Hamilton Clarke, LLP secured a rare post-trial judgment of acquittal under Rule 29 of the Federal Rules of Criminal Procedure in the Eastern District of New York, following a multi-week federal trial, United States v. Siyang Chen, 22-cr-158, tried before the Honorable Eric N. Vitaliano.
The charge at issue involved an allegation of sex trafficking conspiracy under 18 U.S.C. § 1591. Following the close of evidence, Hamilton Clarke moved for a judgment of acquittal, arguing that the government had failed to present legally sufficient evidence on a required element of the offense: causation.
The motion highlighted the evidentiary gaps in the prosecution’s theory, specifically with respect to whether any use of force, fraud, or coercion was knowingly employed to cause any person to engage in commercial sex acts, as the statute requires.
On July 7, 2025, Judge Vitaliano granted the motion, setting aside the verdict and entering a judgment of acquittal as a matter of law. In a thorough 14-page opinion, the court held that the record—even viewed in the light most favorable to the government—did not establish that the purpose or effect of the alleged conduct was to compel commercial sex activity. As the court wrote, “No reasonable jury could so find” on the evidence presented.
The ruling offers important clarification of the causation requirement under § 1591 and reinforces the high bar that applies to criminal convictions based on theories of coercion. It also highlights the continuing role of trial courts in ensuring that convictions remain tethered to the statutory elements Congress enacted.
Post-verdict relief under Rule 29 remains exceptionally rare. This outcome underscores the importance of disciplined trial strategy, issue preservation, and post-trial advocacy grounded in both statutory text and case law.
At Hamilton Clarke, we are proud to advocate with precision and principle at every stage of litigation.