The sentencing of Leniyah Butler to five years in federal prison marks another flashpoint in the complex intersection of transgender rights, sex worker safety, and criminal justice in San Francisco. The 21-year-old's case—which culminated in last week's emotional courtroom scene where both she and her victim's family spoke—has exposed deep tensions about how the legal system handles cases involving marginalized communities.
Butler's conviction for voluntary manslaughter in the November 2023 shooting death of Hamza Walupupu at Crissy Field came after a trial that highlighted issues rarely discussed openly in federal court. The defense's claim of self-defense, rooted in Butler's fear after Walupupu allegedly demanded his money back upon learning she was transgender, resonated with a grim reality facing trans sex workers nationwide.
Failed Motion Exposes Juror Bias Concerns
Two months before the sentencing, Judge Susan Illston denied a defense motion for a new trial based on troubling comments allegedly made by a juror. According to the Bay Area Reporter, the motion centered on a juror's statement, relayed by another juror, that Butler's defense was impossible because "You can't rape a man." The comment directly attacked Butler's claim that she feared sexual assault—a defense grounded in the documented violence transgender sex workers face.
Judge Illston ruled that the alleged comment, while concerning, couldn't cast enough doubt on the entire jury's impartiality to justify a retrial. The decision reflects the high bar defendants face when challenging jury verdicts, even when bias against transgender individuals may have influenced deliberations. Legal experts note that proving juror misconduct sufficient for a new trial requires showing the misconduct substantially affected the verdict—a standard that remains difficult to meet even with evidence of discriminatory statements.
Surveillance State Meets Street Reality
Butler's arrest showcased San Francisco's expanding surveillance capabilities, with the San Francisco Chronicle reporting that FBI agents tracked her through automated license plate readers after she was picked up in a black Jeep Commander—the only one registered in the Bay Area at the time. This occurred before the city's recent massive expansion of Flock Safety cameras, suggesting even more comprehensive tracking capabilities now exist.
The surveillance footage captured Butler attempting to wipe down Walupupu's car on Kiska Road in Hunters Point, where she abandoned it after driving from Crissy Field. According to the SF Standard, Butler told law enforcement she had been ready to use her gun before arriving at Crissy Field, feeling she was being taken "out of her element" when Walupupu drove her 20 minutes from where he picked her up at Post and Polk streets—an area known as "the Blade" where trans sex workers gather.
Violence Against Trans Sex Workers: A Broader Crisis
Butler's case unfolds against a backdrop of endemic violence faced by transgender sex workers. Studies show 62 percent of transgender people killed worldwide from 2008 to 2017 were sex workers, according to the Trans Murder Monitoring Project. In San Francisco specifically, a needs assessment found trans community members were seven times more likely than cisgender people to feel unsafe in most settings, with 79% experiencing physical violence and 65% reporting sexual violence.
Defense attorney David Rizk argued in court filings that Walupupu had a history of mental illness, alcohol abuse, and assaulting transgender sex workers—claims prosecutors dismissed as "blatant victim-blaming." According to SFist, Rizk also stated Butler was sex-trafficked as a child and forced onto the streets through maternal coercion and neglect, painting a picture of compounded trauma that preceded the fatal encounter.
Federal Jurisdiction and Trump-Era Policies Complicate Case
The shooting's location on federal land at Crissy Field brought the case under federal jurisdiction, adding layers of complexity. Butler's sentencing comes amid President Trump's January executive order directing federal prisons to stop providing gender-affirming care to transgender inmates and house them according to biological sex—policies Butler's attorneys cited in arguing for alternative sentencing.
Judge Illston ultimately ordered Butler remanded to a women's prison where she will continue receiving hormone therapy, a decision that stands in contrast to federal policy directives. The judge waived fines due to Butler's inability to pay but scheduled a January 30 hearing to consider restitution to Walupupu's family.
Voices of Pain and Forgiveness
The sentencing hearing revealed the human cost on both sides. Butler, expressing remorse while acknowledging her emotional numbness from trauma, directly addressed Walupupu's family: "I'm deeply sorry to the victim's family for all the pain I caused them. The night this situation occurred, I was deeply scared and hurt."
Walupupu's sister Aziza offered Christian forgiveness while describing her brother as someone who made people "feel connected and very friendly, caring." Their mother, Fifi Yambayamba, speaking through a translator, noted that multiple community members called themselves "Mama Hamza" because of his widespread popularity among Congolese immigrants who, like the Walupupu family, had fled war-torn Democratic Republic of the Congo as refugees.
Legal Implications and Future Precedent
The five-year sentence—significantly less than the 13 years prosecutors sought but more than the two years the defense requested—reflects what Rizk called the court's "recognition of the complexity of what occurred." Federal prosecutors had characterized the killing as "callous and deliberate," while the defense framed it as a young, impaired Black transgender trafficking victim defending herself against an older, drunk, violent client.
The case sets no clear legal precedent but highlights ongoing challenges in how courts handle violence involving sex workers, particularly those who are transgender. San Francisco's 2020 "Prioritizing Safety for Sex Workers" policy—the nation's first collaborative effort between the DA's office and police to encourage violent crime reporting without prostitution charges—aims to build trust. Yet cases like Butler's demonstrate how far the system has to go in addressing the structural violence and discrimination that creates dangerous conditions for trans sex workers.
Butler will serve three years of supervised release following her prison term. Her case joins a growing body of jurisprudence grappling with how self-defense claims apply when marginalized people face violence in criminalized industries—questions that will likely persist as similar cases continue to emerge from the shadows of San Francisco's streets.
