, Georgia, and Arizona. Then, describe how to solve the problem. Don’t forget to emphasize the role of social work with illegal migrants.

An expository essay includes a thesis statement, evidence, and a logical conclusion. You can also use elements of creative writing in your paper (feel free to read our expository essay guide for more info.) Here are the main steps:

Human Trafficking Research Paper Topics

• Survival in an unfamiliar city: is an escape from slavery possible?
• What prevents citizens from recognizing victims of human trafficking?
• Are monthly payments for human trafficking survivors justified?
• Dietary adaptation for malnourished forced labor survivors.
• How do the police investigate slavery markets?
• Economic levers to combat human trafficking: practical approaches.
• Describe global criminal connections that lead to modern slavery.
• Being in captivity leads to psychological trauma inherited by victims’ children.
• The use of figureheads on social media is a successful tactic against traffickers.
• Five app projects that will help avoid becoming a human trafficking victim.
• We should ban goods produced by forced labor worldwide.
• Human trafficking transportation problems as an opportunity to catch criminals.
• Research the use of symbolic language in informing victims of human trafficking.
• Funding for the installation of video surveillance systems to catch traffickers.
• People from what socio-economic background are the most vulnerable to child labour and exploitation?
• How can we combat human trafficking during a pandemic ?
• Ethics of business and economic relations as a way to combat slavery.
• Informing vulnerable groups about human trafficking and attracting them to cooperation.
• Coordinated interaction of police departments is the key to success in combating people smuggling.

Human Trafficking Research Paper Prompts & Tips

• Deficiencies in US law determine success or failure in the fight against human trafficking. US legislation on human trafficking includes several rules. International acts and agreements also guide it. Nonetheless, the US laws, especially in the leading states, require urgent revision.
• Human trafficking as modern slavery: history repeating itself. Draw analogies between the trends and schemes from the past and the present. What historical practices can be effective in combating slavery? In particular, this concerns the anti-slavery movement and public awareness.
• Domestic human trafficking in the US shows increasing tendencies. Here, analyze the growth of domestic human trafficking cases. Demonstrate the need to create new approaches to catch criminals.
• Technology companies can stop human trafficking. The luring of victims often occurs on social media . Should social networking companies be penalized for failing to act against criminals?
• Can social media campaigns help protect potential victims? It’s necessary to create a program that will inform users about the dangers of trafficking . This method of targeted communication can be very effective.
• City officials should be ready to engage in the fight against modern slavery. Provide examples of American cities that are actively fighting human trafficking. What approaches and practices can be adopted throughout the US?
• Medical institutions are the main asset in combating human trafficking. More than three-quarters of victims receive medical care while in captivity. Health workers have the legal right to place a patient in a hospital and protect them from contact with criminals. This approach has been successful in many states.
• The police have insufficient funding to combat human trafficking. The police are conducting successful investigations, and there are many cases of solved human trafficking crimes. The state can grant more money to the police to uncover more trafficking schemes. It will allow using more advanced technologies in search of criminals.

• Hotlines should be more accessible to victims of trafficking. Hotlines are highly effective in combating human trafficking. They are easy to find on the Internet, but captive victims rarely have access to the network. How can we improve this situation?
• Families of trafficking victims and their participation in the search. Demonstrate the need to establish a format for families’ closer cooperation with the police. Would it help to conduct police investigations more effectively? Should we allow families to conduct their own investigations?
• The US is responsible for the success of international cooperation against human trafficking.

To write a research paper, you study the available information, analyze it, and make conclusions. Here’s a human trafficking research paper outline:

Causes of Human Trafficking Essay Topics

• Discuss psychological factors of human trafficking.
• What personal reasons make people become traffickers?
• Greed as a major reason for human trafficking.
• What are the major causes of sex trafficking?
• Substantial profit as one of the human trafficking root causes.
• Explore the reasons for forced marriages.
• How does social media promote people trafficking?
• Commercialized sex and its contribution to human trafficking.
• Does authoritarianism promote human trafficking?
• Compare the cases of human trafficking in the United States and Thailand.
• Explore the court cases of traffickers. Does the judicial system cope with its duties?
• Why are weak anti-trafficking policies the primary cause of people’s exploitation ?
• Discuss the role of government in human trafficking.
• Investigate the reforms on human trafficking. How effective are these measures?
• Lack of relevant laws leads to more trafficking cases. Do you agree?
• Should legal punishments apply to victims as well as traffickers?
• Why is ethnicity one of the main factors of people trafficking?
• Explore the connection between drug addiction and slavery.
• Violent force and threats as major leverages of traffickers.
• Naivety leads to becoming a victim of traffickers. Provide your arguments.

Causes of Human Trafficking Essay Prompts & Tips

• What are the leading causes of human trafficking? Your essay may start with the definition of people trafficking. Think about social and economic factors. Dig into history to find the reasons. Most importantly, look at this issue from various angles.
• Explore poverty as one of the reasons for human trafficking. How does poverty influence people? Can it force them to behave illegally? What are people ready to do for money?
• Migration : is it a cause or a consequence of human trafficking? Some people are so eager to immigrate to developed countries that they can do anything. They are even ready to sell their children to get money or sell themselves into slavery. At the same time, others become traffickers to move to another country.
• Discuss the connection between human trafficking and education. Think about the following: If a person lacks education, they lack knowledge about their rights. They can be deluded more easily. Following this logic, these individuals can become desired prey for traffickers.
• What is the role of war in human trafficking? Do armed conflicts provoke or prevent the spread of slavery? How do they facilitate the development of this problem? Is smuggling flourishing in countries that are at war? These are excellent questions to start with.
• What are the effects of cheap labor demand ? Supply and demand are two pillars of economics. If there were no need for a cheap working force, traffickers wouldn’t exploit people so easily. They force their victims to work almost for free while selling the goods at a high price.
• Investigate institutional racism as a root cause of people trafficking. Who is the most vulnerable social class ? Naturally, these are marginalized groups. They lack protection at a constitutional level. That’s why they can become victims of traffickers.
• Cultural and social causes of human trafficking. For some nations, selling children, slavery, smuggling, and bonded labor are commonplace. In some countries, such as Uzbekistan, people are forced to work in the cotton fields by the authorities. If you do research, you will see many similar examples worldwide.
• How do natural disasters facilitate human trafficking? The consequences of some natural disasters force people to migrate and find alternative ways to earn money. Some of them have no other option but to let themselves be exploited. 
• How does the absence of safe migration conditions assist people trafficking?  Many people from developing countries want to move to the United States to achieve their American Dream . Traffickers delude fortune seekers, promising well-paid jobs and help in crossing the border.

Discussing human trafficking in a cause-and-effect essay is an excellent way to investigate this issue in detail. You can learn how to write it from our article on cause-and-effect essays . Here’s a recap:

Solutions to Human Trafficking Essay Topics

• How can employers help stop human trafficking?
• Producing films about slavery : is it a problem solution?
• How can we stop human trafficking by learning the indicators?
• How can people protect themselves from traffickers when going abroad?
• Why should employers stop using cheap labor?
• Compare and contrast solutions to labor and sex trafficking.
• The role of parents and caregivers in preventing forced labor.
• How can civic awareness stop human trafficking?
• What is more important: to persecute traffickers or to protect victims?
• In what ways can attorneys help stop people smuggling ? 
• Can creating a reliable online platform for job searching help reduce slavery?
• Educational curriculum : should students be taught how to indicate and prevent human trafficking?
• Investigate the list of goods produced by child exploitation as a form of human trafficking. How does this information influence people’s choices?
• Forewarned is forearmed: discuss the effectiveness of anti-trafficking non-profit websites .
• How can stricter validity checks on job-searching websites solve the issue of modern slavery?
• Can the implementation of severe punishments for human trafficking help to curb the problem?
• Legalization of prostitution as a way of preventing sex trafficking.
• How can timely identification of human trafficking indicators save the lives of the victims? 
• Fighting against poverty and unemployment as a means of preventing people smuggling.
• Watching documentaries about modern slavery as a problem solution.

Solutions to Human Trafficking Essay Prompts & Tips

• What are the primary solutions to human trafficking? Think about the following: How can this problem be solved on personal and national levels? It’s crucial to mention self-awareness , education, volunteering , and the role of charity organizations. You may also address the necessity to change the law.
• Human trafficking: an international approach. The issue of modern slavery is a global problem. That’s why it should be dealt with at the international level. The authorities all over the world should unite to fight against people trafficking.
• Compare and contrast the effectiveness of volunteering and adopting new policies. On the one hand, volunteers attract public attention to the issue of human trafficking. On the other hand, we should protect marginalized groups at the constitutional level. Otherwise, human trafficking will remain flourishing in the future.
• Coverage of human trafficking cases in social media . Is it a good idea for the victims to share their stories on Instagram, Twitter, or Facebook ? How can it help prevent this issue? Could it lead to the stigmatization of these people by others? You can start by brainstorming these ideas.
• Discuss whether fundraising is an effective solution to human trafficking. Ponder on how holding a fundraiser helps bring awareness to the problem of modern slavery. What are some other benefits of fundraising, such as financial assistance?
• Donations help prevent human trafficking. Do you agree? Every person can donate some money, clothes, or even shelter for the victims of human trafficking. Business owners may ensure employment opportunities, giving these people a chance for a better future. Focus on the importance of psychological and legal assistance .
• How does the media help prevent human trafficking? The media attracts people’s attention to the problem. They become more aware and careful. The cases of victims are widely discussed, leading to more fundraising and volunteering .
• Explore the anti-trafficking legislation in the United States. Discuss its strengths and drawbacks. What could be changed or done better? Is it effective? How are the rights of marginalized groups protected? These ideas are only the tip of the iceberg.
• Education opportunities for disadvantaged groups as a way of preventing human trafficking. Should the government provide marginalized people with free education? How can it affect human trafficking? Discuss it in your essay.  
• Why is a boycott an effective way of preventing human trafficking? If others start rejecting the goods produced by the victims of human trafficking, traffickers won’t get such huge profits. Everyone can make their contribution to the fight against this issue.

A problem-solution essay is particularly suitable for discussing modern slavery. Explore the facts and suggest how to stop this inhumane practice. Here’s how to write about problems and their solutions:

If you haven’t found a suitable topic, feel free to use our topic generator .

📝 Human Trafficking Essay Outline

Before you start writing, let’s have a look at some aspects to consider in your college essay on human trafficking. Here’s the basic template:

Human Trafficking Essay Introduction: How to Write

The most important part of an essay introduction is a hook. A perfect attention grabber for a human trafficking paper would demonstrate the seriousness of the problem right away. It, in turn, would make your audience eager to read on.

Have a look at some of the ideas for your essay’s hook:

• Cite statistical data related to the current situation with human trafficking.
• Start with a stirring quote to appeal to readers’ emotions.
• Pose a question related to your essay’s topic. Make the reader want to learn the answer.

Besides the hook, it’s logical to start your essay with some background information. This way, even an unprepared reader will understand your essay’s thesis. Think of what your audience may not know about your topic. It will help you determine what to include in this part of the introduction.

Here are some strategies:

• Tell about the countries and regions with the highest trafficking rates—for example, Thailand, the Philippines, India, South Africa, and Eastern Europe.
• Mention reasons behind this problem: unemployment, social discrimination, political instability, armed conflicts, etc.
• Give a solid definition of human trafficking or its specific type. It’s better to formulate your own one rather than take it from a dictionary.

It’s important to notice that your hook and background information should be relevant to your topic. Make sure these elements help to further the understanding of your essay’s main point.

Human Trafficking Essay Thesis

A thesis statement is your essay’s main point formulated in one sentence. It outlines the paper’s direction and provides an answer to the problem stated in the title. You place it at the end of the introduction.

A good thesis statement for a human trafficking essay usually presents the solution to a problem. However, the thesis’ contents depend on your essay’s type. For example, in an informative essay, you don’t need to prove or suggest anything. Instead, you say what you’re going to explain and how you’ll do it.

Once you’ve written the thesis statement, how do you determine whether it’s strong? Well, one way is to answer the questions from the following checklist.

If your answer to all three questions is “yes,” you can be sure of your thesis’s effectiveness.

Finally, don’t forget that the rest of your essay should support your thesis. If necessary, you can rework your statement to better suit the body paragraphs, or vice versa.

Human Trafficking Essay: Main Body

How do you make your essay on human trafficking credible and persuasive? Naturally, you want to add evidence. Here’s how to incorporate it into your paper:

• It’s better to start collecting your evidence before you start writing. Once you’ve found all the necessary information, it will be easier for you to structure the paragraphs. The point is to focus each section on a single aspect.
• Start each paragraph with a topic sentence. It should present the main idea that you will then support with evidence. Ideally, your audience should be able to follow your logic by reading the topic sentences alone.
• Finally, add your evidence. It can be statistics, facts from scholarly articles, quotes, or even anecdotes. Follow it with your explanation of this information. Say how it relates to the topic and supports your thesis.

Human Trafficking Essay Conclusion: Dos & Don’ts

A strong conclusion is a crucial part of any writing. In this final part, you synthesize your essay in a few sentences while adding a twist to it. If a conclusion is done right, it can leave a lasting impression on your readers.

This dos and don’ts list will help you write a perfect conclusion for a human trafficking essay. Check it out:

Don’t forget to introduce statistics in your essay on human trafficking. It’s available on numerous websites of governmental and non-governmental organizations dealing with the problem. You can find more ideas for your paper in our article about writing a child labor essay.

📑 Human Trafficking Essay Examples

We’ve prepared an outstanding sample essay on human trafficking that you can use as inspiration. You’re welcome to download the PDF file below:

Human trafficking is a global problem. It deprives millions worldwide of their freedom and dignity. Traffickers use various tactics to lure children, men, and women into the trap. For that reason, precaution measures should be taken. It is crucial to educate as many people as possible on the issue to ensure everyone’s safety.

Share your thoughts about human trafficking with us! Why do you think slavery is still in demand? If you were a politician, what would you do to prevent it? Tell us your suggestion in comments below!

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✏️  Human Trafficking Essay FAQ

Human trafficking is a topical issue in society because it’s an inhumane practice that affects millions of people worldwide. Writing on that topic helps understand why it is happening and what can be done about it.

Human trafficking is a very complex phenomenon driven by various economic, social, cultural, and other causes. Factors of a high human trafficking risk are poverty, social instability, exclusion, and lack of education and awareness (e.g., in South Africa.)

Pretty much every fact connected with human trafficking is horrifying. Nearly everything about this phenomenon can be considered a danger. As human trafficking is a form of slavery, it would be naive to presume there are any positive effects whatsoever.

Human trafficking is a serious problem, and you should be able to express your opinion on it. For example, it can be done in the form of an argumentative essay. It is vital to avoid using too many emotionally charged words. Remember to stay objective and provide facts and examples.

🔗 References

• Tips for Organizing an Argumentative Essay: Judith L. Beumer Writing Center
• Human Trafficking Essay: Bartleby
• Post Traumatic Stress Disorder Treatment: NHS
• Embrace AI, Technology to Beat Human Traffickers: Reuters
• Essay Writing: Purdue University
• What Is Human Trafficking: Anti-Slavery International
• Human Trafficking: Encyclopedia Britannica
• End Human Trafficking: United Way
• Human Trafficking Facts: CRS
• OSCE Resource Police Training Guide: Trafficking in Human Beings: OSCE
• Study on the Economic, Social and Human Costs of Trafficking in Human Beings Within the EU: Europa.eu
• Writing a Research Paper: University of Wisconsin-Madison
• Human Trafficking: FBI
• Human Trafficking: Causes and Implications: Research Gate
• Writing a Persuasive Essay: Hamilton College
• Parts of an Informative Essay: Pen and the Pad
• Expository Essay Outline: Columbus City Schools
• Introductions & Conclusions: University of Arizona
• Writing the Introduction: Monash University
• How to Write a Thesis Statement: Indiana University Bloomington
• Writing a Thesis Statement: Piedmont University
• 4 Ways Anyone Can Fight Human Trafficking: The Muse
• What Fuels Human Trafficking?: UNISEF USA
• What Is Human Trafficking?: Homeland Security
• Psychological Tactics Used by Human Traffickers: Psychology Today
• Psychological Coercion in Human Trafficking: An Application of Biderman’s Framework: NIH
• Warning Signs of Human Trafficking: State of Nevada
• Human Trafficking: US Immigration and Customs Enforcement
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5 Essays On Human Trafficking You Can Access Freely Online

Every country faces specific human rights issues, but human trafficking is a problem for every place on the planet. Wherever there’s poverty, conflict, a lack of education, or political instability, vulnerable people are at risk. Human trafficking is the world’s fastest-growing criminal industry. Sexual exploitation brings in most of the billions of dollars of profit, but forced labor also generates wealth. The universality of human trafficking doesn’t negate the fact that the issue is multi-faceted and as a multitude of root causes . Certain countries are more dangerous than others and certain people groups are more vulnerable. To learn more about specific human trafficking issues and solutions, here are five essays you can read or download for free:

“Human Trafficking and Exploitation: A Global Health Concern”

By: Cathy Zimmerman and Ligia Kiss

While labor migration can be beneficial to workers and employers, it’s also a hotbed for exploitation. In this essay from PLOS, the authors argue that human trafficking and the exploitation of low-wage workers have significant negative health impacts. Because of the magnitude of human trafficking, health concerns constitute a public health problem. Thanks to certain business models that depend on disposable labor, exploitation is allowed to flourish while protections are weakened. The essay states that trafficking initiatives must focus on stopping exploitation within each stage of labor migration. This essay introduces a special collection from PLOS on human trafficking and health. It’s the first medical journal collection on this topic. It includes pieces on child sex trafficking in the United States and the slavery of sea workers in South East Asia. Cathy Zimmerman and Ligia Kiss, the guest editors and authors of the first essay, are from the London School of Hygiene and Tropical Medicine.

“Introducing The Slave Next Door”

By: Jen Birks and Alison Gardner

Published in a special issue of the Anti-Trafficking Review on public perceptions and responses to human trafficking, this essay focuses on Great Britain. According to the essay, there’s been a shift in what the public thinks about trafficking based on local reporting and anti-slavery campaigns. British communities are starting to realize how prevalent human trafficking is in their own backyards. The essay takes a closer look at the media and campaigns, how they’re representing cases, and what people are doing with the information. While specific to Britain, it’s a good example of how people can perceive trafficking within their borders.

Jen Birks is an Assistant Professor in media at the Department of Cultural, Media, and visual Studies at the University of Nottingham. Alison Gardner is at the School of Sociology and Social Policy at the University of Nottingham with a Nottingham Research Fellowship. She is part of the university’s Rights Lab.

“My Family’s Slave”

By: Alex Tizon

One of The Atlantic’s biggest stories of 2017, this essay tells a personal story of modern slavery. At 18-years old, Lola was given to the writer’s mother and when they moved to the United States, Lola came with them. On the outside, Tizon’s family was, in his words, “a poster family.” The truth was much darker. The essay sparked countless reader responses, including those of people who were once slaves themselves. Reading both the criticism and praise of the essay is just as valuable as the essay itself.

Alex Tizon died at age 57 years old before his essay was published. He had a successful career as a writer and reporter, sharing a Pulitzer Prize while a staff member at The Seattle Times. He also published a 2014 memoir Big Little Man: In Search of My Asian Self.

“Vietnam’s Human Trafficking Problem Is Too Big To Ignore”

By: Thoi Nguyen

In November 2019, 39 Vietnamese people were found dead in a truck container. They were identified as victims of a human trafficking ring. In Nguyen’s article, he explores the facts about the severity of human trafficking in Vietnam. For years, anti-slavery groups have warned the UK about a rise in trafficking, but it took a tragedy for people to start paying attention. Nguyen discusses who is vulnerable to trafficking, how trafficking functions, and Vietnam’s response.

Freelance journalist Thoi Nguyen is a member of Chatham House and a member of Amnesty International UK. In addition to human trafficking, he writes about the economy, finance, and foreign affairs. He’s a specialist in South East Asian geopolitics.

“History Repeats Itself: Some New Faces Behind Sex Trafficking Are More Familiar Than You Think”

By: Mary Graw Leary

This essay highlights how human trafficking isn’t only a criminal enterprise, it’s also an economic one. Leary looks specifically at how businesses that benefit (directly or indirectly) from slavery have always fought against efforts to end it. The essay focuses on government efforts to disrupt online sex trafficking and how companies are working to prevent that from happening. Human trafficking is a multi-billion dollar industry, so it makes sense that even legitimate businesses benefit. Knowing what these businesses are is essential to ending trafficking.

Mary Graw Leary is a former federal prosecutor and currently a professor of law at The Catholic University of America. The Chair of the United States Sentencing Commission’s Victim Advocacy Group, she’s an expert in exploitation, missing persons, human trafficking, and technology.

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About the author, emmaline soken-huberty.

Emmaline Soken-Huberty is a freelance writer based in Portland, Oregon. She started to become interested in human rights while attending college, eventually getting a concentration in human rights and humanitarianism. LGBTQ+ rights, women’s rights, and climate change are of special concern to her. In her spare time, she can be found reading or enjoying Oregon’s natural beauty with her husband and dog.

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Human Trafficking (Argumentative Essay Sample)

Human trafficking.

Human being usually has an absolute control over others especially when it comes to issues regarding slavery for a long time. Human trafficking is one of such illegal activities where man controls others. This form of trafficking usually manifests in the form of sex trafficking, trafficking for labor reasons as well as organ trafficking.  People have been prone to human trafficking due to poverty and their low social status in the society while others appreciate such trade due to financial gain. The most vulnerable victims of human trafficking include women and children who are reduced to sexual commodities. In most cases, the participants in such industry include corrupt officials, rich investors, and tycoons among others.  The beneficiaries of human trafficking exploit the broken society of the victims and lure them with lucrative and false promises, and in the end, these people are physically and sexually abused to obtain their submission. In worse situations, the cops who take care of citizens’ security conspire with the traffickers for money or sexual favors in return while the victims are unable to get justice. Sometimes parents participate in such trade to repay debts or for school fees. Therefore, human trafficking should be abandoned.

Human trafficking should be stopped since it leads to sexual exploitation.  Even though there are numerous reasons for human trafficking, sexual exploitation leads the pack. Most women and children have fallen victims of sexual molestation, abuse, and torture due to human trafficking. The trafficking happens due to increase in unemployment, political instability, armed conflicts and social discrimination in the society. This activity is especially exhibited in regions such as Asia, Africa and parts of Europe such as Russia, Romania, Ukraine and Moldova among others. Therefore, it should be prohibited in these areas.

Secondly, human trafficking should be banned since the activity is conducted against the victims’ will. In most cases, human victims are misled or lured into human trafficking with false promises hence they usually have a hope of living better lives as well as getting well-paying jobs. In most cases, women and young girls fall victims of such false information whom in turn get involved in hard labor and are sexually exploited. Besides, these women and girls are paid minimal wages in their home countries. Therefore, they are highly vulnerable to such false information hence fall victims of human trafficking. Thus, the activity is currently a major problem that should be eradicated.

Human trafficking leads to psychological manipulation of the victims. It is evident that victims of human trafficking undergo psychological manipulation at the hands of the oppressors and traffickers.  The victims are tortured beside being afraid of being killed or arrested. To elaborate on the point, most of these victims live in foreign countries hence the oppressors hide their visas as soon as they reach their destinations. Furthermore, some do not possess documents and are aware that they have violated the rules regarding immigration. Therefore, they typically suffer mental problems as they seek refuge from the oppressors.

In conclusion, human trafficking is a crime that has become profitable in the current society. However, the victims suffer most due to numerous exploitations that they undergo. Therefore, the governments and international communities should tackle the problem through the enactment of treaties and laws prohibiting the trend as well as illegalizing prostitution. On the same note, the potential victims should be aware of human trafficking besides being cautious  especially on the dangers of traveling to other countries These measures can substantially mitigate the problem if.

Human Trafficking: Process, Causes and Effects Analytical Essay

Introduction, the trafficking process, causes of human trafficking, effects of human trafficking, works cited.

Human trafficking can be described as an illegal trade that deals with the selling and buying of human beings just like other kinds of trade. The human being are bought and sold for the purposes of forced labor or commercial sex (Strickland, 1). Human trafficking is a new term for slave trade and the victims are either sold by their family members or scrupulous business people who want to get money for the desire of being wealthy.

After drugs and arm dealing human trafficking comes third in international crime rankings worldwide. This kind of trade involving human beings is illegal but people use dubious means to continue their dealings. It is very hurting to know that some corrupt law enforcement authorities who are supposed to protect the general public against such inhuman practices are the same people involved.

The enslaved people who may also be referred to as the victim are trafficked by being deprived their basic human rights. They are forced or enticed by being given false promises which are never fulfilled by the traffickers (Murphy, 1). They are promised good employment opportunities in neighboring countries but when they get there they are they are forced to work in brothels while others work in factories and agricultural farms.

The good salaries they had been promised they are no longer given and incase they are paid it is either too little to meet their needs or they are offered travel documents by corrupt law enforcement authorities and on arrival to their destination their travel documents taken away from them.

In this case they are forced to work there and do not have the necessary documents required to travel back to their homes in case of maltreatment. Likewise women and young girls are assured jobs that are well paying but on arrival to the Promised Land things are totally different.

They are forced to prostitution or sex trade where the victims are sexually harassed and the traffickers paid money the abuse. To make the matters worse they are abused and the money goes to the pockets of these greedy people as they are left empty handed after all the humiliation they go through. The victims are deprived the chance of going back to their homes or even communicating with their loved ones and relatives.

The traffickers take advantage of the high levels of poverty among people. It is quite obvious that a poor person is willing and ready to do anything for them to get some money to maintain themselves (Laner, 1). Others also rent out a person’s labor for them to be able to repay a loan or debt.

Ignorance or lack of awareness also causes human trafficking. People travel across borders looking for greener pasture with little or no knowledge about traffickers and their operations. Such kinds of people are usually prone to falling victims of this illegal and exploitive kind of business activity (Strickland, 1).

Other people are enticed by the material expectations. They desire high living standards and consumer products that are out of their reach. They envy what they see from others and wish them too were in the same social status with those they envy. This desire for achieving what they don’t have renders them vulnerable and hence traffickers take advantage of such people.

People with very little or no proper level of education are standing higher risk of being trafficked. This group of people has very few employment opportunities due to their limited education. They thereby migrate to search for employment opportunities and that is when they get trafficked and exploited.

Corrupt and weak law enforcement authorities play a major role in the lucrative trade of human beings (Hart, 20). Immigration and other law enforcement authorities are paid by the traffickers to overlook these criminal activities which it is their duty to fight such vices by protecting innocent human beings.

The authorities may also collude with the traffickers by providing delusive information on their travel documents and other identification documents to migrant workers leaving them defenseless to trafficking. In circumstances when such incidences of human trafficking are reported to the public administrators little or no action is taken. Instead if the culprits being arrested and charged in court they bribe the law enforcers and walk away scot free.

Young girls and women are lured into marriage by the traffickers who pretend to be tourist (Kloer, 2). They then promise them to take them to their countries to live with them there. On arrival to the foreign land they are abandoned in brothels to work as sex slaves and threatened not to leave. The military is also well known for sexual abuse in areas where they are sent to serve the public during times of unrest.

This activity results in threat to human health. The victims are exposed to high risks of diseases such as HIV/AIDS and other STDs (Murphy, 2). This does not only affect the victims but also spreads to the sex clients and their spouses and the children given birth thereafter. For those victims that are taken into forced labour may also suffer from diseases caused by overworking and improper living conditions.

Deprivation of the basic human rights is another problem the victims face. They live in conditions in which none of them likes to be associated with. They are denied the rights of communication with their relatives and other people. They also do not enjoy their work because they are forced to do it and that was not the work they had been promised earlier on. These people would work as beasts of burden where they worked beyond the normal working hours and the working conditions very severe.

Many victims lack trust and confidence in the law enforcement authority. They believe they are serving in slavery because of their weak and corrupt laws in their countries (Delta, 1). What hurt the victims most was the fact that the same people in charge of protecting their lives and ensuring that such incidences do not happen to them are the involved in the dealings.

Some people suffer mentally by being traumatized after the humiliation they go through in the name of the good jobs they had been promised. The victims also have the fear of being unsafe around everyone they come across. Those who manage to get their freedom tend to think that all people around them can do the same to them.

In a nutshell human trafficking is a vice which should be done away with in our societies. To put an end to this wicked behavior it is a collective responsibility for the country as a whole. The government should start by punishing the law authorities that have been participating in the exercise and put in place tough repercussions for those found guilty.

The general public should also be eliminated about the effects of being involved and stop being so desperate in search for employment opportunities. If all this is done people will live in a friendly environment where such activities are a thing of the past.

Delta, S. (2010). Human Trafficking Facts. Web.

Hart, J. Human Trafficking . The Rosen Publishing Group, Inc. New York, 2009.

Kloer, A. (2006). End Human Trafficking. Web.

Laner, S. (2005). Human Trafficking. Web.

Murphy, S. (2006) Human Trafficking and Immigrant Smuggling . Web.

Strickland, D. (2008). Human Trafficking. Web.

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Good argumentative essay topics on human trafficking with prompts, bob cardens.

• August 1, 2022
• Essay Topics and Ideas , Samples

Human Trafficking is a controversial and often underserved topic. It’s also an important one. There are many argumentative essay topics on human trafficking you could choose to write about. Here are some ideas to get you started.

• Can abolishing Sex Work help reduce human trafficking cases Essay prompt: Sex work should be abolished but with consideration to the impact it has on vulnerable groups, particularly women. However, I do not think it would end human trafficking but it will surely contribute to its reduction. Sex work is one of the biggest contributors to human trafficking.
• Sex trafficking and comparing it to a book called “Oryx and Crake” Essay prompt: Sex trafficking is a violation of human rights. Human trafficking is a serious crime. Sex trafficking involves activities like sex exploitation and sex slavery. The consent of a person cannot be relevant if it was obtained by coercion, fraud, or deception.

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• Combating Human Trafficking Through Facial Recognition Essay prompt: Trafficking in persons continues to be a growing global health issue. Often, people do not entirely understand the circumstances regarding why people become trafficking victims.
• Providing Better Services for Human Trafficking Survivors Essay prompt: Human trafficking is a major challenge facing society today. Improving coordination among all entities involved, including local and federal enforcement, health care, social services, and non-governmental organizations will be integral to improving the outcomes for survivors of the vice.
• Briefing Paper Topic Proposal: Human Trafficking Essay prompt: Women and children are particularly vulnerable to human trafficking, with mean, purpose, and the act itself important ingredients to determine human trafficking…
• Human Trafficking and Nurse’s Understanding Essay prompt: Human trafficking is a commercial activity involving human beings as the prime goods for forced labor, sexual motives, and removal of body organs such as ova in females. The act is illegal since it has some negative consequences on the psychological, health, safety, and violation of human rights.
• Human Trafficking and its Impacts on the Health Care Industry Essay prompt: Globalization and the international political economy have resulted in a rapid interconnection between the nations therein. Nowadays, countries are so interconnected that the world has become more like one global village. It has made life more convenient and business more expansive.
• Law Essay: Human Trafficking and Crimes Against Children Essay prompt: Human Trafficking and Crimes Against Children. Identify and Discuss the Process, Means, And Ends of Human Trafficking. (Argumentative Essay Topics on Human Trafficking)
• Sex Trafficking and Its Reporting Essay prompt: Despite advancements in technology and tight security across the borders of North American countries, sex trafficking remains rampant. In the United States alone, it is estimated that more than 15,000 foreigners are trafficked every year.

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• Worldwide Database on Human Trafficking. Law Coursework Essay prompt: The United Nations Office on Drugs and Crime (UNODC) is responsible for fighting against international crime, human and drug trafficking.

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126 Human Trafficking Research Topics & Essay Examples

Are you searching for the best human trafficking research topics? Look no further! On this page, you’ll find human trafficking topics for your research paper, speech, and many other writing assignments. Read on to discover the most interesting topics on human trafficking issues and essay examples!

🏆 Best Human Trafficking Essay Examples

✍️ human trafficking essay topics for college, 👍 good human trafficking essay topics, 🎓 human trafficking topics for research paper, ❓ human trafficking research questions, 🔎 research questions about human trafficking, 📝 human trafficking argumentative essay topics.

• Human Trafficking from Perspectives of Deontology, Utilitarianism and Egoism
• Human Trafficking: Ethical Issues
• Human Trafficking in Thailand: Social Work Practice
• Human Trafficking and Ethical Behavior Breaches
• Child Exploitation as a Form of Human Trafficking
• Human Trafficking and Psychological Impacts
• Human Trafficking and Legal Aspects
• The Problem of Human Trafficking in America The human trafficking business thrives because judges are unable to prosecute traffickers. The nature of the crime requires that women who are victims be witnesses and give testimony in courts.
• The Role of Online Games in Human Trafficking Online games such as Roblox and Metaverse act as platforms human traffickers use to lure children and even adults.
• Detailed Analysis of Human Trafficking The persuasive paper presented below gives a detailed analysis of this predicament and how stakeholders can be involved to transform the current situation.
• Biological Theory Applied to Human Trafficking This essay aims to discuss how the use of biological theory in criminology can help explain the phenomenon of human trafficking and the role of poverty in it.
• The Victims of Human Trafficking Most of the victims of human trafficking are young boys and girls who cannot protect themselves against their captors.
• Human Trafficking as Violation of Human Rights Human trafficking is a heinous issue that is very serious and dangerous for our society. It is widely known that human trafficking has become an expanding issue across the world.
• The Role of Technology in Human Trafficking and Sexual Exploitation Human trafficking and sexual exploitation are significant problems in contemporary society that constitute a violation of human rights.
• Human Trafficking and Poverty Issues in Modern Society The problem of human trafficking affects people all over the world, which defines the need for a comprehensive approach to this issue from the criminology perspective.
• Investigating the Nexus Between Human Trafficking and National Security The research paper investigates the nexus between human trafficking and national security from an economics perspective.
• The Case of Veronica: Human Trafficking This paper discusses the severe problem of human trafficking, as it adversely affects millions of individuals regardless of their gender, age, and nationality.
• Human Trafficking in Florida Law Human trafficking is defined by Florida law as modern-day slavery manifested in the form of exploitative labor, transportation, and harboring of individuals.
• Human Trafficking: Risk and Causes The main purpose of the paper is to discover the prevalence, causes, and health risks associated with human trafficking.
• Human Trafficking and Poverty Discussion This paper synthesize information on human trafficking and poverty by providing an annotated bibliography of relevant sources.
• International Organizations Battling Human Trafficking This essay aims to analyze the role of NGOs and IGOs in the recent transnational measures that combat human trafficking.
• Data and Research on Human Trafficking One of the emerging issues regarding criminology is human trafficking that is conducted through organized crime.
• Human Trafficking – Modern-Day Slavery Modern-day slavery is one of the outcomes of globalization; it affects millions of people and brings immense revenue to the criminals.
• Human Trafficking Through a Historical Lens Human trafficking is a global issue that involves coercing a person to provide services or labor forcefully, violating their human rights.
• Human Trafficking as a Practice Problem Victims of modern-day slavery are exploited in every region of the world, forced to work or provide paid sexual services in real-life production environments and on the Internet.
• NGO Involvement in Human Trafficking Information Dissemination The research project aims to address the prevalence of human trafficking as a public health issue by exploring the potential opportunities.
• Human Trafficking in the United States Project Design and Implementation The research project aims to delve into the complex issue of human trafficking in the United States and the vulnerable populations targeted.
• The Internet Role in Human Trafficking This essay will argue that the problem of Internet use for human trafficking is unsolvable because there are not enough ways to control these processes.
• Human Trafficking and Prostitution: Religious Perspective The implementation of an ideal religion is possible in the context of human trafficking and forced prostitution.
• Human Trafficking and Its Use in Historical Lens The essay examines the historical origins and current impact of human trafficking, emphasizing the need for education and awareness to combat this widespread problem.
• The Case of Human Trafficking in China The Chinese government should distinguish between prostitution and human trafficking to put effective procedures for identifying victims of forced marriages.
• Human Trafficking and Forced Prostitution Human trafficking and its connection with prostitution remain a controversial topic, as do their perception and possible remedies.
• Effects of Human Trafficking on the Victims When evaluating the effects of human trafficking on victims, mental health issues are brought up as the direct outcome of being exposed to continuous violence and brutality.
• Prostitution vs. Human Trafficking Many people believe that making prostitution a legal activity will help raise the status of prostitutes and promote their protection.
• Research on Human Trafficking in Arkansas Although the rates of child sex trafficking in Arkansas remain high, the authorities at all levels are concentrated on solving this problem.
• How COVID-19 Affected Human Trafficking This paper presents and supports the argument that the COVID-19 has led to an increase in human trafficking activities.
• Human Trafficking Concerning Minorities in the U.S. The issue of human trafficking concerning minorities and the measures of addressing the problem and dealing with will be discussed in this research paper.
• Nursing Code of Ethics in the Human Trafficking Victim Treatment When nurses face the settings in which their patients are the victims of severe public health issues, it is their explicit responsibility to take action.
• Human Trafficking: International Human Rights International human rights law defines human trafficking as the violation of an individual’s right to liberty through appropriation of their legal personality, labor and humanity.
• Human Trafficking: A Threat to All This essay analyzes the three mentioned types of human trafficking, proving that they are a threat to all of humanity, as it creates inequality and dependency on certain people.
• Human Trafficking: Term Definition In January 2009, a raid by Brazil police led to a rescue of more than 4,500 slaves who had been entrapped in ranches and plantations in remote areas of the country.
• Human Trafficking and Health Care Professional Preventing human trafficking by healthcare professionals largely depends on the government to develop registration purposely meant to make trafficking of people illegal.
• Christian Foundations in Government: Human Trafficking Human trafficking or trafficking in human beings is defined as the movement of people without their consent, usually by force for the intention of sexual or labor exploitation.
• Human Trafficking: National and International Challenges Social workers must respond to any humanitarian crisis domestically and abroad. The international issue of human trafficking and its impact requires the attention of social workers
• Modern Slavery, Human Trafficking and Poverty Be it through the sexual enslavement of girls or trafficking of males for forced labor, slavery has had a tremendous impact on modern society.
• Human Trafficking and Its Signs in Patients The problem of human trafficking is a health hazard for the victims. Places in which human trafficking occur vary depending on the purpose of this modern day slavery.
• Human Trafficking and Unethical Business in the US Over the years, human trafficking in the United States has been ranked as one of the significant challenges facing the federal government.
• Human Trafficking in the USA Human trafficking has been defined as the transportation, transfer or recruitment of human beings, by use of deception, abduction, coercion, and fraud.
• Human Trafficking as a Modern-Day Slavery Problem The paper discusses the anti-trafficking measures of international organizations, such as UN, UNICEF, and UNESCO. The laws enacted by these organizations are further mentioned.
• The Most Shocking Aspects of Human Trafficking The issue of human trafficking can be discussed as challenging because there are opinions that this problem cannot be overcome or addressed effectively.
• Human Trafficking Problem in Society Human trafficking is defined as the process through which human beings are recruited, transferred or received through forceful means with the intention of exploiting them.
• What is Human Trafficking? This paper will set out to define human trafficking and highlight some of the factors why it continues to occur today. The paper will discuss the effects of human trafficking.
• Human Trafficking and Illegal Immigration Human trafficking is a problem which seems to be concealed and even ignored in the United States’ society because of a lack of the appropriate discussion.
• Human Trafficking: Current State and Counteracts Human trafficking involves transportation of people inside their countries and abroad to be sexually exploited and become source of cheap unskilled labor in the developed states.
• Human Trafficking and Public Service Announcements Public Service Announcements project will attempt to educate youth, especially young females, about safety rules to reduct human trafficking on local and national levels.
• “The War on Human Trafficking: U.S. Policy Assessed” by Anthony M. DeStefano “The War on Human Trafficking: U.S. Policy Assessed” by Anthony M. DeStefano is an overview of American government’s efforts to combat the human trafficking.
• Women’s Rights Organizations and Human Trafficking
• Human Trafficking and the Child Welfare Population in Florida
• The Link Between Human Trafficking and Cambodia
• Human Trafficking, Modern Day Slavery, and Economic Exploitation
• Illegal Adoption and Human Trafficking Impact on the US
• The Violent and Perverse System of Human Trafficking
• Human Trafficking Throughout South Africa
• The Differences and Similarities Between Human Trafficking and Slavery
• Human Trafficking From Latin America to Canada
• The Trafficking and Forms of Human Trafficking
• Islamic Law and Human Trafficking in Saudi Arabia
• Human Trafficking and the Trade of Human Sex Trafficking
• Medical Care for Human Trafficking Victims
• The Human Trafficking and the Saga of 53 Indian Nationals
• Human Trafficking Throughout the United States
• The Horrors and Statistics on Human Trafficking in the United States
• Human Trafficking and Its Effects on the Criminal Justice System
• Connections Between Human Trafficking and Environmental Destruction
• The Human Trafficking Aspect of the Military-Industrial
• Human Trafficking Has Increased Greatly With Globalization
• What Are Five Warning Signs of Human Trafficking?
• Human Trafficking and Why Do They Call It Modern-Day Slavery?
• Human Trafficking vs. Prostitution: Is There a Difference?
• Who Is the Biggest Human Trafficking in the World?
• What Is the Most Common Place for Human Trafficking?
• What Are the Top Ten Cities for Human Trafficking?
• What Is the Most Common Age of Human Trafficking Victims?
• Who Is Most at Risk for Human Trafficking?
• How Do You Escape Human Trafficking?
• How Do You Know if You Are Being Targeted for Human Trafficking?
• What Happens to Human Trafficking Victims After?
• What Does the Blade Mean in Human Trafficking?
• What Is the Rate of Human Trafficking in the US?
• What Country Has the Highest Human Trafficking Rate?
• Where Does US Rank in Human Trafficking?
• Where Is Human Trafficking Most Common in Europe?
• What Are the Top Three Countries for Human Trafficking?
• How Many People Are Victims of Human Trafficking in Europe?
• What Are the Three Types of Human Trafficking?
• Is Human Trafficking Common in Africa?
• Why Does Human Trafficking Happen in Africa?
• What Country Has the Most Human Trafficking in 2021?
• Is Romania Known for Human Trafficking?
• Why Is There So Much Human Trafficking in Eastern Europe?
• How Do Human Traffickers Mark Their Victims?
• What Are the Statistics on Human Trafficking of Children?
• How Common Is Human Trafficking in Japan?
• Is There Human Trafficking in Tokyo?
• Where Is Human Trafficking Most Common in the Middle East?
• How Does War Contribute to Human Trafficking?
• How has globalization affected the prevalence of human trafficking?
• What are the most common recruitment tactics of traffickers?
• What population groups are the most vulnerable to human trafficking?
• How do different countries combat human trafficking?
• How do social networks facilitate human trafficking?
• What is the connection between human trafficking and other organized crime types?
• How does police corruption contribute to human trafficking?
• What are the challenges in prosecuting human trafficking cases?
• What social and cultural attitudes perpetuate human trafficking?
• How can education programs help prevent human trafficking?
• The impact of decriminalizing prostitution on human trafficking.
• Can temporary work visas be effective in reducing human trafficking?
• Should human trafficking victims be treated as criminals or supported?
• Human traffickers: do they deserve harsher punishment?
• Should human trafficking be considered a form of terrorism?
• Do public awareness campaigns help prevent human trafficking?
• Demand-side vs. supply-side interventions to combat human trafficking.
• Is the private sector responsible for addressing human trafficking?
• Is human trafficking a domestic or international issue?
• The role of immigration policies in human trafficking.

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These essay examples and topics on Human Trafficking were carefully selected by the StudyCorgi editorial team. They meet our highest standards in terms of grammar, punctuation, style, and fact accuracy. Please ensure you properly reference the materials if you’re using them to write your assignment.

This essay topic collection was updated on January 8, 2024 .

Home — Essay Samples — Social Issues — Human Trafficking — Paragraph About Human Trafficking

Paragraph About Human Trafficking

• Categories: Human Trafficking

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Published: Mar 5, 2024

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Speech on Human Trafficking

Human trafficking is a grave issue that affects countless lives worldwide. It’s a form of modern-day slavery where people are traded for exploitation.

You might be shocked to know how widespread this problem is. It’s crucial to understand this issue to help combat it.

1-minute Speech on Human Trafficking

Ladies and gentlemen, boys and girls, let’s talk about a harsh reality of our world – human trafficking. This is a scary term, isn’t it? It means stealing people, often kids like you, and forcing them to do things they don’t want to do. It’s like a monster from a nightmare, but it’s real.

Imagine your friend goes missing one day. You don’t know where they are, you can’t talk to them, you can’t play with them. This is what happens when someone is trafficked. They are taken away from their homes, their families, their friends. They are alone and scared.

Now, why does this happen? Some bad people think they can make money by selling others. They don’t care about the pain and sadness they cause. They only care about themselves.

But we can fight this monster. We can help stop human trafficking. How? By learning and teaching others about it. If we know the signs, we can alert the police when something is wrong. We can also support groups that help victims of trafficking. They need our help to get their lives back on track.

Remember, we all have the power to make a difference. Every small action counts. Let’s stand together against human trafficking. Let’s protect our friends, our families, and ourselves. Let’s make the world a safer place for everyone. Thank you.

Also check:

• Essay on Human Trafficking

2-minute Speech on Human Trafficking

Ladies and Gentlemen, today I stand before you to talk about a topic that needs our immediate attention – human trafficking. This is a serious problem, like a terrible storm that is causing harm to many people around the world.

Let’s first understand what human trafficking is. Imagine someone taking you away from your family, your friends, your home, and forcing you to do things you don’t want to do. That’s what human trafficking is. It’s a form of slavery where people are bought and sold, like objects.

Now, why should we care about this? Because it’s happening to children, women, and men everywhere. It’s happening in big cities and small towns. It could happen to anyone, maybe even someone you know. It’s not fair, and it’s not right. We should care because every person deserves to be free, to live their life how they want to, not how someone else forces them to.

You might ask, “What can we do?” The first step is to learn and understand. We need to be aware of the signs of human trafficking. If someone is always scared, can’t talk freely, or has no personal belongings, they might need help. If we see something strange, we should tell a trusted adult or call the police.

We can also spread the word. Talk to your friends, your family, your teachers about human trafficking. The more people know about it, the more we can do to stop it.

Finally, we can support organizations that are fighting against human trafficking. These groups help victims and work to change laws to make it harder for the bad guys to get away with it.

In conclusion, human trafficking is a big problem, but together, we can make a difference. We can help stop this terrible storm and bring sunshine back into the lives of those affected. Let’s stand up, let’s speak out, and let’s fight against human trafficking. Thank you.

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Argumentative Essay on Human Trafficking

Human Trafficking is one of the three major criminal industries that exploit victims through slavery, prostitution, sexual exploitation, and forced labor. The victim is often legally transferred to another country for the benefit of the victims. Slavery has evolved into a modern type of human trafficking. When people hear the word ‘slavery,’ it is sad for many people who find themselves bought and sold as objects and not treated with dignity. Human trafficking is like slavery because of the same way of transporting against their will to another country for the benefit of others. It includes not only women but also men and children. However, it is well known for trafficking women. These victims are often kidnapped, raped, or even sent away to be used as sex slaves. When these victims are taken, extreme violence is the same concept. When used as sex slaves, traffickers physically abuse their victims physically and emotionally to undermine their self-esteem, dignity, and self-esteem.

Sexual trafficking is a global problem and a global problem that people need to be aware of daily. When we see young women and girls on the street, we sometimes turn our backs and think they do it because they want to. However, we do not take time to think about what they would do if forced to do so. No one knows the value and growth of the industry, but it is illegal to smuggle, a prominent criminal sector. However, many people believe that human trafficking can occur only in poorer areas, which may not be possible anywhere.

Many young women or girls are lured into smuggling job offers because of a lack of opportunities in their home country. Economic hardships and political changes have made the economy poorer and more challenging conditions that leave nothing to these people but accept any options from anyone that include being paid. When these women take their promise and get where they are going, they are deceived by the people and get the actual work they are expected to do. Once they are forced to work as sex slaves, it becomes difficult for the victims to escape the psychological violence used by these traffickers to feed their victims. Criminals recognize that trafficking in humans is safer and more profitable than drug trafficking. The Internet includes excerpts from author Julian Sher’s book Somebody’s Daugther, in which he quotes an FBI agent. An FBI agent states, “The sex trade is a new drug trade.” If you are selling people, it shows a negligible risk, but selling drugs requires the criminal to take significant risks by trying not to get caught or lose his product. However, it does not need to lose their “purchase” because these victims believe they are going somewhere with a bright future or because they end up in a traumatic situation. It becomes dangerous for these victims to escape.

N.M. Sajjadul Hoque, author of the book “Female Child Trafficking from Bangladesh: A New Form of Slavery,” does not mention that young adults are forced into slavery; young children are also sold as sex slaves. In this article, she explains how Human Trafficking became a form of slavery used by young women to sell themselves to men. However, child trafficking was a NEW form of slavery and became a reality in Bangladesh. Child trafficking should be used worldwide and in India, Pakistan, Malaysia, and other developing countries in the Middle East. In these countries, child trafficking has increased dramatically. Nearly thousands of young children have been trafficked abroad each year. As these children move to a new area where they have to adjust to a new lifestyle, unique personality traits quickly emerge because they are forced to adapt. The children rely on their trafficker, who provides them with food, clothing, and housing. No matter what the traffickers want to do, the children do it to find a place to live. Selected girls are trafficked and set aside by their hotel owners for sale. In ancient history, a merchant would appeal to his wealthy clients by presenting his complete product. Children of women enter a new culture similar to the culture of slavery.

Not only are young women and girls considered victims, but children are also exploited as sex slaves. According to Paul Abramson, a UCLA professor and authority on sexuality, men believe that when a girl is younger, she will earn more money, and more ‘customers’ will want her as a buyer. The United Nations International Children’s Educations Fund (UNICEF) estimates that each year about 1 million children are forced into prostitution and that they are required to have sex with at least 30 men, with a maximum age of five years. There is a term called child sex tourism, where one goes to another country to have sex with young children. These sexually active children are believed to be helping children financially. They can support themselves with the money they earn from their ‘customers .’ they can support themselves.

Social work has been one of the most effective ways of preventing human trafficking. It takes different approaches to deal with human trafficking. It participates in social and political activities to raise awareness of the resources needed to meet basic human needs. Although victims live this way, they often experience health problems such as HIV / AIDS, physical abuse, chemical intoxication, fatigue, and more. They are trying to rehabilitate a victim who has been involved in human trafficking.

Some people do not know that slavery exists to this day. Many people believe it happened decades ago when African Americans were taken into slavery; however, it is modern-day slavery when African Americans are enslaved. Still, people of all races are forced to become slaves. There are many types of slavery, and human trafficking is one form of modern slavery. Although most people are aware that this issue is going on worldwide, not many people take the opportunity to prevent this problem. Some people do not even know that young children as young as five years old are considered sex slaves. We think sex slaves happen to older women, and they never think children are taken to be them. It is essential to address this issue and show people how the industry turns this ugly and disgusting society into a reality.

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Read the Harvey Weinstein Appeal Ruling

In a 4-3 decision on Thursday, the New York Court of Appeals found that the trial judge who presided over Harvey Weinstein’s case had made a crucial mistake , allowing prosecutors to call as witnesses a series of women who said Mr. Weinstein had assaulted them — but whose accusations were not part of the charges against him.

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State of New York Court of Appeals No. 24 The People &c., V. Respondent, Harvey Weinstein, Appellant. OPINION This opinion is uncorrected and subject to revision before publication in the New York Reports. Arthur L. Aidala, for appellant. Steven C. Wu, for respondent. Sanctuary for Families Inc., et al., New York State Association of Criminal Defense Lawyers, amici curiae. RIVERA, J.: Every person accused of a crime is constitutionally presumed innocent and entitled to a fair trial and the opportunity to present a defense (see U.S. Const Amend VI, XIV; NY Const art I, § 6; Estelle v Williams, 425 US 501, 503 [1976] [“The right to a fair trial is a fundamental liberty secured by the Fourteenth Amendment” and “(t)he presumption of innocence, although not articulated in the Constitution, is a basic component of a fair trial -1-

-2- No. 24 under our system of criminal justice"]; Crane v Kentucky, 476 US 683, 690 [1985] [“Whether rooted directly in the Due Process Clause of the Fourteenth Amendment . . . or in the Compulsory Process or Confrontation clauses of the Sixth Amendment . . . the Constitution guarantees criminal defendants ‘a meaningful opportunity to present a complete defense””], quoting California v Trombetta, 467 US 479, 485 [1984]). Under our system of justice, the accused has a right to be held to account only for the crime charged and, thus, allegations of prior bad acts may not be admitted against them for the sole purpose of establishing their propensity for criminality (see People v Molineux, 168 NY 264 [1901]). Nor may the prosecution use “prior convictions or proof of the prior commission of specific, criminal, vicious or immoral acts” other than to impeach the accused's credibility (People v Sandoval, 34 NY2d 371, 374 [1974]). It is our solemn duty to diligently guard these rights regardless of the crime charged, the reputation of the accused, or the pressure to convict (see Boyd v United States, 116 US 616, 635 [1886] [“It is the duty of courts to be watchful for the constitutional rights of the citizen, and against any stealthy encroachments thereon"]). Defendant was convicted by a jury for various sexual crimes against three named complainants and, on appeal, claims that he was judged, not on the conduct for which he was indicted, but on irrelevant, prejudicial, and untested allegations of prior bad acts. We conclude that the trial court erroneously admitted testimony of uncharged, alleged prior sexual acts against persons other than the complainants of the underlying crimes because that testimony served no material non-propensity purpose. The court compounded that error when it ruled that defendant, who had no criminal history, could be cross examined -2-

-3- No. 24 about those allegations as well as numerous allegations of misconduct that portrayed defendant in a highly prejudicial light. The synergistic effect of these errors was not harmless. The only evidence against defendant was the complainants' testimony, and the result of the court's rulings, on the one hand, was to bolster their credibility and diminish defendant's character before the jury. On the other hand, the threat of a cross-examination highlighting these untested allegations undermined defendant's right to testify. The remedy for these egregious errors is a new trial. However, we reject defendant's claim that the third-degree rape prosecution was untimely under CPL 30.10 because, as a New York resident, his brief absences from the State before the authorities were aware of the crime did not toll the limitations period. Defendant's argument finds no support in the statutory text. Therefore, the trial court properly discounted the days defendant was continuously outside the state and correctly held that the prosecution was not time-barred. Defendant may be retried on this count. I. A. Defendant Harvey Weinstein was charged with: one count of first-degree criminal sexual act under Penal Law § 130.50 (1), based on allegations that, on July 10, 2006, defendant forcibly performed oral sex on Complainant A in his New York City apartment; one count of first-degree rape under Penal Law § 130.35 (1) and one count of third-degree rape under Penal Law § 130.25 (3), based on allegations that, on March 18, 2013, defendant engaged in forcible intercourse and oral sex with Complainant B; and two counts -3-

- 4- No. 24 of predatory sexual assault under Penal Law § 130.95 (2), based on allegations that defendant engaged in the attacks against Complainants A and B after having raped Complainant C-in either 1993 or 1994.¹ The court denied defendant's motion to dismiss the third-degree rape charge as untimely, concluding that under CPL 30.10 (4) (a) (i), the statute of limitations was properly tolled during the time defendant was continuously outside New York State. Defendant was tried before a single jury on all counts. At the time of the alleged crimes and at the time of the trial, defendant was a well-known, powerful man within the entertainment industry, having produced several award winning and highly profitable films. The prosecution's theory of the case was that defendant abused his power to take advantage of aspiring female actors, like complainants, to coerce them into unwanted sexual encounters. According to the prosecution, the quid pro quo of assisting them with their careers in exchange for sexual favors on demand was both common behavior and a well-known secret throughout the film industry. When his victims resisted his sexual demands, the prosecution argued, defendant used force. 1 All the counts include a component of intent to commit the act charged without the victim's consent (see People v Williams, 81 NY2d 303, 316-317 [1993]; People v Worden, 22 NY3d 982, 984 [2013]). To establish first-degree criminal sexual act and first-degree rape the prosecution must prove beyond a reasonable doubt that a defendant used forcible compulsion, to engage in “oral or anal sexual conduct” (Penal Law § 130.50 [1]), or "sexual intercourse" (Penal Law § 130.35 [1]). To establish third-degree rape the prosecution must prove beyond a reasonable doubt that a defendant “engage[d] in sexual intercourse with another person without such person's consent” (Penal Law § 130.25 [3]). Predatory sexual assault requires the prosecution prove beyond a reasonable doubt, as relevant here, that a defendant committed either first-degree rape or first-degree criminal sexual act and first-degree rape, first-degree criminal sexual act, or aggravated first-degree sexual abuse (see Penal Law § 130.70) “against one or more additional persons (Penal Law § 130.95 [2]). - 4-

-5- No. 24 Traumatized by defendant's sexual assaults, and fearing retaliation, the complainants never reported the attacks and continued personal and professional relationships with him for years afterwards. Before trial, the court granted the prosecution's application to admit certain testimony of uncharged crimes and miscellaneous bad acts as an exception to the Molineux rule, prohibiting such evidence, to establish defendant's intent and his understanding of the complainants' lack of consent. Thus, Complainant B could testify about defendant's uncharged sexual assaults against her before and after the charged rape and her awareness of defendant's abusive and threatening behavior, and three other women (the “Molineux Witnesses") could testify regarding defendant's sexual misconduct towards them years before and after the charged offenses involving Complainants A and B. The court also granted, in large part, over defendant's objection, the prosecution's Sandoval application to cross-examine defendant on a broad range of uncharged bad acts should he testify. Pursuant to this ruling, the prosecution was permitted to ask about, for example, whether defendant: directed a witness to lie to defendant's wife; filed an application for a passport using a friend's social security number; told a woman he “could harm her professionally" but could also offer her a book publishing opportunity; used his entertainment company's budget for personal costs; withdrew from a business deal and asked others to cease its funding; hid a woman's clothes; insisted that members of his staff falsify a photo for a movie poster by photoshopping a female actor's head on another woman's nude body; told a private intelligence firm to manipulate or lie to people; scheduled a business meeting in 2012 with a woman under false pretenses; induced -5-

-6- No. 24 executives to lie on his behalf; made threats and committed acts of violence against people who worked for him; abandoned a colleague by the side of the road in a foreign country; physically attacked his brother; threatened to cut off a colleague's genitals with gardening shears; screamed and cursed at hotel restaurant staff after they told him the kitchen was closed; and threw a table of food. The court also permitted the prosecution to cross-examine defendant about the details of the sexual assault allegations described by the Molineux Witnesses during the prosecution's case-in-chief. B. After the court denied defendant's motion to dismiss the third-degree rape charge as time-barred, the case proceeded to trial. Complainant A testified that she had known defendant since 2004 when she met him in a hotel room to discuss a job opportunity she later accepted, during which he made comments about her body and asked her for a massage, which she refused. Sometime later, defendant unsuccessfully propositioned her to travel abroad with him and, at one point, “barged” into her apartment. Two years later, defendant invited Complainant A to a film premiere in Los Angeles and, the day before she was to travel, asked her to his New York hotel room. When she arrived, defendant "lunged" at her to kiss her. She said, “no, no, no” and tried to push him away, but defendant pulled her back towards him and “kiss[ed] and fondl[ed] her.” She attempted to flee, but defendant used “his weight and his body" to lead her into the bedroom, where he pushed her “with his body” until she fell backward onto the bed. She recalled that she tried several times to get up, but each time defendant pushed her back. She “kick[ed]” and “push[ed]" -6-

-7- No. 24 to "get away," but defendant held her arms by her wrists and laid on top of her, holding her down. After she gave up struggling, he “forced himself on [her] orally." After she returned to New York, defendant again asked her to his hotel room where, according to Complainant A, he “grabbed” her by the arm and led her “straight towards the bed." She testified that she “laid there” and “didn't resist physically" as defendant “had intercourse with [her]” while calling her derogatory names. Despite feeling “embarrassed" and unsure of "how to deal with it,” Complainant A maintained a “professional connection" with defendant because she "wanted a job.” Over the next two-and-a-half years, she met defendant in London to “pitch him an idea” and sent him friendly e-mails thanking him for his “support” and signing off with: “Lots of love, [A].” Complainant B testified that she wanted to act since childhood and first met defendant at a party in February 2013, where defendant expressed interest in her career. Defendant subsequently took her to exclusive Academy Awards parties and dinners. Later that same month, defendant invited Complainant B to his hotel room in Los Angeles, California and, when she entered, grabbed both of her arms and tried to kiss her “like crazy" and then sexually assaulted her. Afterwards, she decided to initiate a “real relationship” with defendant and saw him regularly, engaging in consensual oral sex with him. Complainant B testified that, during their relationship, defendant attempted to persuade her to have a sexual interaction with himself and another actress but both women were uncomfortable, and Complainant B left the room. During the defense's cross-examination -7-

-8- No. 24 of Complainant B, the prosecution successfully moved to present the other woman's testimony about this incident and her testimony corroborated Complainant B's description. Complainant B also testified that, in March 2013, she and some friends met defendant for breakfast in a Manhattan hotel. Defendant arrived early and booked a room. Once in the room, Complainant B argued with defendant, saying that they did not “have time" for anything sexual. She stated that she twice tried to leave, but defendant “blocked" her by putting his hand on the door above her head and “slam[ming]” it shut. Defendant told her to undress in a “sharp and angry" tone and when she hesitated, defendant “grab[bed] her hand" and held it to "force" her to undress. When Complainant B was completely naked, defendant told her to lie down on the bed and, after disrobing in the bathroom, he got on top and had intercourse with her. 66 " Complainant B explained that she maintained a friendly relationship with defendant afterwards out of fear for her personal safety and professional prospects. When defendant discovered she was dating another actor, he told her: “ ‘[Y]ou owe me one more time' and “dragg[ed]” her into his Los Angeles hotel room. Complainant B pleaded “no, please, no,” but defendant “lunged" at her and “ripped” her pants off, leaving scratches on both legs. He then forcibly performed oral sex on her, forced her to reciprocate, and forcibly had intercourse with her. She maintained a friendly relationship with defendant during the years that followed, which included consensual sexual relations and emails telling defendant that she loved him. Complainant C, an established Hollywood actor, testified that she met defendant during the early 1990s and that he played a role in her becoming addicted to drugs at that -8-

-9- No. 24 time. Sometime during the 1993-1994 winter, they had dinner together and he left her at her Manhattan apartment. A half hour later, he returned, pushed his way inside, grabbed her near the collar, “led [her] into” the bedroom, and “shoved [her] on the bed." Complainant C explained that she was “[p]unching him” and “kicking him,” but defendant restrained her hands above her head and “raped” her “while [she] was trying to fight, but [she] could not fight anymore because he had [her] [h]ands locked.” Complainant C also testified that, later in 1994, defendant repeatedly called her and sent cars to her hotel room while the two were in London and, the following year, “tricked” her into agreeing to make another film that she did not know his company was producing. C. The three Molineux Witnesses, testified about defendant's individual unwanted sexual advances towards them. Witness 1 stated that she met defendant in 2004 at a Manhattan nightclub while she was working as an actor and defendant said he could help her career. Sometime in 2004 or 2005, she met defendant in a hotel room for a networking event. Defendant led her to the bedroom, where he suddenly put his hand up her skirt and tried to put his hand inside her vagina and apologized when she pulled away. A few weeks later, she agreed to meet defendant at another hotel where, clothed in a bathrobe, he told her that he would sign contracts for her to work only if she had sex with him and his -9-

- 10 - No. 24 assistant, but then told her he was joking and that she would “never make it in this business" unless she changed her attitude. Witness 2 testified that she met defendant during the summer of 2005 while she was an aspiring actor working as a cocktail server at a Manhattan lounge. Defendant gave her his contact information and then, minutes later, “grabbed" her by the arm and led her upstairs to a deserted terrace, where he “pulled" her so that she was facing him and masturbated. A week or two later, Witness 2 was invited to read for a part at defendant's production company but, while in the waiting room, was told that defendant wanted to see her at his apartment. When she arrived, defendant grabbed her arms and threw her on his bed before removing her clothes and having intercourse with her as she “just froze” and "looked off." Witness 2 explained that defendant was “a heavy man” who "weighed [her] down." Defendant then drove Witness 2 back to the studio, but she was not allowed to audition and did not get the part. Witness 3 testified that she met defendant in February 2013 in Los Angeles, where she was working as an actor. Another actor friend of hers invited her to a Beverly Hills hotel to discuss a film script. Defendant invited the two to continue the conversation inside his room and, once inside, led Witness 3 into a bathroom as the friend closed the door behind them. She then testified in detail about how defendant undressed as she nervously laughed before he pulled down her dress and masturbated, despite her protests, while - 10 -

- 11 - No. 24 grasping her breast and asking her how else he could know whether she could act. The prosecution admitted photographs of the dress she had been wearing into evidence.2 Following the testimonies of these three Molineux Witnesses, the trial court instructed the jury that this evidence “must not be considered for the purpose of proving that the defendant had a propensity or predisposition to commit the crimes charged.” The court further explained that the prosecution introduced the Molineux Witnesses to the jurors "for [their] consideration on the question of whether the defendant intended to engage in the sexual acts, and whether each of the complaining witnesses consented.” During the final charge to the jury, the court reiterated that the testimonies of the Molineux Witnesses "was offered for [its] consideration on the issues of forcible compulsion and lack of consent." The prosecution also presented testimony from a forensic psychiatrist and an expert on rape trauma syndrome. She described how sexual assault victims may behave in ways towards their attackers that persons unfamiliar with the syndrome might consider counterintuitive. She attempted to dispel certain rape myths, including that most rapes are committed by strangers and that "credible" victims promptly report attacks and discontinue 2 Defendant was tried in California for this conduct against Witness 3, but the jury failed to reach a verdict. - 11 -

- 12 - No. 24 relationships with their attackers. She further testified that traumatic events narrow the brain's ability to focus on specific details, yielding clearer memories of such events. Defendant did not testify on his behalf but, during cross-examination of the complainants and during closing argument, defense counsel questioned the credibility of the complainants by highlighting their continued personal and professional relationships with defendant and Complainant B's admission that she continued a consensual sexual relationship with defendant after her alleged March 2013 rape. Defendant also presented testimony, as limited by the court, from a psychologist specializing in human memory who testified that exposure to falsehoods regarding a traumatic incident leads to the formation of false memories, which themselves could fade with time. She also testified that asking a traumatized person to remember the trauma could cause additional stress that further impairs their memory of the event.³ The jury acquitted defendant of both counts of predatory sexual assault and the first-degree rape count, and convicted him of first-degree criminal sexual act for the July 10, 2006 Complainant A charge and third-degree rape for the March 18, 2013 3 Defendant also proffered testimony of an expert on human memory but did not call them to the stand after the court limited both proposed experts' testimonies to memory flaws in recovering traumatic events and precluded specific testimony about sexual assault memories. - 12 -

- 13 - No. 24 Complainant B charge. The court sentenced defendant to consecutive terms on each count, an aggregate 23 years in prison, followed by five years post-release supervision. The Appellate Division affirmed (207 AD3d 33 [1st Dept 2022]). The court concluded, as relevant here, that the tolling provisions of CPL 30.10 (4) applied and the third-degree rape prosecution was timely commenced. The court also concluded that the trial court properly admitted the Molineux testimonies to show that defendant's sole interest in the complainants was sexual and their consent was irrelevant to him because, during his prior experiences with the Molineux Witnesses he had, as he had done with complainants, expressed an interest in helping them and yet they “reacted negatively to defendant's advances" (id. at 65). This “demonstrate[d] to the jury that defendant knew that a woman would not consent to having sex with him merely as a quid pro quo for the assistance he could provide them in their professional career” (id.). The court observed that the amount of Sandoval material on which the trial court permitted the prosecution to cross-examine defendant had he testified was “unquestionably large” but that "all of the material allowed by the court was unquestionably relevant” because “[a]llegations that defendant solicited lies or deception went directly to his credibility” and “[h]is abusive or violent behavior in business settings ‘reflected a willingness to place [his] self-interest above the interests of - 13 -

- 14 - No. 24 another person'” (id. at 68-69, quoting People v Wells, 51 AD3d 403, 403 [1st Dept 2008]). A Judge of this Court granted defendant leave to appeal (38 NY3d 1154 [2022]). II. Defendant claims that his third-degree rape conviction should be reversed because the prosecution was commenced beyond CPL 30.10 (2) (b)'s then-applicable five-year statute of limitations (see CPL former 30.10 [2] [b]).4 The prosecution of this count was undisputedly commenced 69 days after expiration of that limitations period, but the prosecution argued that CPL 30.10 (4) (a) tolled certain periods when defendant was not in New York. Defendant claims the tolling provision does not apply here because it applies only to nonresidents, he was not continuously outside the state within the meaning of the statute, and, in any case, CPL 30.10 (4) does not apply to those periods when law enforcement is unaware of the crime. "The plain text of a statute is the best indicator of legislative intent and thus the proper starting place in discerning its meaning" (Town of Irondequoit v County of Monroe, 36 NY3d 177, 182 [2020]); see also People v Cahill, 2 NY3d 14, 117 [2003] [“(T)he plain meaning of the statutory text is the best evidence of legislative intent and, in fact, the only authoritative basis for interpretation"]). The Court has “eschewed efforts to rewrite the statute to achieve what a court or advocate perceives to be a better outcome” (People v 4 The statute was subsequently amended to its current version, which sets a 20-year limitations period or 10 years from when the crime is reported, “whichever is earlier" (CPL 30.10 [a-2]; L 2019, ch 315, § 2). - 14 -

- 15 - No. 24 Anonymous, 34 NY3d 631, 643 [2020]) and has cautioned that, “[w]here a statute describes the particular situations in which it is to apply, and no qualifying exception is added an irrefutable inference must be drawn that what is omitted or not included was intended to be omitted or excluded” (Matter of Alonzo M. v New York City Dept. of Probation, 72 NY2d 662, 665 [1988] [internal quotation marks omitted]; see also McKinney's Cons Laws of NY, Book 1, Statutes, § 363 and the cases cited therein [“(A) court cannot amend a statute by inserting words that are not there, nor will a court read into a statute a provision which the Legislature did not see fit to enact. (A) court cannot, by implication, read or supply in a statute a provision which it is reasonable to suppose the Legislature intentionally omitted"]). Section 30.10 (4) (a) provides, in pertinent part, that, “[i]n calculating the time limitation applicable to commencement of a criminal action," the time period “shall not" include "[a]ny period following the commission of the offense during which (i) the defendant was continuously outside this state or (ii) the whereabouts of the defendant were continuously unknown and continuously unascertainable by the exercise of reasonable diligence" (CPL 30.10 [4] [a]). Nowhere does this provision distinguish between residents and nonresidents and we cannot read into the statute a limitation not adopted by the legislature (see Matter of Alonzo M., 72 NY2d at 665). If the legislature intended this tolling - 15 -

- 16 - No. 24 provision to apply only to nonresidents or that courts should factor residency into a tolling analysis, it would have said so expressly, as have several other jurisdictions.5 Defendant argues that CPL 30.10 (4) (a) has only been applied to cases involving nonresidents, relying principally on People v Knobel, where a nonresident defendant remained continually outside of New York, which this Court concluded thereby tolled the limitations period, adding that “all periods of a day or more that a nonresident defendant is out-of-State should be totaled and toll the Statute of Limitations” (94 NY2d 226, 230 [1999]). However, the Knobel Court did not hold that CPL 30.10 (4) (a) is limited to nonresidents, and the fact that Knobel and other courts have had occasion to apply the statute to nonresidents is simply a consequence of the particular facts of those cases. Nor does the statute contain any requirement that the tolling period apply once authorities know that a crime has been committed and, as with defendant's proposed exclusion for New York residents, we reject defendant's invitation to rewrite the statute to provide such limitation. We also reject defendant's contention that he was not “continuously outside this state" during his brief absences from New York. This argument is based, in part, on his erroneous and now squarely rejected interpretation that CPL 30.10 (4) (a) should not apply to residents. To the extent defendant advocates for a lengthy temporal floor, Knobel instructs to the contrary, as the Court there held that “all periods of a day or more” during 5 See e.g. AK ST § 12.10.040 (a); AZ ST § 13-107 (D); CT ST § 54-193 (e); Idaho Code Ann § 19-404; ILCS CH 720 § 5/3-7 (a) (1); Ind Code Ann 35-41-4-2 (h) (1); IA ST § 802.6 (1); MA ST 277 § 63; MI ST 767.24 (11); MN ST § 628.26 (1); MT ST 45-1- 206 (1); ND ST 29-04-04; NM ST § 30-1-9; OK ST T 22 § 153; OR ST § 131.145 (2)-(3); SD ST § 23A-42-5; TN ST § 40-2-103; WA ST 9A.04.080 (2) (1); WI ST 939.74 (3). - 16 -

- 17 - No. 24 a defendant's absence from the state "should be totaled and toll the Statute of Limitations" (id.). Logically, then, even a day's absence counts. Moreover, defendant's absences would count even under his reading: he was outside of New York for a total of 200 days, including periods lasting up to two weeks. Defendant's policy arguments in support of his interpretation of the tolling provision are properly left to the legislature, the only body constitutionally authorized to enact and amend the statute.6 As the courts below properly concluded, defendant was outside of New York within the meaning of CPL 30.10 (4) (a) for a period of time that tolled the statute of limitations, and, therefore, the third-degree rape prosecution was timely commenced. III. A. Defendant argues that admission of the Molineux Witnesses' testimonies detailing sexual assaults he allegedly committed against them before and after the alleged offense conduct ran afoul of Molineux and its progeny. We agree that this challenge has merit. Indeed, we reject the prosecution's theory, accepted by the Appellate Division and the 6 Relying on People v Quinto (77 AD 3d 76 [2010]) and quoting from People v Jordan, defendant claims, as he did before Supreme Court, that that CPL 30.10 (4) (a) “cannot be read to exclude the period of time during which the police are unaware of the commission of the offense itself" (43 AD3d 1976, 1977 [2007]). Although this claim is preserved, the record contains no evidence regarding when the police became aware of the allegations that gave rise to the charged counts, leaving us without “a factual record sufficient to permit appellate review” of the question underlying his claim (see People v Kinchen, 60 NY2d 772, 774 [1983]). - 17-

- 18 - No. 24 dissenters here, that this testimony showed defendant's state of mind to use forcible compulsion against complainants and his understanding of their lack of consent. That analysis, if adopted, would eviscerate the time-tested rule against propensity evidence, which, in criminal cases, serves as a judicial bulwark against a guilty verdict based on supposition rather than proof, on “collateral matters or ( ) because of [a defendant's] past" or on the defendant's “bad character” alone (People v Alvino, 71 NY2d 233, 241 [1987]). In Molineux, the Court reaffirmed that the "general rule of evidence applicable to criminal trials is that the state cannot prove against a defendant any crime not alleged in the indictment, either as a foundation for a separate punishment, or as aiding the proofs that [they are] guilty of the crime charged” (168 NY at 291). The purpose of the rule is simple: "[E]vidence of a defendant's uncharged crimes or prior misconduct is not admissible if it cannot logically be connected to some specific material issue in the case, and tends only to demonstrate the defendant's propensity to commit the crime charged" (People v Denson, 26 NY3d 179, 185 [2015] [internal quotation marks omitted]). The rule "is the product of that same humane and enlightened public spirit which, speaking through our common law, has decreed that every person charged with the commission of a crime - 18 -

- 19 - No. 24 shall be protected by the presumption of innocence until [they have] been proven guilty beyond a reasonable doubt” (Molineux, 168 NY at 291). To illustrate the universal acceptance of the rule and “the reasons upon which it rests," Molineux quoted its earlier decisions and those of other state courts (168 NY at 291). For example, the Molineux Court noted, as far back as Coleman v People, the Court had explained: 66 "The general rule is against receiving evidence of another offence. A person cannot be convicted of one offence upon proof that [they] committed another, however persuasive in a moral point of view such evidence may be. It would be easier to believe a person guilty of one crime if it was known that [they] had committed another of a similar character, or, indeed, of any character; but the injustice of such a rule in courts of justice is apparent. It would lead to convictions, upon the particular charge made, by proof of other acts in no way connected with it, and to uniting evidence of several offences to produce conviction for a single one' ” (id. at 292, quoting 55 NY 81, 90 [1873]). " The Court also observed that, the following decade in People v Sharp, Judge Peckham observed in a separate opinion that “[t]he general rule is that when a [person] is put upon trial for one offense [they are] to be convicted, if at all, by evidence which shows that [they are] guilty of that offense alone, and that, under ordinary circumstances, proof of [their] guilt of one or a score of other offenses in [their] lifetime is wholly excluded" " (id., quoting 107 NY 427, 467 [1887] [Peckham, J.]). The Molineux Court recalled that, a few years later, Judge Peckham authored the majority opinion in People v Shea explaining: 66 'The impropriety of giving evidence showing that the accused had been guilty of other crimes merely for the purpose of thereby inferring [their] guilt of the crime for which [they are] on trial may be said to have been assumed and consistently maintained by the English courts ever since the common law has itself been in existence. Two antagonistic methods for the judicial investigation of crime and the conduct of criminal trials have existed for - 19 -

- 20 - No. 24 many years. One of these methods favors this kind of evidence in order that the tribunal which is engaged in the trial of the accused may have the benefit of the light to be derived from a record of [their] whole past life, [their] tendencies, [their] nature, [their] associates, [their] practices, and, in fine, all the facts which go to make up the life of a human being. This is the method which is pursued in France, and it is claimed that entire justice is more apt to be done where such course is pursued than where it is omitted. The common law of England, however, has adopted another and, so far as the party accused is concerned, a much more merciful doctrine. By that law the criminal is to be presumed innocent until [their] guilt is made to appear, beyond a reasonable doubt, to a jury of 12 []. In order to prove [their] guilt it is not permitted to show [their] former character or to prove [their] guilt of other crimes, merely for the purpose of raising a presumption that [they] who would commit them would be more apt to commit the crime in question?” (147 NY 78, 99 [1895], citing Sharp, 107 NY at 427). The Molineux Court also cited cases from Massachusetts and Pennsylvania that were to a similar effect (see 168 NY at 293, citing Commonwealth v Jackson, 132 Mass 16, 19 [1882] [noting "the general rule that limits the trial to the immediate act for which the defendant is indicted"]; Shaffner v Commonwealth, 72 Pa 60, 65 [1872] [“It is a general rule that a distinct crime, unconnected with that laid in the indictment, cannot be given in evidence against a prisoner. It is not proper to raise a presumption of guilt, on the ground, that having committed one crime, the depravity it exhibits makes it likely [they] would commit another”]). Molineux recognized exceptions by which evidence of other crimes could be used to prove the charged crime when such evidence “tends to establish (1) motive; (2) intent; (3) the absence of mistake or accident; (4) a common scheme or plan embracing the commission of two or more crimes so related to each other that proof of one tends to establish the others; and (5) the identity of the person charged with the commission of the - 20 -

- 21 - No. 24 crime on trial" (168 NY at 293). Although this list is not exhaustive (see Denson, 26 NY3d at 185), the Court's Molineux jurisprudence “begin[s] with the premise that uncharged crimes are inadmissible and, from there, carve[s] out exceptions" (People v Resek, 3 NY3d 385, 390 [2004]). In order to be admissible, Molineux evidence must “logically be connected to some specific material issue in the case" and be “directly relevant” to it (Cass, 18 NY3d at 559-560). The prosecution has the burden of showing this direct relevance (see Denson, 26 NY3d at 185, citing Cass, 26 NY3d at 560). In other words, “evidence of a defendant's uncharged crimes or prior misconduct is not admissible if it cannot logically be connected to some specific material issue in the case, and tends only to demonstrate the defendant's propensity to commit the crime charged" (Denson, 26 NY3d at 185 [internal quotation marks omitted]). When “the proffered Molineux evidence is relevant to some material fact in the case, other than the defendant's propensity to commit the crime charged, it is not to be excluded merely because it shows that the defendant had committed other crimes” (id. [internal quotation marks omitted]). In reviewing a Molineux ruling, the Court engages in a two-step process. First, it evaluates whether the prosecution has “identif[ied] some issue, other than mere criminal propensity, to which the evidence is relevant” (People v Hudy, 73 NY2d 40, 55 [1988]). This "is a question of law, not discretion” and we review it de novo (People v Telfair, NY3d, 2023 NY Slip Op 05965 at *2 [Ct App Nov. 21, 2023]). Second, if the evidence is relevant to an issue aside from propensity, the Court determines whether its "probative value exceeds the potential for prejudice resulting to the defendant” (Alvino, 71 NY2d at - 21 -

-22- No. 24 242). At this step, "the trial court's decision to admit the evidence may not be disturbed simply because a contrary determination could have been made or would have been reasonable. Rather, it must constitute an abuse of discretion as a matter of law" (People v Morris, 21 NY3d 588, 597 [2013]). However, “any substantial doubt” regarding how “to strike a neat balance between possible prejudice to the defendant, and indispensability of the challenged evidence to the [prosecution's] case. . . should weight the scales in favor of the defendant" (People v Stanard, 32 NY2d 143, 147 [1973]). If the Court concludes that the trial court abused its discretion by admitting Molineux evidence, the Court must determine whether the error was harmless or requires a new trial (see e.g. People v Leonard, 29 NY3d 1, 8 [2017]). 66 The Molineux ruling here fails at Step 1. The trial court admitted the evidence to show defendant's forcible intent when he had sexual relations with complainants, rebut his claim of consent, and explain why complainants were "hesitant to report these assaults." The prosecution argues that “the unusual nature of the entertainment industry . . . and defendant's then-outsized role in [it],” popular “ “misconceptions' about the behavior of sexual assault victims," and the complainants' acceptance of favors from him and, in one case, their continued consensual sexual relations with defendant following the assaults rendered their testimonies “equivocal" on the issue of defendant's intent. Thus, the prosecution contends, the trial court properly admitted the three Molineux Witnesses' testimonies to show his unlawful intent. We disagree and conclude that, as a matter of law, the trial court erroneously held that the prosecution showed that the Molineux Witnesses' testimonies were necessary for - 22 -

-23 - No. 24 a non-propensity purpose (see Hudy, 73 NY2d at 55). First, the complainants' respective testimonies were not "equivocal" on the issue of consent. Complainant A described a violent, forcible sexual assault as well as her efforts to resist by kicking and pushing defendant. Complainant B testified that defendant physically blocked her attempt to leave the hotel room in March 2013 and that, when she did not comply with his demand that she undress, he grabbed her hand to force compliance. Complainant C testified that defendant lunged at her and that, when she tried to walk away, defendant used his weight to lead her to the bedroom where she fell backward onto the bed. She tried to leave but he pushed her back. She kicked and pushed to get away, but defendant used physical force to hold her down with her hands above her head and then forced himself on her as she cried and continued to say "no." There is no equivocality regarding consent when a person says "no" to a sexual encounter, tries to leave, and attempts to physically resist their attacker before succumbing to the attacker's brute physical force. No reasonable person would understand such behavior as having communicated anything other than their rejection of sexual activity. Indeed, a contrary proposition perversely turns the concept of consent on its head. Simply put, there is nothing consensual about the conduct complainants described. Thus, even though the prosecution contends (and the Appellate Division agreed) that the jury could believe complainants' recollections of the sexual attacks yet still believe that defendant - 23 -

- 24 - No. 24 thought they were consenting to the sex, we conclude that such is inconceivable. Complainants' descriptions of events belie any such equivocation in the moment.7 Nor did the fact that complainants maintained relationships with defendant- -some sexual before and after the alleged assaults giving rise to the instant charges necessitate introduction of the Molineux Witnesses' testimonies to show defendant's forcible intent. As the Court has explained, where the crime requires the prosecution to prove forcible compulsion, "[t]he intent required is the intent to perform the prohibited act—i.e. the intent to forcibly compel another to engage" in the sexual act (People v Williams, 81 NY2d 303, 317-318 [1993]). And, when it comes to Molineux, “evidence sought to be introduced to prove a defendant's intention in the crime charged, the probative balance has generally warranted admission of this evidence only where the acts involved in the crimes charged are equivocal so that intention is not easily inferred from the acts alone" (People v McKinney, 24 NY2d 180, 184 [1969] [internal quotation marks omitted]). In other words, “evidence of prior criminal acts to prove intent will often be unnecessary, and therefore should be precluded even though marginally relevant, where intent may be easily inferred from the commission of the act itself" (Alvino, 71 NY2d 233, 242 [1987]). Here, this 7 66 Even the treatise that Judge Singas quotes comments that “ “it is possible, albeit unlikely, for a complainant to testify truthfully that she did not consent to sexual intercourse and that the defendant raped her, and the defendant to raise an honest defense of mistake" " (Singas, J., dissenting op at 5, quoting Richard de Simone & Steven Y. Yurowitz, New York Criminal Law § 7:2 [6 West's NY Prac Series, Dec. 2023 update]). Based on complainants' accounts here, any claim by defendant that he made a mistake in the moment would have been implausible and, perhaps for this reason, that was not his defense. In that respect, Judge Singas's reference to this class of cases is irrelevant. - 24 -

- 25- No. 24 proposed basis for admitting the Molineux Witnesses' testimonies is a candid acknowledgement that the true purpose of this evidence was to bolster complainants' credibilities by showing that others behaved similarly towards defendant even after he made unwanted sexual demands. Of course, this is an impermissible propensity purpose and the trial court therefore should not have admitted the evidence (see Molineux, 168 NY at 291). In reaching this legal conclusion, we take no “step backwards from recent advances in our understanding of how sex crimes are perpetrated and why victims sometimes respond in seemingly counterintuitive ways" (Cannataro, J., dissenting op at 2) and we do not “shut[ ] [our] eyes to the enduring effect of rape culture on notions of consent, and intent,” (Singas, J., dissenting op at 10) as the respective dissents assert. 8 On the contrary, consistent with our judicial role, our analysis is grounded on bedrock principles of evidence and the defendant's constitutional right to the presumption of innocence and a fair trial. 8 Judge Singas discusses various academic theories redefining consent. They are not the law. Moreover, as two law journal student notes Judge Singas references observe (see Singas, J., dissenting op at 14 n 8), as part of an effort to combat campus sexual assault, the legislature in 2015 imposed on institutions of higher learning a uniform definition of "affirmative consent” which “is a knowing, voluntary, and mutual decision among all participants to engage in sexual activity" that "can be given by words or actions, as long as those words or actions create clear permission regarding willingness to engage in the sexual activity" but under which “[s]ilence or lack of resistance, in and of itself" is insufficient (Education Law § 6441 [1]). This definition is not part of the Penal Law and, indeed, some commentators have highlighted potential constitutional problems that might arise from its importation into the criminal law (see e.g. Aya Gruber, Consent Confusion, 38 Cardozo L Rev 415, 449-451 & n 176 [2016] [contending that, when integrated into the criminal law, “strict affirmative consent standards criminalize a significant amount of wanted, consensual sex" that might violate substantive due process under Lawrence v Texas (539 US 558, 578 [2003])]). - 25 -

-26- No. 24 Judge Singas would ignore these principles because, in her view, they fail to account for how rape myths distort jurors' perceptions of victims, and corrupt the deliberative process (see id. at 9-18).⁹ But justice for sexual assault victims is not incompatible with well-established rules of evidence designed to ensure that criminal convictions result only from the illegal conduct charged. Indeed, just as rape myths may impact the trier of fact's deliberative process, propensity evidence has a bias-inducing effect on jurors and tends to undermine the truth-seeking function of trials. Thus, “[w]hen we limit Molineux or other propensity evidence, we do so for policy reasons, due to fear of the jury's ‘human tendency' to more readily ‘believe in the guilt of an accused person when it is known or suspected that [they have] previously committed a similar crime' ” (People v Brewer, 28 NY3d 271, " 9 Judge Singas correctly acknowledges that "[v]ictims of color are especially disadvantaged, through the intersection of rape and racial mythology, because of harmful stereotypes that ascribe heightened sexuality to these victims” (Singas, J., dissenting op at 13). However, racial and ethnic stereotypes and express and implicit bias also play a significant role in the failures of our criminal legal system, as “men of color. . . are still more likely than white men to be falsely accused, falsely arrested[,] . . . [a]nd, yes, even falsely convicted" (Hon. Barbara Madsen, Racial Bias in the Criminal Justice System, 47 Gonz L Rev 243, 245 [2012]. Erosion of our precedents that limit the introduction of uncharged conduct in the manner our dissenting colleagues suggest would only amplify the risk that biased jurors would justify a vote to convict defendants of color on such uncharged conduct in cases where the evidence supporting the charged conduct is weak— an all too real phenomenon (see Brandon L. Garrett, Judging Innocence, 108 Colum L Rev 55, 66 [2008] [observing that a study of the first 200 defendants exonerated by DNA evidence, “73% of innocent rape convicts were Black or Hispanic, while one study indicates that only approximately 37% of all rape convicts are minorities”]; see also Death Penalty Information Center, DPIC Special Report: The Innocence Epidemic [Feb. 18, 2021] at 19, available at https://dpic-cdn.org/production/documents/pdf/The-Innocence- Epidemic.pdf?dm=1683576587 [last accessed Mar. 28, 2024] [study concluding that "63.8% of wrongfully convicted death-row exonerees are people of color, 53.5% of whom are Black"]). Hollowing out the Molineux rule will not end systemic racism, but it may very well exacerbate societal injustices replicated within our courts. -26-

-27- No. 24 276 [2016], quoting People v Ventimiglia, 52 NY2d 350, 359 [1981], citing Molineux, 168 NY at 313). And while the Molineux rule addresses jurors' reliance on propensity evidence, contrary to the dissenters' suggestion, we have a means to address jurors' possible disinclination to believe sexual assault victims who act in ways that appear contrary to the jurors' experiences or views (see Cannataro, J., dissenting op at 6-8; Singas, J., dissenting op at 20-21). The proper method for dispelling rape myths in “nuanced and complex” cases (Singas, J., dissenting op at 24) is the one deployed by the prosecution here: educating jurors about rape myths and social misperceptions about sexual assault with expert testimony explaining rape trauma and survivor responses (see Taylor, 75 NY2d at 288-289). 10 Specifically, testimony from the prosecution's expert provided non-propensity evidence that addressed what some jurors might have seen as counterintuitive acts by complainants when they continued to interact with defendant, and contextualized conduct associated with rape trauma. As the expert explained to the jury, her professional work with sexual assault victims led her to conclude that many victims often maintain contact 10 Judge Singas misconstrues our acknowledgment of this Molineux-compliant technique for combating rape myths as a "conclusion that the Molineux evidence was not necessary" and that it was "cumulative" in light of this "other evidence to dispel rape mythology" Singas, J., dissenting op at 22). At no point does our analysis turn the admissibility of the Molineux Witnesses' testimonies on the availability of other evidence to accomplish this same end. Rather, we hold that their testimonies served no non-propensity purpose as a matter of law. Incidentally, the Molineux Witnesses did not dispel rape myths anyway, given that they rejected defendant's advances. -27-

-28- No. 24 with their attackers out of fear the attacker will retaliate. That testimony was particularly crucial here. Judge Singas asserts that this Court's decision will have adverse effects on other prosecutions. She claims, for example, that “instances in which a trafficker repeatedly leverages workers' undocumented status to coerce them into sex, or a restaurant manager withholds tips from his employees unless they perform sexual acts” will become “a series of individual credibility contests' and unrelated 'misunderstandings'" (Singas, J., dissenting op at 23). However, cases involving such “repeated” conduct likely would feature—much like this case did—direct evidence in the form of testimony from multiple complainants. Judge Singas assumes, with no empirical data, that few such cases involve evidence aside from victim testimony. In fact, many trafficking cases feature much more than that (see e.g. People v Lamb, 37 NY3d 1174, 1175-1177, 1187-1188 [2021] [Singas, J., concurring] [summarizing sex trafficking case featuring evidence of online advertisements, phone records, emails, and photographs of unconscious victims, in addition to victim testimony]). The Molineux rule has not and will not, based on its application to this appeal, present an obstacle to prosecution of such cases, notwithstanding Judge Singas' exaggerated claims to the contrary. Moreover, this was not a single-victim prosecution where there arguably is a heightened risk that rape myths could impair the jury's factfinding and credibility determinations. Instead, three complainants testified to defendant's violent actions on different occasions, years apart, and how they behaved toward him long afterwards. There also were significant differences between complainants and the Molineux Witnesses. All -28-

- 29 - No. 24 three complainants had long-term relationships with defendant, whereas the Molineux Witnesses each interacted with defendant for brief periods. And Complainant B explained that she maintained a consensual sexual relationship with defendant following the alleged criminal conduct, whereas none of the Molineux Witnesses testified about consensual sex with defendant at all. Nor, as the prosecution contends, did “the unusual nature of the entertainment industry” and defendant's stature within it require admission of the Molineux Witnesses' testimonies to show defendant's forcible intent or awareness of complaints' lack of consent during the alleged crimes. According to this argument, defendant might have thought complainants consented in order to advance their careers. The argument has a historical basis: “The casting couch—where, as the story goes, aspiring actresses had to trade sexual favors in order to win roles—has been a familiar image in Hollywood since the advent of the studio system in the 1920s and '30s. Over time, the phrase has become emblematic of the way that sexual aggression has been normalized in an industry dominated by powerful men” (Ben Zimmer, 'Casting Couch': The Origins of a Pernicious Hollywood Cliché, The Atlantic [Oct. 16, 2017], available at https://www.theatlantic.com/ entertainment/archive/2017/10/casting-couch-the-origins-of-a-pernicious- hollywood-cliche/543000/ [last accessed Apr. 4, 2024]). This perverse quid pro quo—i.e., “unwanted sexual relations imposed by superiors on subordinates at work”—however, is not unique to the entertainment industry and “is centuries old" (Reva B. Siegal, "A Short History of Sexual Harassment” in Catherine A. MacKinnon, Directions in Sexual Harassment Law at 3 [2004]). Within such a dynamic, an employer, supervisor, executive, or coworker with some power either offers to help— or agrees not to hinder—a victim's career—a historical reality especially for women because - 29-

- 30 - No. 24 of the historical subjugation of women and their exclusion from positions of influence and power (see Marion Crain and Ken Matheny, Sexual Harassment and Solidarity, 87 Geo Wash L Rev 56, 71 [2019] [“(Q)uid pro quo harassment . . . occurs when a supervisor with the power to grant job-related rewards or impose discipline conditions the receipt of the reward or threatens discipline contingent on the victim's willingness to confer sexual favors (e.g., 'sleep with me and I'll promote you' or 'sleep with me or I'll fire you' ")]; id. at 74 ["(M)uch gender-based harassment, especially hostile work environment harassment, is not driven by sexual desire and may not even be sexual in content. Instead, it takes the form of undermining women's competence to perform their jobs" "] [footnote omitted]; Sexual Harassment Claims of Abusive Work Environment Under Title VII, 97 Harv L Rev 1449, 1454 [1984] [“(Q)uid pro quo sexual harassment, is harassment that forces an employee to choose between acceding to sexual demands or forfeiting job benefits, continued employment, or promotion"] [footnote omitted]). But this is all irrelevant to whether defendant intended to use force during the course of the alleged offense conduct (see Williams, 81 NY2d at 317-318). Here, complainants testified that defendant used force and, thus, his intent to commit the crime would have been established if the jury believed their accounts and concluded that force was used. But the Molineux Witnesses' prior experiences with defendant had no bearing on whether defendant used force against complainants. Testimonies from three individuals about their own unwanted sexual encounters with defendant were therefore “unnecessary" (Alvino, 71 NY2d at 242). Instead, the testimony served to persuade the jury that, if he had attempted to coerce those three - 30 -

- 31 - No. 24 witnesses into nonconsensual sex, then he did the same to the victims on the dates and under the circumstances as charged. That is pure propensity evidence and it is inadmissible against a criminal defendant under Molineux and its century-old progeny (see Hudy, 73 NY2d at 55). This case bears some noteworthy similarities to People v Vargas (88 NY2d 856 [1996]). There, the complainant told the police that the defendant followed her into her apartment building and dragged her to the rooftop where he raped and sodomized her (id. at 857). She testified that, thinking it would later facilitate his apprehension, she exchanged phone numbers with the defendant and agreed to meet him the next day at his apartment, where she had consensual sex with him (id.). The defendant told police that he met the victim in the neighborhood and that she took him to the rooftop of her apartment building, where they had consensual sex (id.). The trial court ruled that, given the defendant's consent defense, the prosecution could, under Molineux, present testimony from four other women that the defendant had committed sexual misconduct against them, and, in response, the defendant abandoned his consent defense and a jury later convicted him on a host of counts, including first-degree rape (id. at 857-858; see also People v Vargas, 215 AD2d 415, 416 [2d Dept 1995] [listing the convicted counts]). This Court reversed his conviction on various sexual offenses, holding that the trial court wrongly admitted the testimonies of the other women to show the defendant's intent (id. at 858). The Court's analysis there applies with equal force here: "[T]wo starkly contrasting scenarios were presented, with only credibility in issue. If the trier of fact believed defendant's version of events, complainant consented to a sexual encounter with him on the night of February 22, 1992. - 31 -

- 32 - No. 24 If the trier of fact found complainant more credible, defendant used force and threats to rape her, with intent readily inferable from the acts alleged. As in Hudy (73 NY2d at 56), the prior misconduct evidence was relevant only to lend credibility to complainant by suggesting that, because defendant had engaged in sexual misconduct with others, he was likely to have committed the acts charged. The evidence therefore was improperly ruled admissible" (id.). Judge Singas attempts to distinguish Vargas because that case involved a “stranger rape” and chides us for not doing the same (Singas, J., dissenting op at 7, 15). Here, of course, we engage in a straightforward analysis that applies Vargas's animating legal principles. Thus, it is Judge Singas―not this Court-who “misses" the relevant point (id.) that here, as in Vargas, defendant's intent was “easily inferred from the commission of the act[s] [themsel[ves]” as recounted by complainants in a case that boiled down to a credibility contest for the jury to evaluate (88 NY2d at 858). In sum, we conclude that the testimony from the Molineux Witnesses was unnecessary to establish defendant's intent and served only to establish defendant's propensity to commit the crimes charged. Neither the prosecution nor the trial court “identified] some issue, other than mere criminal propensity, to which the evidence is relevant" (Hudy, 73 NY2d at 55), and therefore its admission during the prosecution's case- in-chief was error. B. Defendant also claims that the trial court's Sandoval ruling violated his right to testify. For the reasons we discuss below, the trial court abused its discretion when it ruled that defendant, who had no criminal history, could be cross-examined about prior, - 32 -

- 33 - No. 24 uncharged alleged bad acts and despicable behavior which was immaterial to his in-court credibility, and which served no purpose other than to display for the jury defendant's loathsome character. The ruling necessarily and impermissibly impacted defendant's decision whether to take the stand in his defense and thus undermined the fact-finding process in this case, which turned on the credibility of the parties. Under Sandoval, a trial court may “make an advance ruling as to the use by the prosecution of prior convictions or proof of the prior commission of specific criminal, vicious or immoral acts for the purpose of impeaching a defendant's credibility” (34 NY2d at 374 [internal citations omitted]). "When evidence of other crimes has no purpose other than to show that a defendant is of a criminal bent or character and thus likely to have committed the crime charged, it should be excluded" (People v Schwartzman, 24 NY2d 241, 247 [1969]). The trial court must strike a balance “between the probative worth of evidence of prior specific criminal, vicious or immoral acts on the issue of the defendant's credibility on the one hand, and on the other the risk of unfair prejudice to the defendant, measured both by the impact of such evidence if it is admitted after [their] testimony and by the effect its probable introduction may have in discouraging [them] from taking the stand on [their] own behalf” (Sandoval, 34 NY2d at 375). This category of evidence "will always be detrimental to the defendant” and “will have a propensity to influence the jury or the court" (id. at 376). Thus, to ensure that the defendant is not deprived of a fair trial the court must consider whether the evidence will “have a disproportionate and improper impact on the triers of fact,” and “undesirably deter the defendant from taking the stand and thereby deny the jury or the court significant material evidence" (id.). "In weighing - 33 -

- 34 - No. 24 prejudice to the defendant's right to a fair trial, an important consideration may be the effect on the validity of the fact-finding process if the defendant does not testify out of fear of the impact of the impeachment testimony for reasons other than its direct effect on [their] credibility as where the defendant would be the only available source of material testimony in support of [their] defense” (id. at 378). We review Sandoval determinations for abuse of discretion (see People v Walker, 83 NY2d 455, 459 [1994]). Prior crimes and vicious and immoral conduct evidence includes that which shows "a willingness or disposition on the part of the particular defendant voluntarily to place the advancement of [their] individual self-interest ahead of principle or of the interests of society," because such proof “may be relevant to suggest [the defendant's] readiness to do so again on the witness stand” (Sandoval, 34 NY2d at 377). In other words, even if the evidence did not "necessarily involve[] an act of dishonesty-like perjury, fraud, bribery and similar offenses,” evidence that the defendant committed a “ruthless” act "voluntarily and deliberately" supports the notion, that the defendant “may well disregard an oath and resort to perjury if [they] believe[ ] that to be in [their] self-interest” (People v Bennette, 56 NY2d 142, 148 [1982]). This basis for admitting Sandoval evidence is, by its terms, broad and vague. Accordingly, courts must be judicious in resting Sandoval rulings upon it, lest acts of common selfishness lead to mini-trials on the defendant's character that distract the jury from the crimes charged. The question for trial courts at all times is whether the evidence shows a defendant's “lack of in-court veracity" (Sandoval, 34 NY2d at 377). - 34 -

- 35 - No. 24 If so, the evidence may be admitted—but only if not unduly prejudicial—for the “limited purpose of attacking credibility” (id. at 373 n 1). Here, the trial court's Sandoval ruling—to the extent it permitted the prosecution to cross-examine defendant about bullying and fits of anger towards employees, restaurant 11 workers, and business associates—was an abuse of discretion.¹¹ Defendant had no criminal history, many of the acts approved for cross-examination by the court were not criminal in nature and had little if any “probative value as to [defendant's] lack of in-court veracity,” while also prejudicing the jury against defendant (id. at 377). Far in excess of what Sandoval and its progeny allow, the court ruled that the prosecution could ask defendant details about whether he allegedly: verbally abused an employee and also threw food at another worker; bullied, overworked and verbally abused his personal assistant; pulled out of business deals; threw staplers and other objects at people; punched his brother at a business meeting; threatened executives in his office; and photoshopped the head of an actress onto the nude body of another without consent. Without question, this is appalling, shameful, repulsive conduct that could only diminish defendant's character before the jury. But Sandoval does not legitimize destroying a defendant's character under the guise of prosecutorial need. Quite to the contrary, because trial courts have a responsibility to carefully balance the prosecution's 11 The remainder of the Sandoval ruling was a proper exercise of the court's discretion. - 35 -

- 36 - No. 24 interest in attacking the defendant's credibility against the defendant's constitutional rights to a fair trial and to testify on their own behalf (see id. at 376-378). Judge Cannataro attempts to cast our correction of this piece of the Sandoval ruling as a byproduct of a general ““disagreement with the ultimate outcome of the trial court's discretionary balancing determination" " (Cannataro, J., dissenting op at 10-11, quoting Walker, 83 NY2d at 459). The nuance of our holding, which actually leaves much of the trial court's Sandoval determination intact, is more than enough to show that he is mistaken. This is not a case where "the trial court might have been more discriminating” but was nonetheless within its discretion (Walker, 83 NY2d at 458). Rather, the trial court here abused its discretion as a matter of law when it ruled that the prosecution could cross-examine defendant on a broad swath of uncharged misconduct that did not bear on his credibility. Far from "invert[ing] Sandoval," as Judge Cannataro charges (Cannataro, J., dissenting op at 12), we heed it in its original form and apply it straightforwardly to rectify a branch of a ruling that necessarily “undesirably deter[red] the defendant from taking the stand" and thereby “den[ied] the jury. . . significant material evidence" (Sandoval, 34 NY2d at 376). C. The Molineux and Sandoval rulings had a synergistic effect that deprived defendant of his right to a fair trial. This was a case- -like many other sexual assault prosecutions― where the complainant and the defendant are the only ones who know for certain what happened. Here, the Molineux witnesses' testimony bolstered complainants' testimony, -36-

- 37- No. 24 thereby impacting the jury's credibility determination. As the Appellate Division observed, the evidence of uncharged acts would show that defendant demanded sexual favors from aspiring female actors, in return for promises of help with their careers, regardless of their agreement to this quid pro quo. The testimony of the three Molineux Witnesses—although framed as evidence of defendant's intent to use forcible compulsion and his awareness of the victims' lack of consent-was, in courtroom reality, evidence of his propensity to commit the crimes charged. This was not the sole error of constitutional dimension. The erroneous Sandoval ruling allowing the prosecution to cross-examine defendant about allegations of charged and uncharged bad acts was breathtakingly inclusive of behavior that was loathsome but not the type of conduct that would assist the jury in measuring his credibility on the stand. The ruling thus served to discourage defendant from exercising his rights to present a defense and testify on his behalf. Together these errors deprived defendant of the “self-standing” constitutional right to a fair trial, “and proof of guilt, however overwhelming, can never be permitted to negate this right" (People v Crimmins, 36 NY2d 230, 238 [1975]; see also Estelle, 425 US at 503). 12 Even if that were not the case, and if we assumed that these errors were subject to our nonconstitutional harmless-error analysis, we would not deem them harmless. A Molineux error “may be found harmless where 'the proof of the defendant's guilt, without reference to the error, is overwhelming' and where there is no ‘significant 12 Because we are ordering a new trial, we do not address defendant's claim that the trial court violated the Federal and State Constitutions when it declined, first, to discharge a prospective juror and then again once the juror was seated. - 37 -

- 38- No. 24 probability . . . that the jury would have acquitted the defendant had it not been for the error” (People v Arafet, 13 NY3d 460, 467 [2009], quoting Crimmins, 36 NY2d at 241-242). The standard applied to nonconstitutional Sandoval errors is substantively the same (see People v Grant, 7 NY3d 421, 424 [2006] [citation omitted]). Finally, in assessing harmless error, the Court considers all trial errors “cumulatively” (People v Wing, 63 NY2d 754, 756 [1984]). Here, "the whole case turned on a very close question of credibility”—the core choice the jury had to make was whether to believe the complainants' respective versions of events (People v Williamson, 40 NY2d 1073, 1074 [1976]; cf. Benn v Greiner, 402 F3d 100, 106 [2d Cir 2005] [reversing habeas grant because the "case did not present a ‘he said, she said' scenario of two persons, one of whom claimed a sexual encounter was consensual and the other of whom claimed it was not-a scenario in which the exclusion of cross- examination regarding past unverified accusations might well have contributed to the jury verdict in a substantial and injurious way"]). Moreover, the jury had to consider evidence that, both before and after the alleged offense conduct, complainants were outwardly friendly with defendant and maintained personal contacts and in the case of Complainant B, a years-long relationship that included consensual sex. The jury then had to weigh this evidence against defendant's expert evidence about the effects of trauma on memory and the prosecution's expert's testimony that, contrary to public misperceptions -38-

- 39 - No. 24 about how "credible" victims respond, sexual assault survivors often exhibit this same behavior. Even if we were to regard the evidence against defendant as “overwhelming," there remains a“ ‘significant probability' that, absent the trial court's erroneous Molineux ruling, the jury would have acquitted the defendant” (Arafet, 13 NY3d at 467, quoting Crimmins, 36 NY2d at 241-242). And, though "harmless-error analysis in the context of Sandoval ‘does not involve speculation as to whether a defendant would have testified if the legal error had not occurred' " (Grant, 7 NY3d at 425, quoting People v Williams, 56 NY2d 236, 240 [1982]), the erroneous Sandoval determination here “might have affected defendant's decision whether to testify and provide critical information” (Williams, 56 NY2d at 241). Thus, neither error was harmless. IV. "How different is our own common law, which is the product of all the wisdom and humanity of all the ages. Under it the accused comes into a court of justice, panoplied in the presumption of innocence, which shields [them] until [their] guilt is established beyond a reasonable doubt. [Their] character can be thrown into the balance by no one but [themselves]. The incidents of [their] life, not connected with the crime charged, are [their] sacred possession. [They] face[ ] [their] accuser in the light of a distinct charge, with the assurance that no other will be, or can be, proved against [them]” (Molineux, 168 NY at 310). These words are no less true and vital today as they were when first written by this Court in 1901. Over a century later, we reaffirm that no person accused of illegality may be judged on proof of uncharged crimes that serve only to establish the accused's propensity for criminal behavior. At trial, a defendant stands to account for the crimes as - 39 -

- 40 - No. 24 charged. Proof of prior crimes and uncharged bad acts are the rare exception to this fundamental rule of criminal law. Similarly, under Sandoval, cross-examination of the defendant with allegations concerning prior convictions or proof of prior "specific criminal, vicious or immoral acts" is impermissible except to the extent it bears on the defendant's credibility. Thus, it is an abuse of judicial discretion to permit untested allegations of nothing more than bad behavior that destroys a defendant's character but sheds no light on their credibility as related to the criminal charges lodged against them. The trial court's rulings ran afoul of these time-honored rules of evidence. Accordingly, the order of the Appellate Division should be reversed, and a new trial ordered. - 40 -

SINGAS, J. (dissenting): Fundamental misunderstandings of sexual violence perpetrated by men known to, and with significant power over, the women they victimize are on full display in the majority's opinion. By whitewashing the facts to conform to a he-said/she-said narrative, - 1 -

-2- No. 24 by ignoring evidence of defendant's manipulation and premeditation, which clouded issues of intent, and by failing to recognize that the jury was entitled to consider defendant's previous assaults, this Court has continued a disturbing trend of overturning juries' guilty verdicts in cases involving sexual violence. The Molineux rule—created by this Court— has never been static. Instead, its use has evolved over time to meet the challenges of complex criminal prosecutions. Unfortunately, in the context of sexual assault, that evolution lapses today with a decision that has all but ended the use of Molineux evidence in such cases. I fully join Judge Cannataro's dissent but write separately to highlight how the majority's determination perpetuates outdated notions of sexual violence and allows predators to escape accountability. The overarching issue presented by this case is whether the trial court properly admitted evidence of defendant's prior sexual assaults. Whether such Molineux evidence—i.e., evidence of a defendant's prior crimes and other bad acts—is admissible is guided by a two-step analysis. First, a court must consider whether the evidence is relevant to a material issue other than defendant's criminal propensity (e.g., intent). If the evidence is relevant for an appropriate purpose, the court must then determine whether it should be excluded for other reasons, such as its lack of probative value or risk of undue prejudice (see People v Denson, 26 NY3d 179, 185-186 [2015]). Remarkably, the majority holds that the proffered evidence fails at "Step 1," concluding that evidence of defendant's past sexual assaults was irrelevant to this case (majority op at 22). The majority does not hold, under "Step 2," that this evidence was too overwhelming, too dissimilar from the charged crimes, too remote in time, or too prejudicial. Rather, it concludes that additional evidence -2-

-3- No. 24 of defendant's intent is not relevant to the issues the jury needed to decide, as a matter of law, because no rational person could accept the victims' testimony recounting the violence committed against them and have any lingering doubts as to defendant's state of mind. While the majority's holding may, at first glance, appear to endorse a utopic vision of sexual assault prosecution in which a victim's word is paramount, the reality is far bleaker. Critically missing from the majority's analysis is any awareness that sexual assault cases are not monolithic and that the issue of consent has historically been a complicated one, subject to vigorous debate, study, and ever-evolving legal standards (see People v Regan, 39 NY3d 459, 475-482 [2023, Singas, J., dissenting]). By ignoring the legal and practical realities of proving a lack of consent, the majority has crafted a naïve narrative: that within the most fraught and intimate settings, intent is readily apparent, and issues of consent easily ascertained. This conclusion deprives juries of the context necessary to do their work, forecloses the prosecution from using an essential tool to prove intent, ignores the nuances of how sexual violence is perpetrated and perceived, and demonstrates the majority's utter lack of understanding of the dynamics of sexual assault. Because New York's women deserve better, I dissent. I. Defendant was charged with one count of criminal sexual act in the first degree, one count of rape in the first degree, one count of rape in the third degree, and two counts of predatory sexual assault. An element of each is "that the sexual act was committed without consent of the victim" (Penal Law § 130.05 [1]). Defendant's theory throughout the case was that the victims consented to the sexual acts, and that he had ongoing, quid pro quo -3-

- 4- No. 24 relationships with them. His position was that his victims were using him, a Hollywood producer of immense stature and influence, to further their careers- that his victims willingly exchanged sexual favors for professional ones- -and the parties shared this understanding. The defense drew the jury's attention to the jobs defendant secured for his victims, the roles they auditioned for, the scripts they sent him, the parties and movie premieres they asked to attend, and the things he bought for them. In the world the defense painted for the jury, “[s]he was going to do anything she needed to do to have the career that she wanted to have." Simply put, "this is not a sexual assault. This is someone who agrees to do what has then been discussed.” The manner in which the case was defended made this point clear—in defendant's mind, these were consensual transactions and she "made him believe that [she] wanted to be there.” A. Because consent was at the heart of this case, the People necessarily had to demonstrate a lack of it. The People may prove "that the sexual act was committed without consent of the victim” through evidence of forcible compulsion (Penal Law § 130.05 [1]).' “The intent required is the intent to perform the prohibited act―i.e., the intent to forcibly compel another to engage" in the sexual act (People v Williams, 81 NY2d 303, 316-317 1 As to third-degree rape, in addition to forcible compulsion, the People may prove a lack of consent under a different subsection by demonstrating that “the victim clearly expressed that he or she did not consent to engage in such act, and a reasonable person in the actor's situation would have understood such person's words and acts as an expression of lack of consent to such act under all the circumstances” (Penal Law § 130.05 [2] [d]). - 4 -

-5- No. 24 [1993]). A finding of intent to forcibly compel "necessarily" involves a finding "that [a] defendant[] believed the victim did not consent to the sexual activity” (id. at 317 [emphasis added]). Accordingly, in order to prove forcible compulsion, the People were required to demonstrate not only that defendant used force, but that defendant used force believing that the victim did not consent. Indeed, "it is possible, albeit unlikely, for a complainant to testify truthfully that she did not consent to sexual intercourse and that the defendant raped her, and the defendant to raise an honest defense of mistake in that he believed she was consenting and, therefore, that he lacked the intent required for rape. Under New York law, a good faith mistake that negates the mens rea necessary to commit a crime is a defense. In such a situation, if the jury believes both parties, it must acquit the defendant” (Richard de Simone & Steven Y. Yurowitz, New York Criminal Law § 7:2 [6 West's NY Prac Series, Dec. 2023 update] [emphasis omitted]). The People therefore sought to prove defendant's “intent to forcibly compel” his victims (Williams, 81 NY2d at 317)—and necessarily the absence of any mistake as to consent- through the testimony of witnesses regarding their experiences of nonconsensual encounters with defendant under similar circumstances. After interviewing "over 100 people," the prosecution limited their application to five witnesses. The trial court further winnowed this evidence to three witnesses and granted the People's application. 266 'Forcible compulsion' means to compel by either” the “use of physical force" or "a threat, express or implied, which places a person in fear of immediate death or physical injury to [themselves] or another person, or in fear that [they] or another person will immediately be kidnapped" (Penal Law § 130.00 [8] [a], [b]). -5-

-6- B. No. 24 " This Court decided People v Molineux (168 NY 264 [1901]) more than a century ago, “but its foundation remains unchanged: a criminal case should be tried on the facts and not on the basis of a defendant's propensity to commit the crime charged” (People v Rojas, 97 NY2d 32, 36 [2001]; see People v Cass, 18 NY3d 553, 559 [2012]). “‘[T]he familiar Molineux rule states that evidence of a defendant's uncharged crimes or prior misconduct is not admissible if it cannot logically be connected to some specific material issue in the case, and tends only to demonstrate the defendant's propensity to commit the crime charged' ” (Denson, 26 NY3d at 185, quoting Cass, 18 NY3d at 559; see People v Frumusa, 29 NY3d 364, 369 [2017]). But “evidence of uncharged crimes and prior bad acts may be admitted to prove the specific crime charged when it tends to establish” a defendant's "intent” (Cass, 18 NY3d at 560; see Denson, 26 NY3d at 185) or “state of mind" (People v Ingram, 71 NY2d 474, 476 [1988]). "Admission of such proof-where intent cannot be inferred from the act or where [the] defendant claims [they] acted innocently—is founded on the law of probabilities. The theory is that the more often the act constituting the crime has been done, the less the likelihood that it could have been done innocently, as if by chance" (id. at 479). "It is the duplication of the inculpatory conduct which makes the innocent explanation improbable” (id. at 480; cf. People v Caban, 14 NY3d 369, 375 [2010] ["a defendant who is repeatedly negligent in the same way may be found to be unable or unwilling to learn from (their) mistakes”]). When "the proffered Molineux evidence is relevant to” intent, “it is not to be excluded merely because it shows that the defendant ha[s] committed other crimes” (Cass, 18 NY3d at 560). -6-

-7- No. 24 Whether Molineux evidence is admissible to prove a defendant's intent depends on whether “intent may be easily inferred from the commission of the act itself" (People v Alvino, 71 NY2d 233, 242 [1987]). Where a defendant's intent is obvious from the action itself, evidence that the defendant engaged in similar conduct on prior occasions is not necessary to shed light on defendant's state of mind. But “where the act itself is equivocal and, unless accompanied by some guilty knowledge, the transaction would not be criminal,” a culpable mental state is not readily inferable from the commission of the act (id. at 242-243). When “evidence that [the] defendant did the act may allow no ready inference of [the] defendant's guilty state of mind” (id. at 243), Molineux evidence may be admitted as additional proof. A guilty mens rea may be easily inferred where, for example, a defendant puts a gun to a victim's head and pulls the trigger (see People v Katz, 209 NY 311, 328 [1913]) or in the context of a violent stranger rape, like that in People v Vargas (88 NY2d 856 [1996]). In Vargas, the defendant followed his victim, a woman he had never met before, into her apartment building, “pinned her in the corner, threatened to kill her, blindfolded her[,] and dragged her to the roof landing where he raped and sodomized her” (id. at 857). Under those circumstances, it is difficult, if not impossible, to ascribe any intention to the perpetrator other than a guilty one (see People v Leonard, 29 NY3d 1, 8 [2017] [“defendant's alleged action of touching the victim's vagina” while the victim was unconscious was "not an ‘equivocal' act capable of being understood” as innocently committed]). -7-

-8- No. 24 Intent is not so clear from a defendant's actions alone, however, when they are subject to an “innocent explanation" (see Ingram, 71 NY2d at 480). For example, in Ingram, the defendant was present at a gas station during a robbery and drove the getaway car. Because the defendant asserted that he was only there to buy gas and had no idea that his passenger was going to commit a robbery, we held that Molineux evidence of his involvement in a similar robbery was properly admitted as relevant “to refute [his] claim of an innocent state of mind” (id.). Rather than limiting the jury to viewing the defendant's actions in a siloed context, the jury was permitted to consider his prior criminal behavior when evaluating whether his presence at the gas station was indeed innocent. Perhaps the area of criminal prosecution with the most inscrutable mens rea determination is that of acquaintance sexual assault.³ As our understanding of acquaintance assault has grown, the need for Molineux evidence to aid the jury has become more apparent. These cases require exacting consideration of each party's mental state at each stage of the relevant encounters: What did each intend and what did each know of the other's intentions? It is within this context that the trial court allowed the jury to hear instances of defendant's prior sexual assaults to aid them in determining if defendant 3 The difficulties posed to prosecutions of acquaintance sexual assault are reflected in the lower conviction rates of these crimes as compared to conviction rates of stranger sexual assault (see Kristen McCowan et al., A Rape Myth in Court: The Impact of Victim- Defendant Relationship on Sexual Assault Case Outcomes, 26 Berkeley J Crim L 155, 174 [2021] [“ample research suggests that jurors are far more likely to convict in stranger rape cases than in acquaintance rape cases" (emphasis omitted)]; Claire R. Gravelin et al., Blaming the Victim of Acquaintance Rape: Individual, Situational, and Sociocultural Factors, 9 Frontiers Psych, No. 2422 at 2 [2019] [“acquaintance rape cases have a lower probability of conviction in the courts than those that fit with a stranger rape script”]). -8-

-9- No. 24 perpetrated sexual violence or if he indeed thought that he had his victims' consent to behave as he did. II. “[R]ape is a crime that is permeated by misconceptions” (People v Taylor, 75 NY2d 277,288 [1990]). Indeed, sexual assault cases are mired in complex relationship and power dynamics and shadowed by archaic social and cultural attitudes about sexual violence (see Meagen M. Hildebrand & Cynthia J. Najdowski, The Potential Impact of Rape Culture on Juror Decision Making: Implications for Wrongful Acquittals in Sexual Assault Trials, 78 Alb L Rev 1059, 1078 [2015] [citing studies which find that jurors with higher levels of rape myth acceptance are more likely to acquit in sexual assault trials]). The defense sought to capitalize on these pervasive rape myths, 4 and rape culture at large, asking the jury to believe that, despite their words and actions, the victims were consenting. Failing to confront this difficult reality, the majority instead characterizes this case as “boil[ing] down" to a simple “credibility contest” (majority op at 32).5 The majority does this despite 4 Rape myths are the "prescriptive beliefs about the scope, causes, context and consequences of sexual aggression that serve to deny, downplay[,] or justify sexually aggressive [behavior] of (usually) men against (usually) women” (see Joseph Briggs & Russ Scott, 'Rape Myths' and a 'Reasonable Belief" of Consent, 27 Psychiatry Psych & L 750, 765 [2020]; see also Alexa Sardina & Alissa R. Ackerman, Restorative Justice in Cases of Sexual Harm, 25 CUNY L Rev 1, 7-8 [2022]). 5 Even that credibility determination hinges on factors beyond whether the victim has demonstrated herself to be a truthful witness, for the perception of a victim's credibility is influenced by antiquated expectations of how victims should act, both during the crime and at trial (see generally Deborah Epstein & Lisa A. Goodman, Discounting Women: Doubting Domestic Violence Survivors' Credibility and Dismissing Their Experiences, 167 U Pa L Rev 399 [2019]; Louise Ellison & Vanessa E. Munro, Reacting to Rape: Exploring -9-

- 10 - No. 24 the fact that defendant himself, by orchestrating how these encounters played out, created the very ambiguity concerning his state of mind that the majority will not allow the People to negate (see People v Valentin, 29 NY3d 150, 157 [2017]; Cass, 18 NY3d at 561; Ingram, 71 NY2d at 479). Consequently, the majority not only ignores how this case was litigated but shuts its eyes to the enduring effect of rape culture on notions of consent, and intent. A. "[R]esearch across law, sociology[,] and psychology has suggested that jurors may be influenced in their deliberations by a number of extra-legal stereotypes about 'appropriate' socio-sexual [behavior]," including the victim's conduct "in the lead-up to the incident" and "the existence of any previous flirtation or intimacy with the defendant” (Reacting to Rape at 202-203; see Dan M. Kahan, Culture, Cognition, and Consent: Who Perceives What, and Why, in Acquaintance-Rape Cases, 158 U Pa L Rev 729, 761 [2010]).6 Consequently, what one juror perceives as a “lack of consent” another may not. And when one juror concludes that a reasonable person in the defendant's position would have understood the complainant's actions as indicating a lack of consent, another may not. Indeed, defense strategy in sexual assault cases may take advantage, as the defense sought Mock Jurors' Assessments of Complainant Credibility, 49 Brit J Criminology 202, 211 [2009]). 6 Rape myth usage is a problem that extends beyond jurors, as one recent study found that "[r]ape myths do appear to be a common and widely used discourse in sexual assault cases" among American state appellate judges (see Holly Boux, "If You Wouldn't Have Been There That Night, None of This Would Have Happened to You": Rape Myth Usage in the American Judiciary, 40 Women's Rts L Rep 237, 259 [2019]). - 10 -

- 11 - No. 24 to do here, of societal misconceptions about sexual violence and enlarge or create ambiguity around a defendant's state of mind and what actions a defendant may have perceived as indicating consent (see ‘Rape Myths' and a 'Reasonable Belief' of Consent at 766; Dominic Willmott et al., Jury Decision-Making in Rape Trials: An Attitude Problem?, in David A. Crighton & Graham J. Towl, Forensic Psychology 94, 105-106 [3d ed 2021]).7 Antiquated notions of sexual violence persist, consciously and unconsciously, throughout our population and within jury pools. This Court has already recognized the disconnect between our social norms and our professed social values and acknowledged the influence of toxic rape mythology on jurors' conceptions of consent (see Taylor, 75 NY2d at 288-289 [holding that expert testimony regarding “rape trauma syndrome” is admissible under certain circumstances]). Considering the intricacies of the victims' testimony here, it is clear that there were numerous opportunities for rape myths to insidiously work their way into the jury's analysis of defendant's state of mind and importantly, into their analysis of whether he reasonably understood that his victims were conveying a lack of consent. Ostensibly, we live in a culture where “no means no" and that is the end of the conversation. In practice, when a woman says "no," some hear "yes,” “not yet,” or "convince me" (see Douglas N. Husak & George C. Thomas, III, Rapes Without Rapists: 7 Notably, "the impact of prejudicial attitudes and misconceptions surrounding rape have been so well documented within past research, that judges in England and Wales now routinely instruct jurors in rape trials to avoid drawing upon such myths and extra-legal influence [while] judging the case" (Jury Decision-Making in Rape Trials at 102). - 11 -

- 12 - No. 24 Consent and Reasonable Mistake, 11 Phil Issues 86, 95-96 [2001]; Charlene L. Muehlenhard & Lisa C. Hollabaugh, Do Women Sometimes Say No When They Mean Yes? The Prevalence and Correlates of Women's Token Resistance to Sex, 54 J Personality & Soc Psych 872, 872 [1988]). Pursuant to the myth that a “no” may actually be an invitation, some believe that “[a]ggressive or violent tactics are part of the ordinary seduction" (see Sarah Gill, Note, Dismantling Gender and Race Stereotypes: Using Education to Prevent Date Rape, 7 UCLA Women's LJ 27, 46 [1996]). As a result, many view consent as something to be negotiated, bargained for, or coerced. In one mock jury study evaluating conceptions of sexual assault and their impact on criminal prosecutions, jurors, "[f]ocusing on the degree of verbal resistance offered by the complainant, also often questioned whether the complainant had ‘done enough to say no' in simply telling the defendant to 'stop' and ‘get off' her . . . . Such comments were often accompanied by conjecture that the defendant may have believed reasonably, in the opinion of many jurors—that the complainant was a willing sexual partner” (see Louise Ellison & Vanessa E. Munro, A Stranger in the Bushes, or an Elephant in the Room? Critical Reflections Upon Received Rape Myth Wisdom in the Context of a Mock Jury Study, 13 New Crim L Rev 781, 791 [2010]). Jurors consider more than verbal and physical expressions of resistance: they consider their form and degree, and whether other actions by the victim may have negated any resistance. Even where a victim “may communicate that he or she does not consent, the jury may still look for objective signs of non-consent, such as resistance and use of force" (see Becky Farley, Note, A Perpetrator's Paradise: Outdated Sexual Assault Statutes Provide Minimal Protection to Survivors Who are Victimized in Common Sexual Assault Scenarios, 17 Wyo L Rev 315, 338 [2017]). This very Court once required a victim - 12 -

- 13 - No. 24 to exert "the greatest effort of which she is capable therein, to foil the pursuer” for such rape to qualify as a legal offense (People v Dohring, 59 NY 374, 383 [1874]). Though New York has “eliminated resistance as an element of rape, the requirement of resistance, and the corresponding presumption of consent if resistance is absent, persists" (see Lisa Avalos, Seeking Consent and the Law of Sexual Assault, 2023 U Ill L Rev 731, 735 [2023]). Even where a victim asserts physical resistance, “jurors continue to be skeptical" where the victim “did not resist to their satisfaction” (I. Bennett Capers, Real Women, Real Rape, 60 UCLA L Rev 826, 863 [2013]). And even where a victim asserts physical and verbal resistance, jurors will consider whether the victim ceased resistance at some point. While decades of research informs us that this is an entirely normal response to the trauma of sexual violence (see Sunda Friedman TeBockhorst et al., Tonic Immobility Among Survivors of Sexual Assault, 7 Psych Trauma: Theory Rsch Prac & Poly 171 [2015]), the problematic belief persists that a victim's "freezing up" during the encounter is indicative of consent (Jen Percy, What People Misunderstand About Rape, NY Times, Aug 22, 2023, available at https://www.nytimes.com/2023/08/22/magazine/immobility- rape-trauma-freeze.html [last accessed Apr. 15, 2024]). Jurors also consider whether the victim's other actions “sen[t] coded signals of sexual interest," including whether the victim willingly met her attacker and, if so, whether it was in a private, intimate setting (see Reacting to Rape at 207). Victims of color are especially disadvantaged, through the intersection of rape and racial mythology, by harmful stereotypes that ascribe heightened sexuality to these victims (see Real Women, Real Rape at 863-865; Darren Lenard Hutchinson, Ignoring the Sexualization of Race: - 13 -

- 14 - No. 24 Heteronormativity, Critical Race Theory and Anti-Racist Politics, 47 Buff L Rev 1, 84-86, 6 " 89, 93-96 [1999]) and characterize them as 'less harmed by an assault' ” (Real Women, Real Rape, at 867, quoting Gary D. LaFree et al., Jurors' Responses to Victims' Behavior and Legal Issues in Sexual Assault Trials, 32 Soc Probs 389, 401-402 [1985]). Additionally, jurors will look to the nature of the parties' relationship and, specifically, whether they had consensual sexual encounters in the past which “provides an opening through which judgments about the (mis)communication of signals of sexual interest are introduced” (A Stranger in the Bushes at 789). The “generalized consent" concept postulates that "consent to prior sexual intercourse either indicates consent to subsequent intercourse or suggests a greater likelihood that the defendant reasonably believed the victim consented to the later encounter. This notion effectively creates a presumption of consent to sexual intercourse on any specific occasion that the victim must somehow negate" (Note, Acquaintance Rape and Degrees of Consent: "No" Means “No,” But What Does "Yes" Mean?, 117 Harv L Rev 2341, 2342 [2004] [footnote omitted]).8 8 The growing movement toward an affirmative consent standard, or a “yes means yes” standard, reflects the shortcomings of a system which requires a victim to proactively express a lack of consent (see generally Eric Sandoval, The Case for an Affirmative Consent Provision in Rape Law, 94 ND L Rev 455 [2019]; Michelle Lewis, Note, University Adjudication of Sexual Assault: How Affirmative Consent Can Help Close the Gap, 23 Sw J Intl L 351 [2017]; Chandler Delamater, Note, What "Yes Means Yes" Means for New York Schools: The Positive Effects of New York's Efforts to Combat Campus Sexual Assault Through Affirmative Consent, 79 Alb L Rev 591 [2016]). Recognizing that the public's varied opinions regarding the method and manner in which victims must express their lack of consent clouds these issues, the legislature enacted a requirement that New York colleges and universities adopt an affirmative consent standard in their codes of conduct (Education Law § 6441 [1]). If the majority's unrealistic view of how consent - 14 -

- 15 - No. 24 The majority misses this point entirely when it draws exaggerated, and frankly confounding, parallels between the facts of this case and those in Vargas. The sexual violence in Vargas, as described earlier, fits within the prototypical construct of “real” rape—“a sudden, surprise attack by an unknown, often armed, sexual deviant [which] occurs in an isolated, but public, location, and the victim sustains serious physical injury, either as a result of the violence of the perpetrator or as a consequence of her efforts to resist the attack" (A Stranger in the Bushes at 783). "Real" rape does not implicate the same issues as acquaintance assaults. Indeed, here, because the victims know defendant, they are forced to contend with heightened scrutiny of their actions that draws on the problematic rape myths delineated above (see Nicholas J. Little, Note, From No Means No to Only Yes Means Yes: The Rational Results of an Affirmative Consent Standard in Rape Law, 58 Vand L Rev 1321, 1332-1333 [2005] [explaining why jurors are more likely to believe claims of non-consent in cases of “real” rape]).⁹ Casting this case and Vargas in the same light allows the majority to conclude that it is as easy for this jury to find that the victims were raped as it was for the jury in Vargas to draw that same conclusion. plays out in intimate settings were true, this legislative action and other ongoing conversations around consent standards would be largely unnecessary. 9 The impact of these rape myths on whether a victim receives justice goes beyond what happens in the courtroom and affects a victim's decision of whether to report the crime in the first instance (see Jessica Woodhams et al., Behavior Displayed by Female Victims During Rapes Committed by Lone and Multiple Perpetrators, 18 Psych Pub Poly & L 415, 418 [2012]; Kathleen Daly & Brigitte Bouhours, Rape and Attrition in the Legal Process: A Comparative Analysis of Five Countries, 39 Crime & Just 565, 572-573 [2010]). - 15 -

- 16 - B. No. 24 This discussion of rape myths is not merely theoretical. Beyond being deeply rooted societal attitudes that jurors have to grapple with, the defense encouraged the jurors to apply these attitudes to the facts of this case. Defense counsel emphasized to the jury that Victim B, according to her own testimony, did not exert physical resistance in that she did not "tr[y] to push [defendant] off of her in any way." Defense counsel further implored the jury to adopt the mindset that Victim B's initial verbal resistance was disingenuous or fleeting. Victim B testified that she initially told defendant, “We don't have time,” consistent with her testimony that “[o]ftentimes before we would engage in something sexual, there was a negotiation and me trying not to do something.” But defense counsel emphasized that Victim B stopped saying no quickly after the encounter began and then, according to her testimony, “what does she do? Gets naked and lays on the bed.” The prosecution further had to contend with the fact that Victim A also ceased resistance at some point; that, according to her testimony, she “checked out” and “endure[d] it.” Defense counsel also argued that the victims' actions demonstrated their sexual interest. Playing on the myth of generalized consent, the defense hinted or outright asserted that the victims had prior, consensual sexual encounters with defendant. Defense counsel stated that Victim A had been “to Harvey's apartment alone to spend time with him” one night and “[t]hey ha[d] a nighttime meeting in a bar [on another]. I want you to think ... about what that meeting was really about." With respect to Victim B, the defense posed, "[W]hy does [defendant] get a room at the Doubletree? ... [B]ecause he was going to see the woman he was having a sexual relationship with.” The defense noted their past sexual - 16 -

- 17 - No. 24 encounters, asking Victim B about a time that she had “put lotion in [her] hand and put it on [defendant's] back . . . [w]hile he is laying on the bed" on one occasion. The defense further asked Victim B whether she "never wanted to have sex with" defendant and was "lying to [defendant] every single time [she] engaged in sexual activity with him that [she] didn't want to have” and whether she was lying when she had previously told defendant that one encounter was “the best [she] ever had." Counsel concluded, “Well, you made him believe that you wanted to be there, isn't that right?” “You are allowing all this to happen………. Manipulating him to make him think that you wanted to see him by sending .... him e-mails, by going to meet with him and by engaging in consensual sexual acts?" "As manipulated as you felt, you manipulated Harvey Weinstein every time you continued to see him after each individual sexual encounter." The defense asked her, “You decided to go out with a married man, correct? . . . You decided to have sexual relations with [him]?” Defense counsel also emphasized that both victims willingly met defendant in the intimate settings of his apartment or hotel. Indeed, when asking Victim A “about [her] decision to go over to the Soho apartment,” the defense confirmed, “Well, you did go there, correct?" "[Y]ou decide[d] to go?” With regard to Victim B, defense counsel asked, “[Y]ou didn't make the choice to walk out the door? You made the choice to go up to the hotel room?" Defendant's quid pro quo theory inserted another innocent explanation of defendant's conduct for the jury to consider and put the professional favors that defendant granted his victims at the forefront of the case. Regarding Victim A, the defense asserted that “[s]he cared [about her relationship with defendant] because she was using him for - 17 -

- 18 - No. 24 jobs. She cared because she wanted him to fly her places." Defense counsel reiterated that defendant secured a production position for Victim A on his company's television show; that the day after the incident, Victim A flew to Los Angeles on a ticket paid for by defendant's company; and that she traveled back to New York two weeks later, again on defendant's company's dime. Regarding Victim B, the defense asserted that she was using defendant for her career and “we know that's exactly what she was doing.” “[S]he made a choice that she wanted to be in his world. She made a choice she wanted the life that he could potentially provide for her.” Defense counsel told the jury that on the day of the incident with Victim B, she did a reading for the opportunity to be cast in one of defendant's movies. Additionally, defendant came to the hotel the morning of the rape at the request of Victim B, to do her a favor and meet her friend who was an agent in the industry. The defense asked Victim B, “[Y]ou didn't want that stigma” of “sleeping with Harvey Weinstein . . . [b]ut you wanted the benefit of what the action got you?” This line of questioning suggested to the jury that because defendant offered professional rewards, the sex was necessarily consensual. Confronted with the defense's arguments, it was entirely possible for the jury to believe the victims' accounts of defendant's actions while at the same time accepting defendant's assertion that he believed this was a consensual transaction. In this circumstance, even if the jury believed the victims when they said that they resisted, it would have to acquit defendant. Nonetheless, the majority holds that the facts here were simple to parse, and that defendant's prior sexual assaults (where his quid pro quo understanding failed) were irrelevant to the issues of intent and consent. - 18 -

- 19 - III. No. 24 Viewed in proper context, in light of our contemporary understanding of acquaintance sexual violence, the proffered Molineux testimony unquestionably had a "natural tendency to disprove defendant's specific claim as to h[is] state of mind" (People v Bradley, 20 NY3d 128, 134 [2012] [internal quotation marks and some brackets omitted]) and “make[ ] the innocent explanation improbable” (Ingram, 71 NY2d at 480). As the unanimous Appellate Division aptly explained, the Molineux witnesses "described an arc of events where defendant met her, flattered her by expressing his willingness to help her advance her career in Hollywood, and then put in motion a plan where he could be alone with her. As soon as it was opportune, he made an overt sexual advance for which there was no indication that there was consent" (207 AD3d 33, 65 [1st Dept 2022]). The evidence thus demonstrated “that defendant did not see the women as romantic partners or friends, and that his interest in them and their talents was feigned" (id.). Further, “defendant's goal at all times was to position the women in such a way that he could have sex with them, and that whether the women consented or not was irrelevant to him” (id.). These Molineux witnesses' negative reactions to defendant's sexual advances elucidated for the jury that defendant was fully aware that he could not assume consent simply because women crossed the threshold to his apartment or hotel room. Their testimony explained the idiosyncrasies of the entertainment industry that allow assaults to be perpetrated by influential and powerful men against young and relatively powerless aspiring actresses, such that the jury could better assess how defendant would have perceived the victims' actions. The evidence showcased a “repetition, duplication[,] and - 19 -

- 20 - No. 24 similarity of defendant's acts” which has “a direct bearing on the question of premeditated intent" (Cass, 18 NY3d at 563). "[T]he reason defendant invited the victim[s] to his apartment” or hotel room necessarily informed the jury's analysis of "whether he had the requisite intent, i.e.,” the intent to forcibly compel his victims to engage in sexual acts (see Denson, 26 NY3d at 186). The People's theory was that defendant orchestrated these moments to be alone with women in an intimate setting, “lured in on false promises of professional help” to a private location commonly used for business meetings in the entertainment industry, in order to sexually assault them. But defendant posited the innocent explanation that he was simply following through on a mutually agreed upon rendezvous for a consensual quid pro quo exchange and they came to his hotel room or apartment fully aware it was to have sex with him. Indeed, referencing one such meeting, defense counsel skeptically asked Victim A, "You wanted to pitch a project to [defendant]? ... You wanted to meet with him in a hotel room and pitch a project to him?” The Molineux witnesses' testimony went to the heart of this issue and, notably, explained for the jury the unique facet of the entertainment industry in which screen tests and meetings would often occur in these intimate settings. Moreover, because they rejected his sexual advances in similar situations, the People could use this testimony to undermine defendant's quid pro quo theory. In sum, the facts of this case are equivocal, and defendant's state of mind subject to numerous interpretations-layer after layer of nuance, opportunity after opportunity for rape culture to rear its ugly head. Properly considering the realities against which sexual assault cases are presented to a jury, and the myriad of experiences, beliefs, and attitudes - 20 -

- 21 - No. 24 that jurors bring with them into the courtroom, it is clear that a jury could fully accept the victims' recounting of events and still find defendant did not possess the requisite mens rea. As such, defendant's culpable state of mind was not so easily inferred, and the Molineux evidence was admissible to aid the jury's understanding of his intent. The fact that the jury convicted defendant of third-degree rape against Victim B but acquitted him of first-degree rape lays bare the majority's error, and refutes its theory that, if it accepted Victim B's testimony, the jury would have to find forcible compulsion and convict defendant of first-degree rape. Ultimately, it is the rejection of any subtlety in this case which leads the majority to its erroneous conclusion that resolving defendant's intent merely involved a binary choice—believe the victims' testimony and convict defendant or disbelieve it and acquit and that any other evidence on that topic was “irrelevant" to anything but defendant's criminal propensity (see majority op at 2, 30). But how can this issue be “irrelevant" when defendant's very theory rests on the perceived consent flowing from the quid pro quo nature of these sexual encounters? The majority references the testimony of the People's expert witness which offered the jury critical information to dispel some of the rape myths identified above, including misconceptions about victims exerting verbal and physical resistance to an attacker. But the majority falls on the sword it claims to wield against rape myths when it claims that the expert's testimony negates the need for Molineux evidence here. The majority acknowledges that the expert provided testimony relevant to explain “what some jurors might have seen,” as a result of misconceptions about sexual violence, “as counterintuitive acts by complainants” and thus acknowledges that the victims' actions could be perceived - 21 -

-22- No. 24 as unclear (majority op at 27). This inevitably raises the question: if it was appropriate to introduce this testimony to address the equivocality of the victim's actions, why was it not appropriate to introduce evidence to address how the defendant may or may not have perceived the equivocality of the victim's actions? Moreover, the majority's conclusion that the Molineux evidence was not necessary because the People had other evidence to dispel rape mythology-specifically, the expert testimony and the "testimony from multiple complainants"-further demonstrates its misunderstanding of Molineux (see majority op at 28-29). Whether Molineux evidence is cumulative is patently not an appropriate consideration under “Step 1," because it has no bearing on whether defendant's state of mind was open to multiple interpretations and thus, on whether the evidence was relevant (see People v Hudy, 73 NY2d 40, 55 [1988]). Given that the majority disposes of the trial court's Molineux ruling on “Step 1," the majority renders its own discussion of “Step 2” considerations, such as the probative value of the Molineux evidence or its prejudicial impact, academic. Additionally, “it is immaterial that the People could establish a prima facie case without the disputed [Molineux] evidence. They were not bound to stop after presenting minimum evidence but could go on and present all the admissible evidence available to them” (Alvino, 71 NY2d at 245). Sexual assault cases necessarily require a jury to understand a defendant's awareness of a victim's lack of consent. Proof of this intent falls within the core class of evidence that Molineux took great care to distinguish from evidence simply demonstrating a defendant's criminal propensity. But today, this Court elides these two categories, effectively foreclosing the introduction of Molineux evidence in sexual assault cases and - 22-

- 23- No. 24 denying juries relevant evidence. Demonstration of a defendant's culpable state of mind is often a difficult task in any prosecution (see Ingram, 71 NY2d at 479). But where jurors enter a courtroom to adjudicate a sexual assault case, carrying with them deeply entrenched attitudes toward sexual violence, this can be a most daunting task. The Molineux intent exception was designed to combat such evidentiary challenges. The majority appears oblivious to, or unconcerned with, the distressing implications of its holding. Men who serially sexually exploit their power over women—especially the most vulnerable groups in society-will reap the benefit of today's decision. Under the majority's logic, instances in which a trafficker repeatedly leverages workers' undocumented status to coerce them into sex, or a restaurant manager withholds tips from his employees unless they perform sexual acts becomes a series of individual “credibility contests” and unrelated “misunderstandings." After today's holding, juries will remain in the dark about, and defendants will be insulated from, past criminal acts, even after putting intent at issue by claiming consent. Ultimately, the road to holding defendants accountable for sexual assault has become significantly more difficult. IV. With today's decision, this Court continues to thwart the steady gains survivors of sexual violence have fought for in our criminal justice system (see People v Cerda, 40 NY3d 369 [2023] [reversing a first-degree sexual abuse conviction against a child victim by rejecting the trial court's application of the Rape Shield Law]; Regan, 39 NY3d 459 [reversing a first-degree rape conviction on an expanded application of pre-indictment delay doctrine and dismissing the indictment]). Forgotten are the women who bear the - 23 -

- 24 - No. 24 psychological trauma of sexual violence and the scars of testifying again, and again. This erosion of precedent, born from a refusal to accept that crimes of sexual violence are far more nuanced and complex than other crimes, comes at the expense and safety of women. Until we recognize and account for these differences, we cannot claim to dispense fairness and justice for all. - 24 -

CANNATARO, J. (dissenting): The adjudication of sex crimes occupies a challenging space in the evolution of American criminal law. Rooted in centuries of deeply patriarchal and misogynistic legal tradition, progress toward a more enlightened and evidence-based approach to the - 1 -

-2- No. 24 prosecution of rape and related crimes perpetrated predominantly against women has been both challenging and sporadic, with most meaningful progress achieved only over the past 50 years (see People v Regan, 39 NY3d 459, 475-482 [2023] [Singas, J. dissenting]). Today's majority decision represents an unfortunate step backwards from recent advances in our understanding of how sex crimes are perpetrated and why victims sometimes respond in seemingly counterintuitive ways, endangering decades of progress in this incredibly complex and nuanced area of law. I must therefore dissent. As the jury heard in this case through the testimony of the People's expert witness in the area of rape trauma, a commonly held misconception is that the majority of sex offenses involve an assault perpetrated against a woman by an unknown male—the stereotypical stranger in a dark alley who isolates his victim or waits for her to be alone before launching a violent assault. But, as the jury also heard in this case, we now know that most sex crimes are perpetrated by acquaintances-sometimes intimate acquaintances of the victims. These crimes present a host of difficulties in terms of producing competent proof of guilt, as the victims frequently delay reporting, especially to the authorities, and often maintain relationships with their abusers out of fear, manipulation or the prospect of societal opprobrium. These complex psychological and sociological dynamics were at play here. The trial court permitted the People to introduce the testimony of three additional women who had been subjected to the same kind of manipulation and intimidation by defendant, so that the jury could gain a better understanding of his intent and his knowledge of their lack of consent. This evidence, which, as the verdict demonstrates, was carefully parsed by the -2-

-3- No. 24 jury, is the type of evidence that our well-developed Molineux jurisprudence permits. The trial court also ruled that if defendant chose to testify, the People could cross-examine defendant on three categories of prior bad acts that established defendant's willingness to advance his own interests at the expense of others, and was therefore directly relevant to the jury's assessment of defendant's credibility. The trial court's Molineux and Sandoval rulings reflect sensitivity to the nature of the charges, the circumstances of the case, and potential prejudice from admission of the proffered evidence. There was no abuse of discretion in either ruling. The Appellate Division order should be affirmed. I. Under our well-settled Molineux rule (People v Molineux (168 NY 264 [1901]), “[e]vidence of a defendant's prior bad acts may be admissible when it is relevant to a material issue in the case other than defendant's criminal propensity” (People v Dorm, 12 NY3d 16, 19 [2009]). We have set forth an illustrative list of permissible uses for such evidence, including to prove a defendant's motive or intent (see id.). Where there is a proper nonpropensity purpose for the evidence at issue, "it is not to be excluded merely because it shows that the defendant had committed other crimes” (People v Cass, 18 NY3d 553, 560 [2012]). Rather, its admissibility “rests upon the trial court's discretionary balancing of probative value and unfair prejudice" (Dorm, 12 NY3d at 19). "[U]nder our Molineux jurisprudence, we begin with the premise that uncharged crimes are inadmissible and, from there, carve out exceptions" (People v Resek, 3 NY3d 385, 390 [2004]). This rule of exclusion, however, “is not an absolute . . . [and] gives way when evidence of prior - 3-

- 4- No. 24 crime is probative of the crime now charged” (People v Ventimiglia, 52 NY2d 350, 359 [1981]; People v Allweiss, 48 NY2d 40, 46-47 [1979]). We have recognized that “[e]vidence of prior criminal acts to prove intent will often be unnecessary, and therefore should be precluded even though marginally relevant, where intent may be easily inferred from the commission of the act itself. It may be admitted to prove intent, however, when proof of the act falls short of demonstrating that the defendant acted with a particular state of mind and where proof of a prior act is relevant to that issue" (People v Alvino, 71 NY2d 233, 242 [1987] [citations omitted]). Stated otherwise, proof of other crimes may be admissible “[w]hen defendant's criminal intent cannot be inferred from the commission of the act or when defendant's intent or mental state in doing the act is placed in issue” (People v Ingram, 71 NY2d 474, 479 [1988]). Here, prior to trial, the court granted the People's application to introduce three categories of Molineux evidence. The first category permitted complaining witness B to testify that defendant committed two uncharged instances of sexual assault against her— one before and one after the charged offense. The second category permitted three additional witnesses to testify that defendant committed sex offenses against them under similar circumstances to the charged offenses. Under the third category, complaining witnesses A and B were permitted to testify about their observations of defendant's threatening, abusive and manipulative conduct toward others. The evidence in the first and third categories was properly admissible in the exercise of the trial court's discretion under our settled Molineux jurisprudence. As to the first category, a prior assault by a defendant that is observed or experienced by the victim can - 4 -

-5- No. 24 be admissible on the issue of the victim's state of mind- -consent and use of force and to explain a delay in reporting (see People v Tas, 51 NY2d 915, 916 [1980]). Moreover, "when appropriate—as here, in light of the [intimate] relationship between defendant and complainant evidence of a defendant's prior abusive behavior toward a complainant may be admissible to prove the element of forcible compulsion in a rape case" (People v Cook, 93 NY2d 840, 841 [1999]). With respect to the third category, testimony by the complaining witnesses about their observations of other bad acts by defendant was relevant to explain their delayed disclosure (see People v Nicholson, 26 NY3d 813, 829-830 [2016]). There was no error or abuse of discretion in the trial court's admission of either of these categories of Molineux. The majority does not contend otherwise. The category of evidence subject to dispute is the admission of the testimony from the three additional Molineux witnesses. In their Molineux application, the People initially sought to call five additional witnesses in their case-in-chief, arguing that their testimony was relevant to the contested issues of lack of consent and forcible compulsion. The court precluded the People from introducing testimony from two of the proposed witnesses but otherwise granted the application. The trial court permitted these additional witnesses to testify to rebut defendant's claim of consent and to demonstrate his intent to forcibly compel the complaining witnesses to engage in sexual acts with him—specifically, by engineering situations in which he could be alone with women, through an offer of professional assistance, giving the encounters the ostensible appearance of being consensual. Consistent with this ruling, the court gave the jury limiting instructions as to the purpose of the Molineux witnesses' testimony that these witnesses were not the -5-

-6- No. 24 complaining witnesses in the case and that their testimony "was not offered and must not be considered for the purpose of proving that the defendant had a propensity or predisposition to commit the crimes charged in this case. It was offered as evidence for your consideration on the issues of forcible compulsion and lack of consent." When a defendant's intent in a sexual assault case is unequivocal, it is improper to introduce evidence that he has previously committed other similar acts (see People v Leonard, 29 NY3d 1, 8 [2017]). The majority views this as one of those cases, pointing out that there was testimony from complaining witness B that would have allowed the jury to conclude- as it did that she did not consent to sexual contact with defendant with respect to the charged offense. However, there was also testimony that allowed defendant to argue that he reasonably believed she consented—specifically, that she undressed, lay down on the bed and waited for him to come out of the bathroom. Although the majority finds it "inconceivable” that the jury could believe the complaining witness and still find that defendant reasonably believed she consented (majority op at 23-24), that is the precise argument defendant made to the jury and it is the argument the People had to rebut.¹ The majority's approach fails to account for the nuances present in a relationship of this type. Given the witness's description of the encounter and their consensual sexual activity both before and after the charged offense, the lines simply were not that clear. 1 Defense counsel argued in summation that, “even if we look at her testimony and her testimony alone about what happened there that night or that day. Even if you believe every word she says about what happened in that hotel room, it does not rise to the level of a rape." -6-

-7- No. 24 Thus it follows that People v Vargas (88 NY2d 856, 858 [1996]), involving a sexual encounter between strangers where “two starkly contrasting scenarios were presented, with only credibility in issue," is not controlling. In that case, the jury could have either believed the victim's testimony that the interaction was a violent sexual assault by a stranger, or credited the defense that it was a consensual sexual encounter. There was no ambiguity stemming from the context of an ongoing relationship (see e.g. Cook, 93 NY2d at 841) and the defendant's intent could easily be inferred from the act itself. We therefore held that the evidence of the defendant's prior sexual misconduct was inadmissible because it "was relevant only to lend credibility to complainant by suggesting that, because defendant had engaged in sexual misconduct with others, he was likely to have committed the acts charged” (88 NY2d at 858; see also People v Hudy, 73 NY2d 40, 56 [1988], abrogated on other grounds by Carmell v Texas, 529 US 513 [2000]). Here, particularly with respect to complaining witness B, with whom defendant had an intimate relationship, those stark contrasts were not presented.² With complaining witness B, defendant's intent was squarely in issue and, given the context of their ongoing relationship, the nature of defendant's actions was "subject to varying interpretations" (People v Bagarozy, 132 AD2d 225, 236 [1st Dept 1987]). That is, there is no doubt that he intended to have sexual contact with both victims, but there was considerable ambiguity 2 Even if the testimony could be deemed inadmissible on the issue of forcible compulsion as to complaining witness A, it was still admissible as to complaining witness B, as well as to defendant's knowledge of complaining witness A's lack of consent. Defendant failed to preserve any argument with respect to the “imprecision of the court's limiting instructions" as to complaining witness A (see Ingram, 71 NY2d at 478 n 1; People v Cohen, 5 NY2d 282, 290 [1959]). -7-

-8- No. 24 as to whether he intended to force himself on complaining witness B against her will, a conclusion that the jury ultimately rejected. In these circumstances, the People were permitted to introduce evidence that these were not transactional “quid pro quo" interactions made in exchange for defendant's professional assistance, but were situations devised by defendant to engage in sexual activity regardless of whether the victims consented. "Because there [was] a proper nonpropensity purpose, the decision whether to admit evidence of defendant's prior . . . acts rests upon the trial court's discretionary balancing of probative value and unfair prejudice" (People v Brewer, 28 NY3d 271, 276 [2016]). Evidence that is probative of a defendant's guilt will always be prejudicial to some degree, “[b]ut the probative value of a piece of evidence is not automatically outweighed by prejudice merely because the evidence is compelling" (id. at 277). It is also important to note that the jury acquitted defendant of the top three counts-two counts of predatory sexual assault and one count of first-degree rape—all of which required proof of forcible compulsion, one of the permissible uses of the testimony from the Molineux witnesses. This at least suggests that the Molineux evidence did not overwhelm the jury or poison the panel against defendant. There was no abuse of discretion as a matter of law in the trial court's determination with respect to the balancing of probative value against prejudicial effect. II. Under People v Sandoval, the trial court may permit the People to cross-examine a defendant who chooses to testify with evidence of the defendant's “prior convictions" and -8-

-9- No. 24 any "vicious or immoral acts" that bear on the defendant's credibility (34 NY2d 371, 374 [1974]). The trial court makes this determination by balancing “the probative worth of [the] evidence" with respect to defendant's credibility against "the risk of unfair prejudice to the defendant, measured both by the impact of such evidence if it is admitted after his testimony and by the effect its probable introduction may have in discouraging him from taking the stand on his own behalf” (id. at 375). Prejudice to the defendant must also be considered against "the potential prejudice to the prosecution and the fact-finding process of denying the jury access to probative, perhaps even crucial, evidence of the defendant's credibility" (People v Bennette, 56 NY2d 142, 147 [1982]). While such proof should be excluded where its sole purpose is to demonstrate that a defendant's generally bad or criminal character makes it more likely that they committed the charged offense, it "should be admitted if the nature of such conduct or the circumstances in which it occurred bear logically and reasonably on the issue of credibility” (Sandoval, 34 NY2d at 376). Bad acts that show "[a] demonstrated determination deliberately to further self-interest at the expense of society or in derogation of the interests of others go[] to the heart of honesty and integrity" and are "relevant to suggest [a] readiness to do so again on the witness stand" (id. at 377). The quantum of evidence admitted under Sandoval will depend on the nature of the charged conduct and the history of the individual defendant. There was much to work with here: The volume of evidence in the People's Sandoval application encompassed three categories of prior bad acts relevant to defendant's credibility, including general “bad acts,” uncharged sexual assaults (some similar to the charged offenses), and defendant's abusive -9-

- 10 - No. 24 behavior towards others. Asserting that the credibility of the respective parties was the “critical and ultimate issue” in the case, the People argued that these proffered acts demonstrated, as Sandoval material must, that defendant would put his own interests above those of society. The trial court, best positioned to assess the admissibility of such proof based on "the facts and circumstances of the particular case before it” (People v Hayes, 97 NY2d 203, 207 [2002]), was cognizant of the effect this type of evidence could have upon a jury (see People v Walker, 83 NY2d 455, 459 [1994]). The trial court carefully considered each proffered act and its potential for prejudice, excluding the most prejudicial portions— allegations by nontestifying witnesses relating to sexual misconduct- -as "too prejudicial," as well as other acts deemed too remote in time, too general, or too similar to the charged offenses. The court also limited questioning on certain acts, permitting the People to question defendant about instances demonstrating a willingness to further his own interests at the expense of others while at the same time precluding the People from asking defendant about portions of those acts that had to do with sexual misconduct. Applying our well- settled jurisprudence, the Appellate Division concluded that the trial court's ruling was a provident exercise of its discretion (see 207 AD3d 33, 69 [1st Dept 2022]). In our prior cases, our inquiry would end there. Until today, we considered the Sandoval ruling a “largely, if not completely [] discretionary determination for the trial courts and fact-reviewing intermediate appellate courts,” and would only intervene where "the trial court ha[s] either abused its discretion or exercised none at all" (Walker, 83 NY2d at 458-459 [quotation marks and citations omitted]). And until this case, claims which - 10 -

- 11 - No. 24 present "nothing more than a disagreement with the ultimate outcome of the trial court's d[id] not furnish a cognizable ground for discretionary balancing determination intervention by this Court" (id. at 459). Today, the majority intervenes for this defendant, reassessing the proof, making its own unwarranted balancing of interests, and essentially exercising the discretion heretofore reserved for the trial court.³ Purporting to follow Sandoval "and its progeny" (majority op at 35), the majority ignores that we have consistently "declined to prescribe fixed rules prohibiting or allowing the use for credibility purposes of prior offenses based solely upon the potentially inflammatory impact of the crime or the victim involved" (Bennette, 56 NY2d at 147) and have never approved “per se rules requiring preclusion because of the age, nature and number of a defendant's prior crimes” (Walker, 83 NY2d at 459). Even where "the trial court might have been more discriminating” (People v Williams, 12 NY3d 726, 727 [2009] [quotation marks and citation omitted]), the sheer number of prior bad acts and the fact that some were remote in time “are matters of substance that may properly be considered by the trial court but are not appropriate bases for this Court to second-guess the trial court's conclusion" (Walker, 83 NY2d at 459). 3 The majority also appears to quietly endorse a new requirement that material admitted under Sandoval be limited to acts that amount to criminal conduct, arguing that “[d]efendant had no criminal history” and that the admitted acts included those “not criminal in nature” (majority op at 35). This would amount to a significant and novel limitation on Sandoval, one which the language of Sandoval itself prohibits (see Sandoval, 34 NY2d at 373; see also People v Kennedy, 47 NY2d 196, 205 [1979] [Sandoval considerations “are to be applied to cross-examination into alleged immoral, vicious, or criminal acts, regardless of whether those acts resulted in convictions"]). - 11 -

- 12 - No. 24 The majority concludes that proffered evidence acts the majority describes as “appalling, shameful, repulsive conduct”—would “only diminish defendant's character before the jury" and the trial court's ruling would “legitimize destroying a defendant's character under the guise of prosecutorial need” (majority op at 35). But “a criminal defendant who chooses to testify, like any other civil or criminal witness, may be cross- examined regarding prior crimes and bad acts that bear on credibility, veracity or honesty, even in the sensitive area of sex offenses” (Hayes, 97 NY2d at 207-208; see also Bennette, 56 NY2d at 147-148 [rejecting lower court's “inflexible rule prohibiting the prosecutor from impeaching the defendant's credibility by cross-examination on prior sexual offenses" and explaining that “(a) person ruthless enough to sexually exploit a child may well disregard an oath and resort to perjury if he perceives that to be in his self- interest"]). Despite this longstanding approach, the majority instead inverts Sandoval (see 34 NY2d at 376 [“specific criminal, vicious or immoral conduct should be admitted if the nature of such conduct or the circumstances in which it occurred bear logically and reasonably on the issue of credibility"] [emphasis added]), rolling back the People's ability to present relevant evidence that bears directly on defendant's credibility in the name of preserving defendant's “character before the jury” (majority op at 35). Much like the majority's grave error with respect to the Molineux testimony, the majority fails to understand the importance of this particular form of credibility evidence in a case where -12-

- 13 - No. 24 defendant seeks to convince the jury that he had consent and that his accusers are simply lying.4 Order reversed and a new trial ordered. Opinion by Judge Rivera. Chief Judge Wilson and Judges Barros and Clark concur. Judge Singas dissents in an opinion, in which Judges Garcia and Cannataro concur. Judge Cannataro dissents in a separate dissenting opinion, in which Judges Garcia and Singas concur. Judges Troutman and Halligan took no part. Decided April 25, 2024 4 I agree that defendant's remaining arguments are without merit for the reasons stated by the Appellate Division. - 13 -