160 CAPITAL UNIVERSITY LAW REVIEW [44:159
all eight of the massage parlors in Warren were selling sex, and they were
all interconnected, with the women being transported to work in several of
the locations.7 Affidavits showed that one of those spas earned more than
a half million dollars per year.8 Authorities in Warren found
approximately $100,000 in cash at the parlors, including $22,850 hidden
under a fake floor.9 All eight massage parlors were shut down and the cash
seized by forfeiture was divided among the Warren police department and
the prosecuting offices of Ohio Attorney General Mike DeWine and of
Trumbull County.10 This case exemplifies successful asset forfeiture
application in a human trafficking case, but only because Warren’s police
chief asked for the Attorney General’s help in the investigation.11 Federal
law permits forfeiture proceeds to be shared with state and local law
enforcement agencies.12 One former Warren police officer believes these
investigations are rare because police departments are understaffed and
often cannot afford to assign detectives to these large-scale, long-term
Human trafficking is “the illegal trade of human beings for commercial
sexual exploitation and forced labor.”14 It is arguably one of the greatest,
most sweeping, and most disastrous eradicators of human rights of this
century.15 However, “[d]espite its social, spiritual, political, and criminal
‘employment.’” Kristian Bryant Rose, Comment, Looking for Love in All the Wrong
Places: A Call to Reform State Law on Sex Trafficking, 65 OKLA. L. REV. 303, 325 (2013)
(citing DONNA M. HUGHES, THE DEMAND FOR VICTIMS OF SEX TRAFFICKING 14 (June 2005),
7 See Caniglia, supra note 2.
8 See id.
9 See id.
10 See John Caniglia, A Year Later, Warren Massage Parlor Investigation Yields No
Charges, PLAIN DEALER (Aug. 3, 2013, 2:00 PM), http://www.cleveland.com/
11 See Caniglia, supra note 2.
12 See 21 U.S.C. § 881(e)(1)(A) (2012).
13 See Caniglia, supra note 2.
14 OHIO HUMAN TRAFFICKING TASK FORCE, RECOMMENDATION S TO GOVERNOR JOHN R.
KASICH 4 (2012), http://www.governor.ohio.gov/Portals/0/pdf/news/OhioHumanTraffi
ckingTaskForceReport.pdf [hereinafter RECOMMEND ATIONS]. Human trafficking includes
both labor trafficking and sex trafficking. Sara Elizabeth Dill, Comment, Human
Trafficking: A Decade’s Track Record, Plus Techniques for Prosecutors and Police Moving
Forward, 26 CRIM. JUST. 18, 19 (2011).
15 See RECOMMENDATIONS, supra note 14, at 4.