Case Explained: FinalOpinion in case# 24-3017

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-13 The Seventh Circuit affirmed the convictions and sentences of Marina Oke, Nawomi Awoga, and Assiba Lea Fandohan for conspiracy to harbor and shield unauthorized aliens, harboring and shielding unauthorized aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(iii), (B)(i), and forced labor in violation of 18 U.S.C. § 1589. The court held that the evidence was sufficient to support the jury’s guilty verdict, rejecting the defendants’ arguments that the victims’ testimonies were incredible as a matter of law or insufficient to prove intent to conceal the victims from authorities. Applying a de novo standard of review for sufficiency of the evidence while giving great deference to the jury’s credibility determinations, the court found that the jury could reasonably infer intent to harbor based on the defendants’ affirmative acts of concealment, including instructing the victims to hide from law enforcement, restricting their movement, and shuffling them between homes after police inquiries. The court further affirmed the application of the statutory financial-gain enhancement under 8 U.S.C. § 1324(a)(1)(B)(i), noting that the defendants derived substantial economic benefit from the victims’ unpaid labor. Regarding sentencing, the court applied an abuse of discretion standard and found no error in the district court’s imposition of within-guidelines and below-guidelines sentences under 18 U.S.C. § 3553(a). The appellate court concluded that the district judge adequately considered all relevant mitigating and aggravating factors, including the defendants’ ages, lack of criminal history, and the severe nature of the abuse inflicted on two minor victims, and properly declined to treat Beninese cultural norms as a mitigating factor for conduct violating U.S. law. Consequently, the judgments of the district court are affirmed, and the defendants remain subject to their respective prison terms and terms of supervised release. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.