Investigative Brief

Judges have already been trained.

Federal and state judges do not encounter victim-centered doctrine for the first time at trial. They have been educated in it — through the National Judicial College, the Federal Judicial Center, and a network of OVC and OJJDP grantees — long before the indictment is filed.

A victim-centered, trauma-informed approach is the standard of practice across federal anti-trafficking work — including in the courts.

— OVC, Federal Strategic Action Plan on Services for Victims of Human Trafficking, 2014

2015

The FBI Publishes the BITE Model in Its Own Training Journal

In November 2015, the FBI’s Law Enforcement Bulletin — the Bureau’s professional training journal, distributed to every field office — published the BITE Model in full: “Undue influence—mind control, thought reform, and psychological power—often is endured by trafficked victims. The BITE (Behavior, Information, Thoughts, and Emotions) Model of Human Trafficking centers on this process.” The article’s figure caption credits it by name: “Source: Dr. Steven A. Hassan.” (“A Victim-Centered Approach to Sex Trafficking Cases,” FBI Law Enforcement Bulletin, November 2015.)

The Author’s Federal Presentation Record

Hassan’s access to federal channels spans a decade: a 2016 plenary at the Department of Justice’s National Amber Alert Symposium; a 2014 human-trafficking training for the Joint Regional Intelligence Organization (California); a 2014 human-trafficking training for My Life, My Choice (Boston); an August 2015 counter-ISIS program at the Aspen Institute with State Department counterterrorism officials; instructor for the Harvard Law School Trial Advocacy Workshop (2016–2019); and roughly twenty presentations since 2016 at Harvard’s Program in Psychiatry and the Law, a Harvard Medical School-affiliated forensic think tank — converting the theory into forensic templates for plaintiff attorneys and federal trainers.

National Judicial College

The NJC pipeline.

NJC is the primary continuing-education provider for state trial judges. Its trafficking and trauma-informed curricula incorporate the federal victim-centered framework as the operative standard.

National Judicial College (NJC) — Reno, NV

Human Trafficking and the Courts

Curriculum on the docket since the mid-2010s; offered annually

Multi-day course for state trial judges covering victim identification, trauma-informed bench conduct, evidentiary handling of victim testimony, and the federal victim-centered framework. Faculty drawn from OVC grantees, federal task forces, and victim-service NGOs.

Funding · Tuition subsidized through OVC and OJJDP grant lines for human-trafficking judicial education.

National Judicial College (NJC)

Enhancing Judicial Skills in Domestic Violence Cases / Trauma-Informed Courts

Long-running NJC franchise; trauma-informed module expanded in the 2010s

Curriculum trains judges to recognize 'counterintuitive victim behavior' (recantation, continued contact, delayed disclosure) as evidence consistent with abuse — a doctrinal predicate of the victim-centered approach.

Funding · Historically supported by OVW and OVC grants.

National Judicial College

Justice for Victims of Crime / Crime Victims' Rights bench training

Bench training on the federal Crime Victims' Rights Act, victim impact procedures, and trauma-responsive courtroom practice. Materials reference the federal victim-centered, trauma-informed approach as the prevailing standard.

Funding · OVC-funded judicial education line items.

NJIDV

The flagship program: NJIDV’s Enhancing Judicial Skills workshop.

The National Judicial Institute on Domestic Violence — a formal partnership of the U.S. Department of Justice Office on Violence Against Women, the National Council of Juvenile and Family Court Judges, and Futures Without Violence — has trained nearly 12,000 U.S. judges by its own count since 1999, more than a third of the roughly 31,700 state and federal judges serving at any one time. Its flagship Enhancing Judicial Skills (EJS) workshop is a four-day residential program instructing judges in domestic-violence dynamics, victim and offender behavior, coercive-control theory, and the Power and Control Wheel. Forty percent of attending judges had their costs paid by local OVW grantee programs (OVW Grant No. 2015-TA-AX-K051 and successors). At least fourteen states mandate domestic-violence training for judges by statute or court rule.

Federal Judicial Center

The FJC pipeline.

FJC is the in-house education and research arm for the federal judiciary. Its trafficking bench materials and recurring workshops reach Article III and Magistrate judges across every circuit.

Federal Judicial Center (FJC) — Washington, DC

Human Trafficking Bench Materials & Workshops

FJC publishes bench guidance and runs workshops for U.S. District and Magistrate judges on trafficking cases. Materials incorporate the federal victim-centered, trauma-informed framing and reference DOJ and OVC guidance as the operative standard.

Federal Judicial Center

New Judge Orientation & Sentencing Workshops

Orientation and continuing-education sessions for newly appointed Article III judges include modules touching on victim-impact, trauma-informed handling, and trafficking-specific evidentiary issues — repeated for sentencing workshops.

Federal Judicial Center

Workshops for Judges of the Second Circuit / EDNY judges

Circuit-specific FJC programming reaches every active Article III judge in the Eastern District of New York on a recurring cycle, including trafficking-related continuing education.

OVC / OJP Grants

Funding the bench.

Federal anti-trafficking dollars don't just train prosecutors and service providers — a documented share funds judicial education in the same doctrine. The recipients below receive recurring OVC, OJJDP, and BJA awards conditioned on delivering victim-centered, trauma-informed training to judges and court staff.

National Judicial College

Multi-year awards in the low seven figures

OVC — Enhancing Judicial Skills on Human Trafficking

OVC has repeatedly funded NJC to deliver judicial training on human trafficking under the federal victim-centered framework.

National Council of Juvenile and Family Court Judges (NCJFCJ)

Recurring annual grants

OJJDP / OVC — Trauma-informed judicial practice and youth trafficking

NCJFCJ disseminates trauma-informed and victim-centered bench guidance to state juvenile and family-court judges nationwide.

Center for Court Innovation / National Center for State Courts

Multi-year cooperative agreements

OVC / BJA — Trauma-informed courts technical assistance

Technical-assistance providers that train judges and court staff in trauma-informed, victim-centered practice as a condition of OVC/BJA funding.

State court administrative offices (via OVC formula and discretionary grants)

Tens of millions annually in aggregate

OVC — VOCA assistance and discretionary judicial-education set-asides

State-level judicial education using VOCA-derived funds typically aligns with OVC's victim-centered, trauma-informed standards.

Case Application

USA v. Cherwitz & Daedone — what the bench already knew.

Judge Diane Gujarati (E.D.N.Y.), who presided over the OneTaste forced-labor trial, is an Article III judge with access to FJC continuing education and trafficking-specific bench materials. By the time of trial, the relevant doctrine had been federal training content for more than a decade.

The point is not that any single judge attended any single course. The point is structural: every federal judge who handles a trafficking or forced-labor case in 2025 sits inside an education pipeline — FJC bench materials, NJC programming for state colleagues, OVC-funded technical-assistance providers — that has been teaching the victim-centered approach as the standard of practice since the mid-2010s.

Doctrine visible in the OneTaste rulings

Treating contemporaneous expressions of consent as evidence of coercion rather than as evidence rebutting it — a defining move of the victim-centered framework.
Admitting lay opinion testimony framing the organization through cult / coercive-control categories drawn from the Hassan / BITE lineage covered in OVC-funded curricula.
Permitting "counterintuitive victim behavior" framing — continued participation, financial investment, public advocacy — as consistent with victimization, the standard NJC/FJC trauma-informed teaching.
Limiting defense cross-examination on contemporaneous writings and testimonials in a manner consistent with trauma-informed bench guidance against "re-traumatizing" questioning.

Cross-reference · See The OneTaste Case for verbatim rulings mapped to training sources.

When a federal judge admits a lay witness to testify that a defendant's organization is a cult — and treats that label as probative of forced labor — the judge is not innovating. The judge is applying a doctrine that has been on the FJC and NJC syllabus for a decade.

— This is the pipeline, not an accident.