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For purposes of criminal prosecution under 18 U.S.C.S. § 241 or 18 U.S.C.S. § 1584, the term "involuntary servitude" necessarily means a condition of servitude in which the victim is forced to work for the defendant by the use or threat of physical restraint or physical injury, or by the use or threat of coercion through law or the legal process. This definition encompasses those cases in which the defendant holds the victim in servitude by placing the victim in fear of such physical restraint or injury or legal coercion.
After two mentally retarded men were found laboring on respondents' farm in poor health, in squalid conditions, and in relative isolation from the rest of society, respondents were charged with violating 18 U. S. C. § 241 by conspiring to prevent the men from exercising their Thirteenth Amendment right to be free from involuntary servitude, and with violating 18 U. S. C. § 1584 by knowingly holding the men in involuntary servitude. At respondents' trial in Federal District Court, the Government's evidence indicated, inter alia, that the two men worked on the farm seven days a week, often 17 hours a day, at first for $ 15 per week and eventually for no pay, and that, in addition to actual or threatened physical abuse and a threat to reinstitutionalize one of the men if he did not do as he was told, respondents had used various forms of psychological coercion to keep the men on the farm. The court instructed the jury that, under both statutes, involuntary servitude may include situations involving any "means of compulsion . . . , sufficient in kind and degree, to subject a person having the same general station in life as the alleged victims to believe they had no reasonable means of escape and no choice except to remain in the service of the employer." The jury found respondents guilty, and the court imposed sentences. However, the Court of Appeals reversed and remanded for a new trial, concluding that the trial court's definition of involuntary servitude was too broad in that it included general psychological coercion. The court held that involuntary servitude exists only when the master subjects the servant to (1) threatened or actual physical force, (2) threatened or actual state-imposed legal coercion, or (3) fraud or deceit where the servant is a minor or an immigrant or is mentally incompetent.
Is the definition of "involuntary servitude," for purposes of criminal prosecution under 18 USCS 241, 1584, limited to physical or legal coercion or threats thereof?
The court affirmed and remanded for further proceedings. The court concluded that because both § 241 and § 1584 prohibited conduct violative of U.S. Const. amend XIII, the use of the term "involuntary servitude" in the statutes should be construed the same way in both statutes. The court held that, for purposes of criminal prosecution under § 241 or § 1584, "involuntary servitude" necessarily meant a condition of servitude in which the victim was forced to work by the use or threat of physical restraint or physical injury, or by the use or threat of coercion through law or the legal process.