As a victim of sex trafficking, Jane Doe should have been able to rely on the local authorities and elected officials to protect her. But instead, these people actively participated her exploitation.
One of the brothels Jane Doe was trafficked in was Mustang Ranch—a mainstream, high-profile brothel located in Storey County. Mustang Ranch is owned by Lance Gilman, who was a Storey County Commissioner when his brothel was trafficking Jane Doe.
During Jane Doe’s initial intake interview with Mustang Ranch, she was forced to sign a non-disclosure agreement saying she wasn’t being trafficked. She had to sign before even experiencing what Mustang Ranch was like. As Jane signed these papers, the brothel staff laughed about sex trafficking, as though it was a joke.
When Jane was sent to the Sheriff’s office to get a card that would register her as legally “working” at a brothel, she was not screened for sex trafficking. She was not even asked for her ID. She and the other prostituted women were in and out of the Sheriff’s office in five minutes, without being asked any questions.
Jane Doe knew that something was wrong with this. So, she commented on it to Mustang Ranch’s driver, as he transported her back to the brothel.The driver warned Jane Doe to stop talking.
And then the nightmare began.
Jane Doe found that she was locked within the brothel property, not allowed to leave or even step out into the gated yard without permission. Mustang Ranch staff changed the gate code regularly, to make doubly sure Jane and the other women could not leave.
Jane was closely monitored, enjoying no privacy or independence. Her phone and email were searched regularly by Mustang Ranch staff, and she had to open her physical mail in front of them.
It was clear that the brothel was involved in illegal activity. For example, Lance Gilman himself held classes at the brothel on how to break Nevada’s laws on prostitution advertising. The brothel broke many other laws as well.
Although Jane had been led to believe Mustang Ranch would be a good opportunity to make money, the reality was that the brothel took such an excessive cut of her wages and imposed so many unreasonable fees on her, that she and many women were left either indebted to Mustang Ranch, or forced to engage in prostitution to avoid going into debt.
Mustang Ranch compelled Jane to meet with sex buyers for 12-hour shifts. During these shifts, she was not allowed to rest or even use the washroom without asking for permission.
Eventually, Mustang Ranch kicked Jane Doe out into the street in her pajamas. They refused to let her take her personal belongings, legal documents, or her final pay cheque.
After all her time of prostituting at Mustang Ranch and other brothels, Jane had only enough money to pay for an Uber. She couldn’t even afford a hotel room for the night. Fortunately, the local hotel staff allowed Jane to stay for free. They understood what had happened to her … because they said it “happens all the time.”
This is the reality of legal, mainstream brothels in Nevada. And Jane Doe decided to speak up.
Represented by the NCOSE Law Center and Jason Guinasso, Jane filed a lawsuit against the brothels that sex trafficked her (Mustang Ranch and three others), as well as the county actors who enabled and profited from this trafficking.
But sadly, Jane’s fight has been an uphill battle. A district court dismissed the county defendants from the case—including Lance Gilman, in his official capacity as Storey County Commissioner. To add insult to injury, the district court refused to allow Jane Doe to proceed under a pseudonym and a protective order—a standard protection offered to sex trafficking survivors.
But Jane is not giving up! We are appealing these rulings to the Ninth Circuit. On Wednesday, March 11th , NCOSE’s Senior Legal Counsel Christen Price presented an oral argument on Jane’s behalf to the court.
Read on to learn more about the district court’s erroneous rulings and our appeal below.
The County Defendants Dismissed from the Case
Jane Doe was trafficked in three different brothels in Storey County, Nye County, and Elko County. In each place, county actors enabled and profited from Jane and countless other women’s sex trafficking.
Prostitution is fully legalized in these three counties, despite established research that shows such legal frameworks are linked to increased sex trafficking. These counties even had laws that banned prostituted persons from operating independently. In other words, the laws required that prostituted persons be under the control of a specific brothel—that is, a pimp.
In Nye and Storey County, convicted felons were eligible to run licensed brothels. This clearly shows the counties were not serious about keeping prostituted persons safe from dangerous individuals who would exploit them.
The counties did not screen for sex trafficking, nor did law enforcement inspect the brothels for exploitation. As mentioned, when Jane was sent to the Storey County Sherrif’s office to obtain a card that would allow her to legally at the brothel, she was not asked any questions—just given the card and sent on her way. This is unsurprising considering Lance Gilman, the owner of Mustang Ranch, was both Storey County Commissioner and a member of the County’s brothel licensing board. This conflict of interest was ripe for corruption.
Further, all the counties were directly profiting from the sex trafficking they enabled, through taxes and brothel licensing fees. Lance Gilman openly stated that the reason he purchased Mustang Ranch was to boost Storey County’s tax revenues—at the county’s request. Knowingly profiting from sex trafficking is a crime under federal law.
All of the above should give Jane Doe more than enough grounds to sue the county actors for their role in her exploitation. That is why we are appealing the district court’s decision to dismiss the county defendants—a deeply erroneous ruling.
“A government that requires women in prostitution to have pimps … allows the pimps to employ debt, physical restraint, and other methods of coercion with impunity, meanwhile profiting handily from the entire enterprise is not a bystander, but exactly the kind of enabler-beneficiary that federal anti-trafficking laws are intended to stop.”
We hope that the Ninth Circuit will grant a more favorable ruling and finally bring justice for Jane!
Jane Doe Denied Pseudonym Status and a Protective Order
As if the dismissal of the county defendants weren’t bad enough, the district court issued another egregious ruling which, if not overturned, all but forces Jane to let go of her case entirely.
Shockingly, the judge refused to allow Jane Doe to proceed in the case with pseudonym status and under a protective order. The pseudonym status would have kept her real name and identity private from the public, and the protective order would have outlined the conditions under which the defendants could obtain Jane’s name and private information (to prepare their defense).
Both of these are standard protections for sex trafficking survivors seeking civil remedies—and indeed, they are often offered to plaintiffs who have far less at stake. It is inexplicable that the court denied Jane these routine protections.
As the NCOSE Law Center’s appeal states:
“The implications are chilling: either a sex trafficking survivor must put herself fully on the line, without even the protections commonly afforded a business’s trade secrets, or the worst human rights abusers will go completely free. The court thus demanded that Jane Doe choose between her own safety and impunity for the brothels, which is not a decision this Circuit’s precedent could have ever justified the court in making.”
Jane has much to fear from making her name and personal information public. At the brothels, she engaged with numerous dangerous individuals—not only her alleged sex traffickers, but also the sex buyers who routinely raped her. One sex buyer has already attempted to track Jane down since she left the brothels. The court is effectively demanding that Jane reveal herself to all her exploiters and any other dangerous individuals attempting to find her. This is unconscionable.
Further, the defendants in the case (i.e. Jane’s alleged traffickers) have made it very clear that they wish to weaponize the media to retaliate against Jane. Disturbingly, the judge agreed that the defendants will be disadvantaged if they can’t do this.
This is why we are appealing the district court’s ruling with the utmost urgency and fervor. What’s on the line is not only justice for Jane—but all survivors. Survivors will never be free to speak up and pursue accountability for their perpetrators, if the courts force them to sacrifice their own safety and privacy.
This egregious ruling must be overturned.
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