Chrystul Kizer murder trial sex trafficking defense
Chrystul Kizer sits in the Kenosha County Courthouse on Thursday, Feb. 6, 2020. The Wisconsin Supreme Court is set to decide whether Kizer, who killed a man can find shelter in a state law that absolves sex trafficking victims of their crimes. Prosecutors in Kenosha charged Chrystul Kizer in 2018 with homicide in Randall Volar's death. A circuit judge rejected Kizer's attempt to use a 2008 Wisconsin law that absolves sex trafficking victims of crimes committed while they're being trafficked, saying it would be absurd to extend it to homicide.(Paul Williams/The Kenosha News via AP, File)
Previous Post
Next Post

By Todd Richmond, AP

On a June night in 2018, 17-year-old Chrystul Kizer put a .38-caliber pistol in her book bag and took an Uber from Milwaukee to Kenosha.

She walked into Randall Volar’s home. She had met Volar on a sex trafficking website and for the past year he had been molesting her and selling her as a prostitute, according to court documents.

Kizer would tell detectives later that Volar, 34, tried to touch her. She pulled out her gun, told him to sit in a chair and shot him in the head. She then burned his house down and stole his BMW, according to court documents.

What looks like a clear-cut case of criminal homicide could actually be legal under a Wisconsin law that absolves sex trafficking victims of crimes related to being trafficked. The state Supreme Court is poised to decide whether Kizer can argue that immunity extends to murder in a case that could help define the scope of sex trafficking victims’ immunity in dozens of states across the country.

Kizer, now 21, wants to argue at trial that her actions were justified under a law then-Gov. Jim Doyle signed in 2008 that absolves sex trafficking victims of “any offense committed as a direct result” of being trafficked. But a Kenosha County judge ruled Kizer can’t raise that argument, saying that extending the law to cover homicide would be absurd.

Anti-violence groups have flocked to Kizer’s defense, arguing in legal briefs that trafficking victims feel trapped and may feel they have to take matters into their own hands.

Oral arguments are scheduled for Tuesday. The high court isn’t being asked to decide whether Kizer is guilty, only if she can argue at trial that the law protects her from criminal liability. The decision won’t legally bind other states with similar immunity laws for trafficking victims. But it could create a baseline for prosecutorial and defense strategies in similar cases and affect how victims respond to abuse, legal experts said.

“If we’re living in a civilized society, it begs the question, are we going to give immunity to people who are sexually abused to kill their abusers?” said Julius Kim, a defense attorney and former Milwaukee County assistant district attorney. “The implications can be devastating. Attorneys general across the country are going to pay attention to see how this plays out.”

Nearly 40 states have passed laws over the last decade that provide sex trafficking victims some level of criminal immunity, according to Legal Action of Wisconsin, which provides legal assistance for low-income people. The laws came as legislators began to understand that traffickers exploit their victims and that states should prioritize rehabilitation and help rather than punishment.

The extent of immunity varies among states. California, Kentucky, Montana and North Dakota, for example, extend immunity to non-prostitution-related crimes, according to a court brief the Harvard Law School Gender Justice Clinic and 12 other anti-violence groups filed supporting Kizer.

Other states limit immunity to prostitution-related offenses, according to the coalition. Wisconsin, Iowa, Oklahoma, South Carolina and Wyoming place no limits on immunity but defendants must show the crimes were related to being trafficked.

Kizer’s attorneys allege in court filings that Kenosha police suspected Volar was trafficking children for sex several months before he was killed. The attorneys allege he filmed himself sexually assaulting numerous children. Police arrested Volar in February 2018 and seized evidence of sexual assault and child pornography from his home but later released him and no charges were filed, according to the filings.

Her attorneys went on to say she was 16 when she met Volar. Kizer told the Washington Post in a 2019 interview from jail that she met Volar on, a website known to facilitate sex trafficking that the federal government has since shut down. She said she needed money for snacks and school. Volar sexually molested her and trafficked her through the website to others, she told the Post.

According to the criminal complaint, Volar paid for an Uber to bring Kizer from Milwaukee to his home in Kenosha in June 2018. The house caught fire that night. Police discovered Volar’s body slumped in a chair in the house. He had been shot and his BMW was missing.

Kizer told detectives that she got a gun to protect herself. She said she was tired of Volar touching her and shot him because a tote blocked the door and she was afraid she couldn’t leave, the complaint said. Asked about the fire, Kizer said she watched the television show “Criminal Minds” and decided to start the fire. She told detectives she jumped out a window and drove off in the BMW.

Prosecutors charged her with first-degree intentional homicide, arson, car theft and illegal possession of a firearm. She would face a mandatory life sentence if convicted on the homicide count.

Kizer spent two years in jail before she was released in June 2020 after community groups raised her $400,000 bail.

Her attorneys planned to invoke the sex trafficking immunity law at trial but Kenosha County Circuit Judge David Wilk refused to allow it, finding immunity extends only to trafficking-related charges, such as restraining someone, extortion, sex acts or slave labor.

Kizer’s attorney, public defender Katie York, persuaded a state appellate court to overturn Wilk’s ruling this past June. That court found that immunity applies to any offense that is a direct result of being trafficked.

The state Department of Justice appealed to the state Supreme Court. Assistant Attorney General Timothy Barber argued in briefs that the shooting wasn’t a direct result of trafficking because it was premeditated. The day before Volar was killed Kizer texted a friend saying “I’m going to get a BMW” and told her boyfriend she intended to shoot Volar, the prosecutor argued. Kizer’s argument that she shot Volar to escape a sexual assault holds no water since she shot him while he was sitting in a chair, Barber added.

Randall Randy Volar Chrystul Kizer murder trial sex trafficking
This booking photo provided by Kenosha County Sheriff’s Department taken on Feb. 22, 2018 shows Randall Volar. (Kenosha County Sheriff’s Department via AP)

“Kizer is asking this Court to interpret (the immunity law) in a manner that creates a broader defense based on trafficking status than someone could assert in any other self-defense context,” Barber wrote.

York declined to comment for this story. But she argued in briefs that Wilk’s interpretation of the immunity statutes undermines the purpose of the law and Kizer should be allowed to make her case at trial.

Kate Mogulescu, an associate professor of clinical law at Brooklyn Law School who specializes in sex trafficking laws and consulted with one of the parties that filed briefs supporting Kizer, said in a telephone interview that it should be an easy call for the Supreme Court to let a jury consider the context surrounding Volar’s death.

“Somehow when it’s a trafficking victim that’s trying to provide additional information and context to what happened in their case, that shouldn’t be allowed? That doesn’t make any sense,” Mogulescu said.

Previous Post
Next Post


  1. I side with the girl. Pimp’s should be treated like the scum they are. Being underage should clinch it. And excuse it…

      • I don’t know what to do, but here is one thought.

        Give her a pass on taking out the trash, but charge her with arson and auto theft. She wasn’t being trafficked anymore after the scumbag was dead. No more immunity after his death..

    • “She had met Volar on a sex trafficking website”

      She was sugar baby looking for a sugar daddy. And she found one. Whatever happened between them, she had left, had a boyfriend and was living someplace else. She went back there to kill him and take his BMW. This was premeditated murder, not a hostage shooting their captor during an escape.

  2. That mug shot of the pimp that got shot. That’s the face I’m going to imagine whenever I’m dealing with the nameless faceless troll polluting ttag.

  3. Burning the place was a bit much.

    Meanwhile, why do I get 26 identical “Recommended for you” ads between the article and the comments?

  4. Having met both trafficked women and girls and having met and threatened a few panderers, the humanistic side of me says that a diminished capacity defense and lesser charge is in order for this girl.
    The pragmatic side of me says label it as ‘pest control’ on the girl’s part and let her go on her way with some state-paid counseling and an understanding that this isn’t how you end normal, non-trafficking relationships.

    • I’m sure with your “pragmatic” side she will go on to lead a model life.

      Dude’s like you only learn the truth when it happens to you.

  5. “Assistant Attorney General Timothy Barber argued in briefs that the shooting wasn’t a direct result of trafficking because it was premeditated. The day before Volar was killed Kizer texted a friend saying “I’m going to get a BMW” and told her boyfriend she intended to shoot Volar, the prosecutor argued.”

    Her text the day before is rather damning and certainly implies premeditation when taken in context with, “Chrystul Kizer put a .38-caliber pistol in her book bag and took an Uber from Milwaukee to Kenosha.”
    She shot him, burned the house and stole his car thus turning her text the day before into fact.

    Seems she had choices to make and made the wrong choices. She had the choice of not going or getting out of the house and chose neither.

  6. I’ll reserve judgement. Maybe there were better choices, maybe there weren’t. A pimp makes it his business to know everything about you – your family, your friends, your likes and dislikes, your likely first, second, and third moves if you run away. I don’t think the law can effectively protect the victim – if it could the victim wouldn’t be a victim. I want to know a lot more than this story tells, before I decided guilt or innocence.

  7. Well ya have to admit that if nothing else…. the victim has come up with a new way to help stamp out sex traffickers.

    • Not quite sure how much of a “victim” is she. Evidently, a willing victim, as a minimum. She knowingly prostituted herself, apparently for some time. Sure, the world is better off with the scumbag permanently retired, but she’s no angel, either. Best solution is to retire both of them.

  8. I am picturing her as a female William Munney from “Unforgiven” in his drunken rage telling the town to straigthten up or she will come back, shoot them all and burn their houses down. Might not be legally defensible, but other than the premeditation and bragging about it I would have a hard time prosecuting her for more than a firm slap on the wrist.

  9. The only people a successful argument of her using the Law as a Defense, would be devastating to would be pimps and abusers. They would know they have signed their own Death Warrant. And that is fine with me. Saves me the bullet!

    • And once that precedent is set the left will expand it. Maybe we can kill those who don’t take the jab, after all they are putting everyone in danger. Or those deplorables that voted for orange man bad. They’re racist fascists and a danger to democracy. maybe we can kill those evangelical Christians because they don’t tolerate homosexuality.

      No sane society and no civilization that wants to last can legalize killing someone in anything other than self defense. If you tell people that you are going to kill this guy and take his car, and then you have to take an Uber to another town because you are living in another town with your new boyfriend, that’s not self defense.

      Anything power you give to people for one thing will be expanded and used against you in the future.

      • Exactly the slippery slope exists.

        “Laws” that are made that will “only target the bad guy” soon are used against everybody.

        Patriot Act anyone? We will only target America’s enemies they said. And they meant it. Then one day you wake up and discover… you are the new enemy.

    • When “abuse” can be clearly defined as a heinous, horrendous act? Yes, I agree. Cut out the cancer. But in current culture, the definition of “abuse” is fuzzy around the edges.

  10. wonder why she never tried to get police or reach out for help , to help her ?
    how did she get the 38 ?
    was the pimp burned in the house also , guess so ?
    take the car , ? ok . to bad didn’t do the bobit , n cut talley wacker off , ?
    let him live in shame , but then he could sue her ? may get time arson , n stealing car ?
    did she shoot him in the knee caps n talley wacker then between the eyes ?

  11. The article didn’t state any hold he had over her. She lived 35-40 miles away. Would he drive to her house and beat her up if she didn’t comply, or would he just give her a cut of the money he got from.pimping her out? It doesn’t seem like he kept her locked away and controlled when not turning tricks, like what happens to runaways or smuggled immigrants. Maybe she wanted to quit, or maybe she wanted a bigger cut. She talked about shooting him and getting a BMW, and she burned the crime scene to destroy the evidence. Seems more like somebody who got greedy and decided to commit cold-blooded murder than spontaneous, irrational acts of somebody who traumatized. OTOH, nothing of value was lost.

  12. If that argument holds up in court (being lawful to kill an abuser), could argument be made that if someone considers someone or an organization (Progressives, and/or Marxists or similar) to be abusing someone, that extreme measures are legal to stop that existential threat?

    Something to ponder… 🙂

      • avatar Geoff "A day without an obsessed, apparently brain-damaged and mentally-ill demented troll (who deserves to live in New Jersey) is like a day of warm sunshine" PR

        ‘real’ –

        How anyone like you can type so much, while saying so little, is a wonder to behold… 🙂

  13. Took out the pimp and probable child molester/sexual abuser/predator. Not a problem. Perhaps a couple years prison for the arson and auto theft. And counseling for the aftereffects of the abuse.

    • No, this was a tragic workplace shooting… the entrepreneur would still be alive if not for the easily obtainable guns that a 17 year old used in a horrible murder ! Oh, and Trump. //s

    • You boomers believe anything.

      This girl was a prostitute. She could have got a job at McDonalds, but she chose immorality.

  14. Not really self defense (in danger but imminent).

    I don’t really like it when people rush to play the “victim” card. It can be true in some cases, but in all cases you have some degree of agency.

    I think it should go to trial but if I were on the jury, and the defense made that argument, I would need to see it documented that multiple less extreme escape attempts were made, and failed. That would be the minimum requirement, in order to make the “it was the only apparent way out” defense plausible.

  15. Anti-violence groups have flocked to Kizer’s defense…

    Ok, I’m not passing judgment on her. She was in a horrible situation no doubt… but this…

    When Rittenhouse, a white guy, had actual eye witness, video, photo evidence of legitimate self defense … all these ‘anti-violence’ groups and people called him a murderer… but this girl, a black girl’, basically pre-meditates her act and seeks out the pimp and intentionally kills him, and goes beyond any reasonable excuse of self-defense and deliberately commits further crime and burns down the house and steals the car, and the ‘anti-violence’ groups and people are going ‘you go girl, we support you’.

    What a world.

  16. I think it’s reasonable to argue that sex trafficking for over a year and sexual abuse can be seen as an ongoing crime and threat to her safety and well-being. Not a perfectly clean shot, but one that i can accept both morally and legally.
    Maybe try her for arson, as that was totally not self defense and destruction of evidence. Reduced sentence because she was clearly not in a good mental state as a result of being victimized.

    I just wish every homeowner and people like Rittenhouse were treated the same way…

    • You want “wish” every homeowner/people like Rittenhouse to be shot in the head, their house burned, and their car stolen?

      “i can accept morally”

      You are f**king sick.

    • Trying for arson makes sense.

      Your last line is a bit ambiguous, though: do you mean Rittenhouse and others should be given the latitude she deserves, or that they should be treated like she treated the pimp?

  17. Normally I’d be all for her having the defense, until I read, she “met him” on a sex trafficking site. Then took an Uber and traveled for miles to his location. You don’t sign up to be trafficked like you’re on Tinder.

    That sounds more like she “met him” on a sugar site and wanted to steal his BMW.

    • Definitely a case of insufficient information. It could be anything from a pervert enticing a minor into a sexual ‘adventure’ and then applying some sort of coercion to force her into prostitution, to… well, since he’s being called her pimp, there’s more going on than she happened to meet him and decide she wanted that BMW, but how much more isn’t clear.

  18. This thot went on sugar daddy website.

    Lots of poor people make the choice to not be prostitutes.

  19. Both sides are right, abd both sides are scum.
    Yes he was a pimp and probably worse, but even pimps have rights and shooting them when they’re not attacking you is still murder.
    Yes she was probably abused, but she committed premeditated murder plus arson and GTA.
    Give her a gold star on her paperwork for making the world a little better, then send her up till she’s gray for the rest of it.

  20. Pimps should be subject to death by hanging wherever they’re found. They are engaged in slavery and not worth the effort of a trial.

    I’ve known two gals who were trapped in prostitution, and from their stories I know that rational thought is something that’s effectively impossible; thinking becomes emotion and simple concepts, so “premeditation” is extremely unlikely in such a situation. One escaped because she managed to flee Cuba by raft — her pimp was on a raft following hers but somehow during the night he “just happened” to fall off into shark-infested waters. The other escaped because “somehow” one day her pimp found his car’s accelerator stuck and he couldn’t go slower than 75 (he’d beaten one of his ‘stable’, whose brother, unknown to him, was a mechanic where he got his pimpmobile serviced).

  21. A pimp controlling a 17 year old girl, making money off her body is the modern day equivalent of a SLAVE HOLDER.


Please enter your comment!
Please enter your name here