The Oklahoma Bar Journal August 2025

Recent litigation underscores the judiciary’s growing willingness to apply the TVPA in contexts of professional exploitation.

control and economic manipu lation vitiated any real consent, aligning the conduct with the TVPA’s coercion-based framework. While the events in question may appear sensational due to their celebrity context, the fact pattern mirrors many workplace sexual exploitation cases: An individual in a position of over whelming professional or finan cial power allegedly uses that leverage to compel sexual acts under duress. Just as an employer who conditions job retention on sexual compliance exploits their authority in a potentially traf ficked context, so too does a public figure who allegedly trades career opportunities for coerced sex acts. The Combs case, therefore, stands as a cautionary exemplar of how the TVPA is not limited to human smuggling or underground prostitution rings – it is equally applicable in professional and entertainment sectors when coer cion and power abuse are present. For attorneys, particularly those representing victims of coercive sexual conduct in employer- subordinate or mentor-mentee relationships, the ongoing legal proceedings against Mr. Combs demonstrate the importance of considering the TVPA as a viable

emboldened other alleged victims to come forward. The Department of Homeland Security subsequently executed raids on Mr. Combs’ res idences in Los Angeles and Miami in March 2024 as part of a broader sex trafficking investigation. 19 The federal nature of the inves tigation underscores the relevance of the TVPA in cases involving psychological coercion, abuse of power and manipulative induce ment rather than overt physical restraint. The statute defines sex trafficking to include knowingly recruiting, enticing, harboring, transporting or obtaining a per son for a commercial sex act by means of force, fraud or coercion. 20 A “commercial sex act” is any sex act on account of which anything of value is given to or received by any person. 21 In the allegations against Mr. Combs, career advance ment, lifestyle access and threats of reputational or physical harm were allegedly used to compel sexual compliance – conduct that may meet the statutory threshold. Mr. Combs’ legal team has publicly argued that any sexual conduct was consensual and part of a consensual adult lifestyle. However, the prosecution and plaintiffs maintain that the cumu lative pattern of threats, substance

reportedly under investigation for a range of potential violations, including sex trafficking under 18 U.S.C. §1591, racketeering under the Racketeer Influenced and Corrupt Organizations Act and transportation for the purpose of prostitution under the Mann Act. Authorities allege that for nearly two decades, Mr. Combs used his business empire, including music and fashion ventures, as a front for orchestrating events involving coerced sexual acts. These gath erings, described by insiders and plaintiffs as “freak-offs,” allegedly involved the use of drugs, intimi dation and implied career rewards to induce compliance from young women and associates. 17 A pivotal figure in the legal actions against Mr. Combs is singer Casandra “Cassie” Ventura, his former partner. In November 2023, Ms. Ventura filed a civil suit under New York’s Adult Survivors Act, alleging that Mr. Combs subjected her to over a decade of physical abuse, rape and sex trafficking, including forcing her to engage in sexual acts with male prostitutes while he filmed the encounters. 18 Though the case settled within a day, Ms. Ventura’s allegations catalyzed broader scrutiny of Mr. Combs’ conduct and

Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

AUGUST 2025 | 13

THE OKLAHOMA BAR JOURNAL