Attempts have been made in the . to charge pornographic-film producers with pandering under state law. The case of California v. Freeman in 1989 is one of the most prominent examples where a producer/director of pornographic films was charged with pandering under the argument that paying porn actors to perform sex on camera was a form of prostitution covered by a state anti-pandering statute. The State Supreme Court rejected this argument, finding that the California pandering statute was not intended to cover the hiring of actors who would be engaging in sexually-explicit but non-obscene performances. It also stated that only in cases where the producer paid the actors for the purpose of sexually gratifying themselves or other actors, could the producer be charged with pandering under state law. This case effectively legalized pornography in the State of California.    In 2008, the New Hampshire Supreme Court would issue a similar ruling (New Hampshire v. Theriault) which declared that producing pornography was not a form of prostitution under state law. 
Apart from incidences of violence directly associated with prostitution, an increasing number of women who sell sex have been physically assaulted, and even murdered, in the course of attempts to steal their money and property.  There have also been a growing number of criminal acts, especially incidences of theft and fraud directed at men who buy sex, as well as bribery of public servants .  Offenders often capitalise on the unwillingness of participants in the prostitution transaction to report such activities. Organised crime rings are increasingly trafficking women into and out of China for the sex trade, sometimes forcibly and after multiple acts of rape.    Mainland China also has a growing number of " heroin hookers", whose drug addictions are often connected to international and domestic crime rackets.