The United States Court of Appeals for the Second Circuit has upheld a significant attorney fee award in a high-profile sex trafficking case involving bond trader Howard Rubin. The court's decision, issued on September 4, 2026, confirmed a $4.8 million fee awarded to six women who successfully sued Rubin under the Trafficking Victims Protection Act (TVPA). This ruling is crucial as it reinforces the legal protections for victims of trafficking and the importance of providing adequate resources for their representation.
The case, Moore v. Rubin (Docket No. 25-613), stems from accusations that Rubin exploited the plaintiffs through sex trafficking. The women claimed that Rubin coerced them into participating in abusive sexual encounters under the guise of consensual agreements. The unanimous jury verdict found Rubin liable and awarded the plaintiffs $3.85 million in damages, marking a significant victory for the victims.
The plaintiffs in this case, Amy Moore, Mia Lytell, Natasha Tagai, Emma Hopper, Brittany Hassen, and Brittany Reyes, alleged that Rubin engaged in severe sexual abuse and exploitation. They argued that their experiences constituted violations of the TVPA, which aims to combat human trafficking and provide legal remedies for victims. Their civil action lasted seven years, culminating in a trial that highlighted the complexities and challenges faced by trafficking victims in seeking justice.
Following the jury's verdict, the plaintiffs sought $8.8 million in attorney fees and costs. The District Court for the Eastern District of New York, led by Judge Cogan, ultimately awarded them $4.8 million in attorney fees, citing the TVPA's fee-shifting provision. Rubin appealed this decision, arguing that the fee award was excessive and did not align with prevailing rates in similar cases.
The Second Circuit, which included Chief Judge Lohier and Judges Parker and Chin, reviewed the appeal and affirmed the District Court's decision. The court found that the lower court had correctly applied the legal standards for determining attorney fees. Chief Judge Lohier stated, "The District Court correctly applied the governing legal standards and reached a fee award within the range of permissible decisions for this case." This affirmation is significant as it underscores the court's support for the legal framework that allows victims to recover reasonable attorney fees in trafficking cases.
The court's ruling emphasized that the District Court had considered various factors in determining the fee award, including the complexity of the case, the extensive discovery process, and the unique challenges associated with representing victims of sexual exploitation. The court noted that the fee award was justified given the duration and intensity of the litigation, as well as the substantial damages awarded to the plaintiffs.
In its analysis, the Second Circuit highlighted the importance of the TVPA's fee-shifting provision, which aims to encourage private enforcement of civil rights statutes. The court recognized the need for adequate legal representation for victims of trafficking, particularly against well-resourced defendants like Rubin. The ruling reinforces the principle that victims should not be deterred from seeking justice due to the potential financial burden of legal fees.
The impact of this ruling extends beyond the immediate case, as it sets a precedent for future trafficking cases and reinforces the legal protections available to victims. The court's decision serves as a reminder of the importance of holding perpetrators accountable and ensuring that victims have the resources necessary to pursue justice.
Looking ahead, it remains to be seen whether Rubin will seek further appeal options. While the Second Circuit has affirmed the lower court's ruling, there may be potential avenues for Rubin to challenge the decision in higher courts. However, the current ruling stands as a significant victory for the plaintiffs and a critical affirmation of the legal protections afforded to victims of trafficking.
In conclusion, the Second Circuit's decision in Moore v. Rubin not only affirms a substantial attorney fee award but also reinforces the legal framework supporting victims of sex trafficking. This ruling highlights the importance of providing victims with the resources they need to seek justice and the ongoing commitment of the legal system to combat trafficking and exploitation.