ROE v. HOWARD

No. 17-2338.

917 F.3d 229 (2019)

Sarah ROE, Plaintiff-Appellee, v. Linda HOWARD, Defendant-Appellant, and Estate of Russell Howard, Defendant.

United States Court of Appeals, Fourth Circuit.

Decided: February 25, 2019.


Attorney(s) appearing for the Case

ARGUED: Richard Francis Rinaldo , JONES, GREGG, CREEHAN & GERACE LLP, Pittsburgh, Pennsylvania, for Appellant. Melissa Lim Patterson , JONES DAY, Washington, D.C., for Appellee. ON BRIEF: Timothy J. Battle , Alexandria, Virginia, for Appellant. Alison B. Marshall , Christian G. Vergonis , JONES DAY, Washington, D.C., for Appellee.

Affirmed by published opinion. Judge King wrote the opinion in which Judge Wilkinson and Judge Quattlebaum joined.


Defendant Linda Howard appeals from a judgment entered against her in the Eastern District of Virginia after a jury found her civilly liable to plaintiff Sarah Roe under the Trafficking Victims Protection Act (the "TVPA").1 Roe had sued Howard for her role in sexual abuse that Roe suffered at the...

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