From Harm to Accountability: Conducting Defensible IMEs in Civil Sex Trafficking Litigation

Thu, September 24 | 1:45 PM EDT– 2:45 PM EDT
Topic: Healthcare, Legal | Knowledge Level: Intermediate

Kirsten Byrnes, PsyD, ABPP

This presentation examines the growing body of civil litigation available to survivors of sex trafficking under 18 U.S.C. § 1595 of the Trafficking Victims Protection Act (TVPA), with particular attention to the evidentiary demands these proceedings place on forensic evaluators and the attorneys who retain and challenge them. Dr. Byrnes argues that psychological evaluations in trafficking cases frequently apply clinical or criminal forensic frameworks that are insufficient for the civil context, leaving significant gaps in the documentation of harm, causation, and damages — and leaving attorneys without the work product they need to build or defend viable claims. Drawing on Keane and Foote’s personal injury framework and the evidentiary standards governing expert testimony in civil proceedings, including recent developments in beneficiary liability doctrine, the presentation outlines what a defensible independent medical examination (IME) requires in this context. Attendees will learn to distinguish between a standard clinical evaluation and a civil IME and understand the psychological constructs most relevant to establishing damages in trafficking claims. Evaluators will leave with a concrete methodology for documenting psychological harm, while attorneys will leave with a framework for assessing the quality of expert work product. Dr. Byrnes integrates forensic psychological principles with legal standards to provide an interdisciplinary framework accessible to evaluators, attorneys, and advocates alike, with didactic content grounded in case illustrations for direct practical application.

Trigger Warning: This presentation contains information (written, spoken, or visual) that may be triggering or (re)traumatizing to attendees.


Presentation Objectives
  • Identify the civil remedy provisions under the TVPA and relevant case law establishing third-party liability
  • Distinguish between standard forensic evaluations and IMEs in the civil litigation context
  • Describe the psychological constructs necessary to document harm, causation, and damages in sex trafficking civil claims
  • Apply Keane and Foote's personal injury framework to trafficking IME methodology
About the Presenter
Kirsten Byrnes, PsyD, ABPP

Dr. Kirsten Byrnes is a board-certified forensic psychologist with two decades specializing in trauma and its psychological impact. She has evaluated and treated hundreds of individuals across child maltreatment, IPV, and sexual exploitation contexts, translating findings for courts and policy audiences.