Wisconsin v. Kizer
[5] Kizer's case has received international attention, especially after the George Floyd protests triggered renewed focus on criminal justice reform.
[9] On May 9, 2024, Kizer pled guilty to one felony count of second-degree reckless homicide, which carries a maximum sentence of 25 years in prison.
[10] In 2017 in Kenosha, Wisconsin, Chrystul Kizer, a 16-year-old Black girl, met Randall P. Volar III, a 33-year-old White man, on Backpage.
In 2018, Kizer, then 17 years old, was arrested for Volar's murder and charged as an adult with first-degree intentional homicide, which carries a mandatory life sentence.
[20] Kenosha County District Attorney Michael Graveley told The New York Times that "permitting vigilante justice, which is the narrative from some seeking dismissal, is a highly subjective, slippery slope".
[27] In October 2023, the trial court ruled that statements Kizer made during her interrogation by the police were not admissible because she did not receive a Miranda warning and her attorney was not present.
[30] On May 9, 2024, Kizer pled guilty to one felony count of second-degree reckless homicide, which carries a maximum sentence of 25 years in prison.
[37] According to Seigel and philosopher Ayanna Spencer, the case is an example of prosecutors using vigilante rhetoric to cast child trafficking victims as criminals who ignore the law.
[38] Historian Nikki M. Taylor, law professor Lisa Avalos, and others, cite Kizer's case as an example of the police and courts' mistreatment of, failure to protect, and lack of sympathy towards, victims of sex trafficking.
[39] Writing in the Harvard Journal of Law and Gender, Brianna N. Banks cites Kizer's case as an example of the ineffectiveness of the federal Victims of Trafficking and Violence Protection Act of 2000 (TVPA) as applied in practice, pointing to legal authorities' failure to provide Kizer and Volar's other underage victims with TVPA protections.
[40] Both Spencer and Banks cite the case as an example of sociopolitical biases that cause Black girls to be perceived as adults, older and more sexually mature than they actually are.
[42] Banks writes that both cases demonstrate racial disparities and biases in the criminal justice system's failure to view Black girls as victims of abuse, treating them instead as "complicit in their own exploitation" (despite being under the age of consent) and "more culpable than the men who purchase their bodies".
[43] Banks writes that implicit biases dating back to the slavery era that hypersexualize and devalue Black women and girls may have caused the trial court to prohibit Kizer from raising the affirmative defense at trial, and likely caused police and prosecutors to characterize Kizer and Volar's other victims as "voluntarily prostituting themselves-as if they themselves chose to be trafficking victims".
Both cases are outliers, as most impoverished defendants charged with serious and minor offenses remain in jail for months or years awaiting trial dates.
[45] The case received global attention, sparking public debate about racial justice and the limits and merits of shield laws for sex trafficking victims.
[6] Interest in her case renewed following the Kyle Rittenhouse trial (also in Kenosha) where the defense claimed self-defense and the jury delivered a not guilty verdict.
