United States v. Kozminski

487 U.S. 931, 108 S. Ct. 2751, 101 L. Ed. 2d 788, 1988 U.S. LEXIS 3032, 56 U.S.L.W. 4910, 46 Empl. Prac. Dec. (CCH) 38,067
Supreme Court of the United States·Decided June 29, 1988·No. 86-2000·Published·Cited by 405 cases

Opinions

Justice O’Connor

delivered the opinion of the Court.

This case concerns the scope of two criminal statutes enacted by Congress to enforce the Thirteenth Amendment. Title 18 U. S. C. §241 prohibits conspiracy to interfere with an individual’s Thirteenth Amendment right to be free from “involuntary servitude.” Title 18 U. S. C. § 1584 makes it a crime knowingly and willfully to hold another person “to involuntary servitude.” We must determine the meaning of “involuntary servitude” under these two statutes.

I

In 1983, two mentally retarded men were found laboring on a Chelsea, Michigan, dairy farm in poor health, in squalid conditions, and in relative isolation from the rest of society. The operators of the farm — Ike Kozminski, his wife Marga-rethe, and their son John — were charged with violating 18 U. S. C. §241 by conspiring to “injure, oppress, threaten, or intimidate” the two men in the free exercise and enjoyment of their federal right to be free from involuntary servitude. The Kozminskis were also charged with knowingly holding, or aiding and abetting in the holding of, the two men to involuntary servitude in violation of 18 U. S. C. §1584 and §21 The case was tried before a jury in the United States District Court for the Eastern District of Michigan. The Government’s evidence is summarized below.

The victims, Robert Fulmer and Louis Molitoris, have intelligence quotients of 67 and 60 respectively. ' Though chronologically in their 60’s during the period in question, [935]*935they viewed the world and responded to authority as would someone of 8 to 10 years. Margarethe Kozminski picked Fulmer up one evening in 1967 while he was walking down the road, and brought him to work at one of the Kozminski farms. He was working on another farm at the time, but Mrs. Kozminski simply left a note telling his former employer that he had gone. Molitoris was living on the streets of Ann Arbor, Michigan, in the early 1970’s when Ike Kozminski brought him to work on the Chelsea farm. He had previously spent several years at a state mental hospital.

Fulmer and Molitoris worked on the Kozminskis’ dairy farm seven days a week, often 17 hours a day, at first for $15 per week and eventually for no pay. The Kozminskis subjected the .two men to physical and verbal abuse for failing to do their work and instructed herdsmen employed at the farm to do The same. The Kozminskis directed Fulmer and Molitoris not to leave the farm, and on several occasions when the men did leave,' the Kozminskis or their employees brought the men back and discouraged them from leaving again. On one occasion, John Kozminski threatened Molitoris with institutionalization if he did not do as he was told.

The Kozminskis failed to provide Fulmer and Molitoris with adequate nutrition, housing, clothing, or medical care. They directed the two men not to talk to others and discouraged the men from contacting their relatives. At the same time, the Kozminskis discouraged relatives, neighbors, farm hands, and visitors from contacting Fulmer and Molitoris. Fulmer and Molitoris asked others for help in leaving the farm, and eventually a herdsman hired by the Kozminskis was concerned about the two men and notified county officials! of their condition. County officials assisted Fulmer and Molitoris in leaving the farm and placed them in an adult foster care home.

In attempting to persuade the jury that the Kozminskis held their victims in involuntary servitude, the Government did not rely solely on evidence regarding their use or threat[936]*936ened use of physical force or the threat of institutionalization. Rather, the Government argued that the Kozminskis had used various coercive measures — including denial of pay, subjection to substandard living conditions, and isolation from others — to cause the victims to believe they had no alternative but to work on the farm. The Government argued that Fulmer and Molitoris were “psychological hostages” whom the Kozminskis had “brainwash[ed]” into serving them. Tr. 15, 23.2

At the conclusion of the evidence, the District Court instructed the jurors that in order to convict the Kozminskis of conspiracy under §241, they must find (1) the existence of a conspiracy including the Kozminskis, (2) that the purpose of the conspiracy was to injure, oppress, threaten, or intimidate a United States citizen in the free exercise or enjoyment of a federal right to be free from involuntary servitude, and (3) that one of the conspirators knowingly committed an overt act in furtherance of that purpose. The court further instructed the jury that §1584 required the Government to prove' (1) that the Kozminskis held the victims in involuntary servitude, (2) that they acted knowingly or willfully, and (3) that their actions were a necessary cause of the victims’ decision to continue working for them. The court delivered the following instruction on the meaning of involuntary servitude under both statutes:

“Involuntary servitude consists of two terms.
“Involuntary means ‘done contrary to or without choice’ — ‘compulsory’ — ‘not subject to control of the will.’
[937]*937“Servitude means ‘[a] condition in which a person lacks liberty especially to determine one’s course of action or ■way of life’ — ‘slavery’ — ‘the state of being subject to a master.’
“Involuntary servitude involves a condition of having some of the incidents of slavery.
“It may include situations in which persons are forced to return to employment by law.
“It may also include persons who are physically restrained by guards from leaving employment.
“It may also include situations involving either physical and other coercion, or a combination thereof, used to ■detain persons in employment.
' “In other words, based on all the evidence it will be for ;you to determine if there was a means of compulsion .used, 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.” App. to Pet. for Cert. 109a-110a.

So instructed, the jury found Ike and Margarethe Kozmin-ski guilty of violating both statutes. John Kozminski was convicted only on the § 241 charge. Each of the Kozminskis was placed on probation for two years. In addition, Ike Koz-minski was fined $20,000 and was ordered to pay $6,190.80 in restitution to each of the victims. John Kozminski was fined $10,000.

.A divided panel of the Court of Appeals for the Sixth Circuit affirmed the convictions. App.- to Pet. for Cert. 72a. After rehearing the case en banc, however, the Court of Appeals reversed the convictions and remanded the case for a new trial. 821 F. 2d 1186 (1987). The majority concluded that the District Court’s definition of involuntary servitude, which would bring cases involving general psychological coer

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United States v. Kozminski, 487 U.S. 931, 108 S. Ct. 2751, 101 L. Ed. 2d 788, 1988 U.S. LEXIS 3032, 56 U.S.L.W. 4910, 46 Empl. Prac. Dec. (CCH) 38,067 (1988).

487 U.S. 931 (United States v. Kozminski) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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