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Chrystul Kizer Trial Updates

Chrystul Kizer was arrested at age 17 for the murder of Randall Phillip Volar III. During her arrest, she claimed Volar was her sex trafficker. On June 5, 2018, she shot him twice while he was sitting in a chair, set his house on fire, then stole his car.

Chrystul Kizer Trial Updates

Chrystul Kizer, the Wisconsin Supreme Court and a watershed sex-trafficking case

The state’s justices will decide whether a law designed to protect child sex-trafficking victims can be used in a homicide case

Wisconsin Supreme Court Justice Jill J. Karofsky on March 1 accused Assistant Attorney General Timothy M. Barber of minimizing the abuse Chrystul Kizer endured. (

MADISON, Wis. — In a marble-walled courtroom in Wisconsin this week, the state’s Supreme Court justices found themselves debating a case about a killing that occurred nearly four years ago. Again and again when discussing what happened, the justices spoke of someone they said was clearly a “victim.” But they were not talking about the man who died.

They were talking about the girl who killed him.

“Why,” asked Justice Rebecca Grassl Bradley, “isn’t Ms. Kizer entitled to present her defense that she did this because she was being trafficked?”

The answer will determine what happens next to Chrystul Kizer, a 21-year-old facing life in prison if convicted of murder for killing her sexual abuser when she was 17. Her case has been in limbo for years, as appeals courts have debated whether she should have access to a never-before-used law that was designed to protect victims of sex trafficking from being punished for crimes they committed that were a “direct result” of being trafficked. State prosecutors and Kizer’s attorneys vehemently disagree about what “direct result” really means — and whether the law, called the affirmative defense, allows for someone to be acquitted of a charge as serious as first-degree intentional homicide.

Shortly after Cyntoia Brown’s release from prison, another case surfaced involving sex trafficking allegations and a young, Black, imperfect victim.

Though Brown was 16 when she killed a man who paid to have sex with her, she was tried for his death and convicted as an adult. She was sentenced to life in prison but granted clemency in 2019. Chrystul Kizer was 16 years old when she met Randall P. Volar III after posting an advertisement on Backpage, the now-defunct website that was frequented by sex workers and potential patrons. Kizer sought money for snacks and school notebooks. The site was shut down in 2018 after being linked to child sex trafficking. Volar sexually abused Kizer multiple times, and filmed the encounters.

In June 2018, a 17-year-old Kizer shot 34-year-old Volar in the head and set fire to his home in Kenosha, Wisconsin.

Last week, a series of demonstrations followed the not-guilty verdicts in the trial of Kyle Rittenhouse, a white teenager who shot three people, killing two of them, during a protest in Kenosha last summer. In at least one of those rallies, protesters connected the dots between the otherwise disparate cases of Rittenhouse, 18, and Kizer, now 21.

Self-defense arguments are at the center of both cases, which have played out in the Kenosha County Courthouse.

4 Things To Know About The Case Of Chrystul Kizer

1. Volar had a lengthy and sordid history with minors.
In the year prior to his death, Volar, who is white, had cops called on him by a 15-year-old. She said she’d been given drugs by a man who was going to kill her, according to The Washington Post.

After being charged with child enticement, using a computer to facilitate a child sex crime and second-degree sexual assault of a child, Volar was arrested and released within the same day without requiring bail.

Kizer said Volar had known she was only 16 years old upon their first meeting and that he went on to sexually abuse her while providing her with money for more than a year.

Volar was still being investigated for child trafficking and possession of child pornography when Kizer killed him. He’d never been called to court over the aforementioned charges. Additionally, court documents state there are over 20 videos of Volar sexually assaulting young Black girls. His case made its way to Kenosha District Attorney Michael Graveley, who was widely criticized for both his handling of that investigation and for seeking to prosecute Kizer.

2. Kizer’s legal team says she acted in self-defense; the prosecution says her actions were premeditated.

Earlier this year, Kizer’s legal team decided to use an affirmative defense argument for the young woman. Affirmative defense involves the introduction of evidence proving a defendant only committed a crime because of circumstances they’d been forced into. Even if found guilty of committing the act, affirmative defense laws offer credible justification for a criminal act.

Thirty-five states have affirmative defense laws, many of which are designated specifically for sex-trafficking survivors, according to The Washington Post.

In a 2019 interview with the Post, Kizer said she was trying to protect herself from Volar. She admitted to killing him because she was sick of him touching her.

In a criminal complaint cited by TMJ4, police said Kizer informed them “she could not leave without being blocked and she believed that Mr. Volar might jump out at her so she shot him.”

“I didn’t intentionally try to do this,” Kizer told the Post.

When asked who she believed the victims were in the case, she gave an acutely candid answer.

“Both of us,” she said. “Because of the stuff that he was doing to me. And, that he should have never died.”

Prosecutors argue that the killing was premeditated and Kizer wanted to steal his BMW, which her brother was later found using.

Prosecutors also allege the teen took a selfie following the killing, and a criminal complaint states she recorded a Facebook Live where she boasted of killing a “white dude” according to the Milwaukee Journal Sentinel.

Kizer’s public defender did not immediately respond to a request for comment.

3. Kizer faces five felony charges.

The 21-year-old is facing five charges: first-degree intentional homicide, arson, operating a vehicle without owner’s consent, being a felon in possession of a firearm and bail jumping.

4. Community leaders continue to rally for her freedom.

In June 2020, the Chicago Community Bond Fund posted $400,000 for Kizer’s bond after receiving mass donations following the murder of George Floyd. By then, Kizer had been jail in two years while waiting for her trial.

“The police and government systems set up to protect Chrystul failed her,” read a statement about Kizer on the group’s website after it funded her release. “Instead of being given care and support from the beginning, she has been wrongfully incarcerated for nearly two years now for choosing to survive.”

The Fund’s executive director, Sharlyn Grace, said Kizer’s case is illustrative of a larger phenomenon.

“We see these cases as incredibly important ... to protect and uplift and support the individual women, who are overwhelmingly Black women,” Grace told Wisconsin Public Radio.

“Because the reality is that Chrystul Kizer was not kept safe by police and prosecution and incarceration and, in fact, after she was forced to defend herself and she chose to survive, she was then further harmed by those systems.”

In the wake of the verdict in Rittenhouse’s trial, a state representative didn’t mince words when addressing the disparities in community response to the two cases.

“Chrystul Kizer was in this building [the Kenosha County Courthouse] advocating for her justice too,” Democratic state Rep. David Bowen said during a Sunday protest at Kenosha’s Civic Center Park. “And we didn’t hear any of y’all. And we didn’t hear anybody that was out making noises for Kyle Rittenhouse.”

Brown herself spoke out in Kizer’s defense in a January 2020 interview with BuzzFeed News’ “AM to DM.”

“Here was yet another situation where there was a young girl caught up with some unfortunate circumstances, who reacted out of trauma,” Brown said. “And the justice system wasn’t necessarily trying to hear that, trying to see that.”

Kizer continues to await trial.

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