In a recent ruling, the Tenth Circuit Court of Appeals affirmed the dismissal of a complaint filed by Akosua Aaebo-Akhan against several defendants, including her former partner and various organizations. The court's decision, issued on November 4, 2026, has significant implications for victims of trafficking seeking legal redress. It highlights the complexities of navigating the legal system, particularly for individuals representing themselves.

The case, docketed as 26-3009, involved a range of serious allegations from Ms. Aaebo-Akhan, who claimed to be a lifelong victim of sex and human trafficking. Her suit named Kwesi Akhan, the Internal Revenue Service (IRS), Canaan Worship Center, the United States Department of Housing and Urban Development (HUD), and Journey Church International as defendants. The court's ruling emphasizes the challenges faced by trafficking victims in seeking justice through the courts.

Background

Akosua Aaebo-Akhan, who represented herself in court, alleged that she was a victim of sex trafficking and that her former partner, Kwesi Akhan, had wrongfully used her sperm for in vitro fertilization without her consent. She claimed to have pursued paternity and child support actions against him in various states, all of which were unsuccessful. In her complaint, she also accused him of defamation and malicious prosecution, asserting that his actions led to her homelessness and poverty.

Additionally, Ms. Aaebo-Akhan accused the Canaan Worship Center and Journey Church International of being involved in her trafficking. She claimed that the leaders of these organizations had solicited donations under false pretenses and had misappropriated her intellectual property during her time as a trafficking victim. She sought damages for these alleged actions as well.

In her claims against the IRS, she argued that she owed no taxes due to her income being derived from forced labor throughout her life. She sought a refund of all taxes assessed against her from 1992 to 2025. Furthermore, she alleged that HUD had failed to process her applications for housing assistance, which she claimed was due to her traffickers preventing her from submitting necessary documents.

The Ruling

The Tenth Circuit reviewed the case after the district court dismissed Ms. Aaebo-Akhan’s complaint, finding that it lacked jurisdiction under the Rooker-Feldman doctrine. This doctrine prevents federal courts from reviewing state court judgments. The court stated, "the district court properly abstained under Rooker-Feldman from exercising jurisdiction over her claims against Mr. Akhan."

The appellate court also agreed with the district court's findings that Ms. Aaebo-Akhan's claims against the other defendants were insufficient. The court noted that her allegations against Canaan and Journey were vague and did not specify any fraudulent actions or reliance on those actions. The court stated, "the allegations were conclusory and failed to allege any viable claim."

Regarding her claims against the IRS and HUD, the court found that she did not present any valid legal basis for her claims. The IRS was protected by sovereign immunity, and HUD did not have a cause of action under the Fair Housing Act. The court concluded that the district court's dismissal was appropriate.

Impact

This ruling has significant implications for victims of trafficking who seek justice through the legal system. It underscores the difficulties faced by individuals representing themselves, especially when navigating complex legal doctrines like Rooker-Feldman. The decision also highlights the importance of clearly articulating claims and providing sufficient evidence to support allegations in court.

For trafficking victims, the ruling may serve as a cautionary tale about the challenges of pursuing claims against multiple defendants, particularly when those claims involve intricate issues of jurisdiction and legal standards. The court's emphasis on the need for specific allegations and a clear legal basis for claims may deter some victims from seeking legal recourse, especially those without legal representation.

What's Next

While Ms. Aaebo-Akhan's case has been dismissed, it is unclear if she will seek further legal action or appeal the decision. The court did not provide details on whether an appeal is planned or if there are related cases pending. The outcome of this case may influence how future trafficking-related claims are approached in the courts.