Issue

Sufficiency of indictments—human trafficking—multiple counts per victim—unit of prosecution

Summary

Each of four indictments charging defendant with multiple counts of human trafficking per victim over specified periods of time were sufficient to put defendant on notice of each offense because they contained the necessary elements of trafficking pursuant to N.C.G.S. § 14-43.11. Although defendant argued that he could be convicted of only one count per victim, the plain language of the statute makes clear that human trafficking is not one continuous offense, that a separate charge may be attached to each violation regardless of whether the same victim is involved, and that the offense is committed when a defendant "obtains" a victim–one of the essential elements of the offense–by any one of the alternative means listed in the statute.

Summary from the North Carolina Reports digest (official subject index). Read the opinion →