Multistate Failure: Advocating for an Affirmative Defense for Sex-Trafficking Victims in Line with Feminist Legal Reasoning

By Katharine Greer. 

Chrystul Kizer entered Gary, Indiana’s junior high performing arts academy with a dream of becoming a violinist.  She practiced all hours of the day trying to master music by composers like Beethoven. She was a “burgeoning artist” and defined herself by her music. However, this dream began to unravel when her mom’s boyfriend became violent. His abuse became too much for the family and forced them to move out of town to Milwaukee. Unable to find work or shelter, Chrystul’s family stayed at a Salvation Army shelter for months. In Milwaukee, Chrystul started dating Delane Nelson. Unfortunately, Delane was abusive, and they spent many days fighting. While Chrystul’s mom eventually got a job at Denny’s, Chrystul was still unable to pay for school supplies or food. Her friend showed her a website where she could advertise her need for cash:, a classified advertising website similar to Craigslist. Thirty-three-year-old Randy Volar responded to her ad. Volar gave her cash for those supplies and snacks, but also took her on expensive dates and let her drive his expensive cars. Volar told Chrystul that she deserved better than Delane, that she deserved someone who would treat her like a princess, someone like him. A year later, Chrystul was charged with his murder. Volar was not offering these gifts freely. In return for the gifts and the shower of compliments, Volar sexually abused Chrystul, drugged her, and forced her to have sex with other men in return for money. Volar trafficked Chrystul. After a year of abuse, Chrystul claims she was “tired of [him] touching her” and told him she was done meeting with him. Chrystul claims Volar reminded her what she owed him and pinned her down. Chrystul does not remember grabbing the gun, just the sound it made. Full Article