USCA4 Appeal: 23-4078 Doc: 107 Filed: 04/08/2025 Pg: 1 of 33
PUBLISHED
UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 23-4054
UNITED STATES OF AMERICA,
Plaintiff - Appellee,
v.
MOHAMMAD NAUMAN CHAUDHRI, a/k/a Nauman Chaudhri,
Defendant - Appellant.
No. 23-4077
MOHAMMAD REHAN CHAUDHRI, a/k/a Rehan Chaudhri,
No. 23-4078
Plaintiff - Appellee, USCA4 Appeal: 23-4078 Doc: 107 Filed: 04/08/2025 Pg: 2 of 33
ZAHIDA AMAN,
Appeals from the United States District Court for the Eastern District of Virginia, at Richmond. John A. Gibney, Jr., Senior District Judge. (3:19-cr-00085-JAG-2; 3:19-cr- 00085-JAG-3; 3:19-cr-00085-JAG-1)
Argued: November 1, 2024 Decided: April 8, 2025
Before GREGORY, THACKER, and BERNER, Circuit Judges.
Affirmed by published opinion. Judge Thacker wrote the opinion, in which Judge Gregory and Judge Berner joined. Judge Berner wrote a concurring opinion, in which Judge Thacker joined.
ARGUED: Barry Joel Pollack, HARRIS ST. LAURENT & WECHSLER LLP, Washington, D.C., for Appellants. Stephen Wiley Miller, OFFICE OF THE UNITED STATES ATTORNEY, Richmond, Virginia, for Appellee. ON BRIEF: Katlin K. O’Brien, HARRIS ST. LAURENT & WECHSLER LLP, Washington, D.C., for Appellant Zahida Aman. Colby J. Ryan, LAW OFFICES OF COLBY J. RYAN, San Diego, California, for Appellant Mohammed Rehan Chaudhri. Jose Garza Badillo, LAW OFFICE OF JOSE GARZA BADILLO, San Diego, California, for Appellant Mohammad Nauman Chaudhri. Kristen Clarke, Assistant Attorney General, Civil Rights Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Jessica D. Aber, United States Attorney, Shea Matthew Gibbons, Assistant United States Attorney, Richmond, Virginia, Jacqueline R. Bechara, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Alexandria, Virginia, for Appellee.
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THACKER, Circuit Judge:
Zahida Aman and her adult sons, Nauman Chaudhri and Rehan Chaudhri
(collectively, “Appellants”), each appeal their convictions for their roles in a forced labor
conspiracy. Appellants argue their convictions should be vacated because (1) the statute
does not apply to the type of familial relationship present here; (2) the Government
improperly struck jurors on the basis of race; (3) the district court admitted unduly
prejudicial evidence of abuse after the conspiracy ended; and (4) the district court
improperly instructed the jury. We conclude that the federal statute is clearly applicable,
the Government did not improperly strike jurors, and that the district court did not
otherwise reversibly err.
Therefore, we affirm Appellants’ convictions.
I.
M.B., the victim of Appellants’ forced labor conspiracy, is originally from Pakistan.
In 2001, Aman and M.B.’s mother arranged M.B.’s marriage to Aman’s son, Salman
Chaudhri. M.B. did not meet Salman until after the marriage was finalized in Pakistan in
January 2002. After the wedding, Salman told M.B. that “if his family, especially his mom,
[Aman] is happy with [M.B.], he’s going to put [her] on a pedestal and our relationship
will be good.” J.A. 530. 1 In this vein, he told M.B. that she “ha[s] to make his family,
especially his mom . . . happy.” Id.
1 Citations to the “J.A.” refer to the Joint Appendix filed by the parties in this appeal.
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About seven weeks after the marriage was finalized, M.B. received a visa and flew
to Virginia to live with Salman and his family in their family home in Midlothian, Virginia.
The first morning after M.B. arrived in Virginia, Aman took her into the living room and
said to her, “[Y]ou are the daughter-in-law of a retired general colonel and the wife of a
doctor here in the United States, so you need to put your standards up. And if you want to
be happy in your married life, the way to your husband’s heart is through me . . . . And if
you want [to make] him happy, you have to make me happy.” J.A. 534.
Soon after M.B.’s arrival in the United States, Appellants took away her notebook
containing contact information for her family and friends in Pakistan. They also made her
turn over her identification and immigration documents for safekeeping in the family safe.
But M.B. did not have access to the safe. And even though M.B. received a green card, 2
Appellants took it from her, saying it was because her name was spelled incorrectly. They
originally told her they would have the green card corrected, but she never saw it again.
M.B. testified that Appellants, as well as other members of the Chaudhri family, told her
repeatedly that she was in the country illegally, and they would have her deported if she
did not comply with their demands.
Along with taking M.B.’s documents, Aman began assigning M.B. a series of
household chores she was required to complete. M.B. testified that “[i]n the beginning it
A “green card” is a permanent residence card that allows noncitizens “to live and 2
work permanently in the United States.” U.S. Citizenship and Immigration Services, Green Card, (Dec. 4, 2024), https://www.uscis.gov/green-card [https://perma.cc/65BZ- EJDW].
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was not much.” J.A. 535. She was required to do things like clean the living room, kitchen,
bathroom, and laundry room before anyone else woke up. She was also responsible for
making meals at Aman’s request. Eventually, however, the chores became full time labor.
M.B. was expected to work all day long -- from morning before others in the house awoke
until bedtime. And as time went on, each of the three Appellants, and other uncharged
family members, began assigning M.B. more strenuous labor.
Notably, Salman did not live in the family home after the first few years of the
marriage. In fact, Salman did not even live in the same state. He was away completing his
medical residency beginning in 2005. He then moved to Pennsylvania in 2006, and to
California in 2008. Although he would return to Aman’s home for brief periods, he
remained in California for the duration of the marriage. Thus, after 2005, M.B. was living
in the family home with Appellants, but not with her husband.
M.B. testified that the work she was required to do escalated. She was required to
paint the entire home several times, including all inside rooms and the exterior as far as she
could reach. Additionally, she was made to rip up and remove carpets from within the
house; strip and re-stain the deck at least twice a year; and tear up and rebuild the cement
pathway in the front of the home at least twice. M.B. also testified that Aman and Nauman
once purchased a used car that was full of animal hair from the previous owner. They made
her clean the car and remove all of the animal hairs using “[a] tweezer with a magnifying
glass.” J.A. 571. She was also required to mow the lawn using a push mower, even though
the family had a riding lawn mower. Similarly, M.B. was required to do her and her
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children’s laundry by hand in a sink. She was not allowed to use the washer and dryer that
the rest of the family used.
Appellants’ requirement that M.B. labor in their home continued from 2002, when
she arrived in Virginia, until at least a couple years after the birth of M.B.’s fourth child in
2008. M.B. was required to work through all of her pregnancies, including even “mow[ing]
the lawn [in her] last week” of pregnancy. J.A. 604.
M.B. testified extensively at trial about the abuse she suffered in Appellants’ home.
She explained that Appellants began with verbally abusing her in 2002 by telling her that
she was a “whore, good for nothing, bastard, [and] bitch” when they were displeased with
her. J.A. 546. In addition, Appellants forced M.B. to sleep on the floor of her children’s
rooms and restricted her access to food.
Physical abuse soon followed beginning in 2003. The first instance occurred after
M.B. had stayed up late with her first child who was sick, which caused her to be late
getting downstairs to start her morning work. Aman was angry with M.B. for being late,
so Aman cussed at M.B. then slapped her and left a mark on her face. More physical abuse
followed from various family members. M.B. testified that Rehan would slap her when he
was mad at her. M.B. also testified to one occasion where another member of the family
held a knife to her throat either because she did not complete a work task or because her
children were yelling. And she discussed another instance where she was forced to mow
the lawn then wait in the laundry room without food or water until her sweat dried, before
she was permitted to enter the house to shower. After showering, M.B. tried to get herself
some food but Aman and Rehan told her she was not allowed to eat until she finished more
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work. While they were yelling at her, Rehan put his phone down and M.B. tried to grab it
to call Salman. Rehan chased her, knocked her down, and then kicked her in the stomach.
Weeks later, Rehan and his sister, Bushra, attacked M.B. because Bushra believed
M.B. needed to apologize and seek forgiveness from Rehan for trying to use his phone.
The two tied M.B. up, wrapping the rope around her neck and then pulling it tight, until
she apologized. They then dragged her out of the room so that her kids could see her and
told the children, “this is what happens if you don’t listen to us or obey us.” J.A. 609–10.
M.B. explained at trial that Appellants also threatened to have her deported on
multiple occasions when they were displeased with her. They also physically and
psychologically abused the children by forcing them to slap M.B. when they talked to her,
and by telling them that M.B. was mentally ill and they should fear her. M.B. explained
that she continued to do the work she was assigned and endure the abuse because she was
terrified Appellants were going to separate her from her kids if she did not.
Some years after the birth of her fourth child in 2008, Appellants forced M.B. to
move into the laundry room. M.B. testified that she did not have a bed in the laundry room.
Rather, she would sleep on a mat on the floor. After they moved M.B. into the laundry
room, Appellants slowly stopped assigning her work around the house. Aman would ask
M.B. to do things like “clean up the kitchen or dining room. Small things.” J.A. 658.
While she was living in the laundry room, M.B. was only allowed to “watch” her children
but was not allowed to “interact” with them. J.A. 665. Eventually Appellants stopped
requiring M.B. to perform any work.
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But the physical abuse continued. M.B. testified to one specific instance where
Rehan hit her with a board six times on the back and legs because she came back in the
house through the front door to get her prayer beads and slippers after he had locked her in
the garage so he could watch television in the living room.
And two years after she was moved into the laundry room, M.B. was exiled from
the main house altogether and forced to live in the “annex,” which was two rooms in the
garage. J.A. 667–68. M.B. was not able to access the main house, and Appellants would
supply her with one to two weeks’ worth of “microwavable food” at a time. J.A. 668. At
some point, Appellants took M.B.’s children to California to see Salman. M.B. was left in
the annex for weeks, ran out of food, and was concerned that she would never see her
children again.
In March 2016, M.B.’s brother visited Virginia from Pakistan and went to
Appellants’ house looking for M.B. M.B. had not talked to her family in more than eight
years by that point. When M.B. first talked to her brother he did not recognize her, partly
due to significant weight loss and hair loss over the 14+ years she had been in the United
States. M.B.’s brother tried to get her to leave with him, but she refused because she did
not want to leave her children. M.B’s brother bought her a cell phone, and she was able to
reconnect with him and the rest of her family in Pakistan.
M.B.’s brother returned to Virginia in May 2016 to help M.B. leave Appellants’
home. When he arrived, he witnessed Nauman slap M.B. in the face, and he called the
police for assistance. Nauman was arrested for domestic assault, and M.B. was able to
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leave and obtain medical treatment. The children were initially placed in foster care, but
M.B. obtained full custody of them in 2017.
Following an investigation, Appellants were charged with conspiracy to commit
forced labor, in violation of 18 U.S.C. § 371; forced labor, in violation of 18 U.S.C. § 1589;
and document servitude, in violation of 18 U.S.C. § 1592.
The jury convicted all Appellants of the conspiracy charge, Aman and Rehan of
forced labor, and Aman of document servitude. The district court denied Appellants’
motions for judgment of acquittal, and this timely appeal followed.
II.
A.
Appellants first argue on appeal that the district court erred in denying their motions
for judgment of acquittal because they assert that the federal forced labor statute, 18 U.S.C.
§ 1589, does not apply to familial relationships like the one here.
1.
We review the district court’s denial of a motion for judgment of acquittal de novo.
United States v. Robinson, 55 F. 4th 390, 401 (4th Cir. 2022). “We will uphold the jury’s
verdict if, viewing the evidence in the light most favorable to the government, the verdict
is supported by substantial evidence.” Id. (citation and internal quotation marks omitted).
“Substantial evidence is that which a reasonable finder of fact could accept as adequate
and sufficient to support a conclusion of a defendant’s guilt beyond a reasonable doubt.”
United States v. Burfoot, 899 F.3d 326, 334 (4th Cir. 2018) (cleaned up). We do not
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“consider the credibility of witnesses and must assume the jury resolved all contradictions
in testimony in the government’s favor.” Id. (citation omitted).
2.
Appellants argue that the district court was incorrect to hold that the forced labor
statute reaches “the domestic labor of a family member obtained by another member of the
family.” Appellants’ Opening Br. at 20. In their view, the evidence was “of family
domestic violence and abuse, a matter of traditional state law concern,” and does not fall
within the ambit of § 1589. Id.
To determine the reach of a statute, we begin “with the plain language of the statute
because when the statute’s language is plain, the sole function of the courts—at least where
the disposition required by the text is not absurd—is to enforce it according to its terms.”
Lynch v. Jackson, 853 F.3d 116, 121 (4th Cir. 2017) (cleaned up). “Only when statutory
text is ambiguous do we consider other indicia of congressional intent such as the
legislative history.” Snyder’s-Lance, Inc. v. Frito-Lay N. Am., Inc., 991 F.3d 512, 516 (4th
Cir. 2021) (citation and internal quotation marks omitted). In interpreting the plain
language of the statute, we look to “the specific context in which the language is used, and
the broader context of the statute as a whole.” Hurlburt v. Black, 925 F.3d 154, 158 (4th
Cir. 2019).
The applicable version of the forced labor statute, provides the following:
Whoever knowingly provides or obtains the labor or services of a person by . . . (1) threats of serious harm to, or physical restraint against, that person or another person;
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(2) by means of any scheme, plan, or pattern intended to cause the person to believe that, if the person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint; or (3) by means of the abuse or threatened abuse of law or the legal process, shall be fined under the title or imprisoned not more than 20 years, or both.
18 U.S.C. § 1589 (2000). The challenge here relates to the first clause: “Whoever . . .
obtains the labor or services of a person.” In Appellants’ view, they are not “whoever” and
M.B. is not “a person” within the meaning of the statute because there is a marital familial
relationship between them, such that their conduct should be excused as far as federal law
is concerned.
But the statutory language is broad. It makes no exceptions for family relationships
as Appellants suggest. Barrientos v. CoreCivic, Inc., 951 F.3d 1269, 1276 (11th Cir. 2020)
(explaining that the terms “[w]hoever” and “person” are broad and “evince[] no intent on
the part of Congress to restrict the application of the statute to particular actors or particular
victims”). And there can be no dispute that the work M.B. was required to perform in this
household was “labor or services.” “Labor” is defined as the “expenditure of physical or
mental effort especially when fatiguing, difficult, or compulsory,” and “service” is defined
as “the performance of work commanded or paid for by another.” United States v. Marcus,
628 F.3d 36, 44 n.10 (2d Cir. 2010) (quoting Labor, Merriam Webster’s Third New
International Dictionary Unabridged (2002)).
Attempting to avoid the obvious conclusion that the plain language of the statute
applies here, Appellants urge us to consider that the forced labor statute is part of the
Trafficking Victims Protection Act (“TVPA”), and its legislative purpose was to
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“implement the Thirteenth Amendment against slavery or involuntary servitude.” Muchira
v. Al-Rawaf, 850 F.3d 605, 617 (4th Cir. 2017). In Appellants’ view, a statute meant to
combat human trafficking and involuntary servitude does not “suggest[] Congress intended
to reach” the circumstances present in this case. Appellants further argue that the only
crime here was domestic abuse, which is a matter of state law.
In support of their arguments, Appellants point to a Sixth Circuit case, United States
v. Toviave, 761 F.3d 623 (6th Cir. 2014). Toviave involved a defendant who had brought
four young relatives from Togo to live with him in Michigan. Toviave had strict rules and
made the children perform chores such as cooking, cleaning, and doing laundry, and he
occasionally made them babysit the children of his girlfriend and relatives. Toviave was
also abusive to the children and would beat them “if they misbehaved or failed to follow
one of [his] many rules.” Toviave, 761 F.3d at 624. Toviave was convicted of forced labor,
but the Sixth Circuit vacated the conviction in a narrow opinion that focused specifically
on the facts of that case.
The Sixth Circuit explained that “[a]n American parent has always had the right to
make his child perform household chores. That right is codified in Michigan.” Toviave,
761 F.3d at 625. And that right applies equally to one “standing in loco parentis.” Id.
Thus, while the court recognized that “the duties assigned by Toviave are ‘labor’ in the
economic sense of the word” because “one could, and people often do, pay employees to
perform these types of domestic tasks,” it held that they were not forced labor under the
statute because a parent has a separate right to require those type of household chores. Id.
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at 625–26. And the court held that the child abuse could not be punished federally absent
any cognizable forced labor because that would be “federalization of state law.” Id. at 627.
Importantly, however, the Sixth Circuit made clear that “[t]he forced labor statute
contains no exception for parents or other close relatives,” and one “is not immunized by
that status.” Toviave, 761 F.3d at 626. But on the facts of that case, the court held narrowly
that there was no cognizable forced labor because Toviave had a legal parental right in
Michigan to require the children to perform chores. The addition of child abuse, which
was not specifically tied only to enforcement of the chores, did not take away that right or
transform child abuse into a federal crime.
Appellants attempt to bootstrap Toviave and extend its holding such that any case
involving family members and forced domestic work is not a federal crime. But that is not
only incorrect, it is absurd. To state what should be obvious -- women are not children.
Appellants had no parental role over M.B., nor did they have any legal right to force her to
do work against her will. And because she was forced to perform labor through the
prohibited means of force, coercion, physical restraint, and serious harm or threats of
serious harm, Appellants are guilty of violating the statute.
3.
In a final attempt to challenge the applicability of § 1589, Appellants argue for the
first time on appeal that the statute is unconstitutionally vague as applied because it “fails
to provide notice that a family member would violate it by forcing another family member
to perform domestic chores.” Appellants’ Opening Br. at 23.
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Because Appellants failed to make this argument below, we review it only for plain
error. See Fed. R. Crim. P. 52(b) (“A plain error that affects substantial rights may be
considered even though it was not brought to the court’s attention.”). To survive plain
error review, Appellants must demonstrate (1) an error (2) that is plain, “that is to say, clear
or obvious.” Molina-Martinez v. United States, 578 U.S. 189, 194 (2016) (citation
omitted). And (3) the error must have affected Appellants’ substantial rights, “which in
the ordinary case means [they] must show a reasonable probability that, but for the error,
the outcome of the proceeding would have been different.” Id. (citation and quotation
marks omitted). Even then, we should only exercise our discretion to recognize and correct
the error if it seriously affects the fairness, integrity, or public reputation of judicial
proceedings. Id.
“A statute is unconstitutionally vague . . . if it ‘fails to provide a person of ordinary
intelligence fair notice of what is prohibited, or is so standardless that it authorizes or
encourages seriously discriminatory enforcement.’” Martin v. Lloyd, 700 F.3d 132, 135
(4th Cir. 2012) (quoting United States v. Williams, 553 U.S. 285, 304 (2008)). “One to
whose conduct a statute clearly applies may not successfully challenge it for vagueness.”
Parker v. Levy, 417 U.S. 733, 756 (1974).
Other than pointing out that the statute does not define labor or services, Appellants
do not explain how the statute fails to put a person of ordinary intelligence on notice of the
proscribed conduct. But, because the statute does not define “labor” or “services,” the
district court defined them, as we do, by their ordinary, dictionary definitions. Appellants’
argument that the statute “fails to provide notice that a family member would violate it by
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forcing another family member to perform domestic chores” defies common sense.
Appellants’ Opening Br. at 23. The notice provided is straightforward -- the statute applies
to “whoever” violates its terms and there are no exceptions for family members. Period.
And, as we have explained, Appellants’ conduct is clearly proscribed by the statute. Thus,
they may not successfully challenge it for vagueness.
Having concluded that § 1589 applies to the relationship and conduct at issue here,
we next consider Appellants’ arguments that various errors at trial require vacatur of the
convictions.
B.
The first trial error Appellants allege is that the Government improperly used its
peremptory strikes during jury selection on the basis of race, in violation of Batson v.
Kentucky, 476 U.S. 79 (1986).
At the beginning of jury selection, the venire included 13 black jurors. Of those, six
were struck for cause. When the court turned to peremptory strikes, jury selection
proceeded in three stages. First, eight jurors were selected from an initial panel. Next, four
jurors were selected from a second panel. This completed the twelve member jury. Finally,
four alternate jurors were selected from a third panel.
The Government exercised a total of six peremptory challenges for non-alternates -
- three on black prospective jurors and three on white prospective jurors. Of the first panel,
the Government struck two black prospective jurors who were under 30, unmarried, and
childless, Jurors 9 and 26. The Government did not strike the third black juror in the first
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panel, a 42 year old black female who was married with three children. But that juror was
struck by Appellants, so she did not serve on the jury.
The second round of peremptory strikes for the non-alternate jury included a panel
of four prospective jurors, two of whom were black. The Government struck one of those,
Juror 42, who was also under 30, unmarried, and childless. 3 It did not strike Juror 49, a
31 year old black female who was unmarried but had two children. When the Government
struck Juror 42, Appellants objected and argued that the Government had improperly
exercised its peremptory strikes on the basis of race. The Government explained that it
had used its strikes to strike every prospective juror who was very young, unmarried, and
childless, because it believed those characteristics would make it difficult for those
potential jurors to understand why M.B. would stay at Appellants’ home. After hearing
this explanation, the court denied Appellants’ challenge and continued on with jury
selection. But, just a few moments later, the Government accepted Juror 38 as a member
of the jury. Juror 38 was a white male who was 34 years old, unmarried, and childless.
The court asked how the Government distinguished that juror, who was also young,
unmarried, and childless, from Juror 42. The Government responded, “Because, Your
Honor, at this point in time we have one strike left, and there are jurors left on the panel
and we want to reserve that.” J.A. 299. The Court responded, “All right. Okay. Playing
with fire.” Id.
3 Although Appellants initially claimed in their opening brief that Juror 42 was 31 years old, the record demonstrates that Juror 42 was born in 1993 and thus must have been under the age of 30 at the time of jury selection.
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The final round of peremptory strikes was for alternate jurors, and each side had
two strikes remaining. The record does not reflect which party struck which juror, but the
record demonstrates that the parties collectively struck four white males of varying ages
and family status. One of those males was the only other potential juror who was under
30, unmarried, and childless.
At the conclusion of jury selection, one black juror, Juror 49, a 31 year old female
with two children, was seated as a member of the jury. The two remaining black jurors
were seated as alternates. Sometime during the trial, Juror 49 was excused from the jury
with the consent of both parties due to childcare issues and economic hardship attributed
to her service on the jury. Appellants reminded the court of their earlier Batson challenge
and asked that one of the black alternate jurors be permitted to deliberate in place of Juror
49, rather than the white alternate who was first on the list. The district court denied the
motion, stating that it “may not have done [jury selection] the way [the Government] did it
myself, but that doesn’t mean it is improper.” J.A. 1654. No black jurors deliberated.
Pursuant to Batson, prosecutors “may not discriminate on the basis of race when
exercising peremptory challenges.” Flowers v. Mississippi, 588 U.S. 286–87 (2019) (citing
Batson, 479 U.S. at 79). A Batson challenge requires a three-step inquiry. First, the
defendant makes “a prima facie showing that a peremptory challenge was based on racial
considerations.” United States v. Dennis, 19 F.4th 656, 662 (4th Cir. 2021). Second, the
burden shifts “to the prosecution to offer a racially neutral reason for the strike; [and]
finally, the trial court determines whether a defendant has shown purposeful
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discrimination.” Id. “If a prosecutor’s proffered reason for striking a black panelist applies
just as well to an otherwise-similar nonblack [panelist] who is permitted to serve, that is
evidence tending to prove purposeful discrimination.” Miller-El v. Dretke, 545 U.S. 231,
241 (2005).
“On appeal, we sustain the trial court’s ruling unless clearly erroneous.” Dennis, 19
F.4th at 662 (citing Snyder v. Louisiana, 552 U.S. 472, 477 (2008)). This is because a “trial
court has a pivotal role in evaluating Batson claims. Step three of the Batson inquiry
involves an evaluation of the prosecutor’s credibility, and the best evidence of
discriminatory intent often will be the demeanor of the attorney who exercises the
challenge.” Snyder, 552 U.S. at 477 (cleaned up). A finding is “clearly erroneous” when
“the reviewing court . . . is left with the definite and firm conviction that a mistake has been
committed.” Anderson v. City of Bessemer City, 470 U.S. 564, 573 (1984) (citation
omitted). But “[w]here there are two permissible views of the evidence, the factfinder’s
choice between them cannot be clearly erroneous.” Id. at 574.
On appeal, Appellants argue that the district court erred in denying their Batson
challenge. Appellants specifically take issue with the Government’s decision to strike
Juror 42, a black male who was under 30, unmarried, and childless, and its decision not to
strike Juror 38, a white male who was 34 years old, unmarried, and childless. Appellants
argue these decisions are inconsistent with the Government’s proffered race neutral
reasoning at trial; namely, that it was striking jurors who were “very young,” unmarried,
and childless. J.A. 297. The Government argues now that it was more specifically striking
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jurors who were under the age of 30, unmarried, and childless. But Appellants argue that
is an impermissible post hoc rationalization.
To be sure, the Government did not inform the district court that it was defining
“very young” as jurors under 30 years of age. Nevertheless, the district court evaluated the
Government’s explanation and the credibility of the prosecutors. And while the court noted
that it may have disagreed with the trial strategy, the district court found no Batson error.
In fact, the district court explicitly rejected Appellants’ Batson challenge at least two
separate times during the trial. We may not undo that finding unless we are “left with the
definite and firm conviction that a mistake has been committed.” Anderson, 470 U.S. at
573. Upon review of the record, we are not left with any such conviction.
While we take Appellants’ point that the Government was not so precise in its
explanation at trial, the record bears out the truthfulness of its assertion that it struck
potential jurors who were “very young,” unmarried, and childless, and that its definition of
“very young” was jurors under 30. At the conclusion of jury selection, there was not a
single member of the panel who met all three criteria the Government identified. Thus, we
do not conclude that the district court’s ruling was clearly erroneous.
C.
Appellants next argue that the district court erred by admitting evidence of
Appellants’ abuse of M.B. that occurred after M.B. had admittedly stopped performing
labor and after the indictment alleged the conspiracy ended in 2014.
Appellants moved in limine to exclude the evidence, arguing that it was irrelevant
and unduly prejudicial. The Government argued that the evidence was admissible as
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intrinsic to the crime charged because it was necessary to complete the story. And it argued
alternatively that, if the evidence was extrinsic, it was admissible pursuant to Federal Rule
of Evidence 404(b) to show Appellants’ knowledge of their crime, demonstrate
consciousness of guilt, and explain why M.B. stayed in the home even after the forced
labor ended. The Government also averred that the probative value was not significantly
outweighed by the risk of unfair prejudice.
The district court found the evidence admissible as intrinsic evidence and denied
Appellants’ motion in limine to exclude it.
We review evidentiary rulings for abuse of discretion. 4 United States v. Freitekh,
114 F.4th 292, 315 (4th Cir. 2024). “In so doing, we will identify an abuse of discretion if
the court’s decision was guided by erroneous legal principles or rests upon a clearly
erroneous factual finding.” United States v. Bush, 944 F.3d 189, 195 (4th Cir. 2019)
(cleaned up). But, even a finding of error “does not end our inquiry.” United States v.
Brizuela, 962 F.3d 784, 798 (4th Cir. 2020). Pursuant to Federal Rule of Criminal
4 The Government argues that we should review this issue only for plain error because Appellants failed to object to the evidence when it was admitted during the trial. We disagree. “As a general rule, motions in limine may serve to preserve issues that they raise without any need for renewed objections at trial, just so long as the movant has clearly identified the ruling sought and the trial court has ruled upon it.” United States v. Williams, 81 F.3d 1321, 1325 (4th Cir. 1996). Appellants moved in limine to exclude this evidence, and the district court explained that it was “denying the [relevant portion of] the motion in limine.” J.A. 152. When Appellants sought clarification about the specific testimony at issue here, the district court made clear that “[n]one of it is excluded at this point.” Id. at 153. Thus, the motion in limine was sufficient to preserve this issue for appeal.
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Procedure 52(a), even if the district court erred in admitting evidence, “we will not vacate
the conviction if the error was harmless.” Brizuela, 962 F.3d at 798. “An error is harmless
if we can say with fair assurance, after pondering all that happened without stripping the
erroneous action from the whole, that the judgment was not substantially swayed by the
error.” Id. (citation and internal quotation marks omitted).
When reviewing a district court’s ruling on a motion pursuant to Federal Rule of
Evidence 403, “[w]e apply a ‘highly deferential’ standard of review . . . and a trial court’s
“decision to admit evidence over a Rule 403 objection will not be overturned except under
the most extraordinary circumstances, where that discretion has been plainly abused.”
United States v. Hassan, 742 F.3d 104, 132 (4th Cir. 2014) (cleaned up).
“Federal Rule of Evidence 404(b)(1) prohibits evidence of a crime, wrong, or other
act from being used to prove a person’s character in order to show that on a particular
occasion the person acted in accordance with the character.” United States v. Webb, 965
F.3d 262, 266 (4th Cir. 2020) (citation omitted). But Rule 404(b) is inapplicable to
“evidence that is intrinsic to the alleged crime.” Id. (citation omitted) Uncharged conduct
is intrinsic when it “arose out of the same series of transactions as the charged offense, or
is necessary to complete the story of the crime on trial.” Brizuela, 962 F.3d at 793–94
(cleaned up) (quoting United States v. Kennedy, 32 F.3d 876, 886 (4th Cir. 1994)). Put
differently, evidence is intrinsic when it “is inextricably intertwined with the evidence
regarding the charged offense [because] it forms an integral and natural part of the
witness’s accounts of the circumstances surrounding the offenses for which the defendant
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was indicted, or serves to complete the story of the crime on trial.” United States v.
Hoover, 95 F.4th 763, 770 (4th Cir. 2024) (alteration in original) (citation and internal
quotation marks omitted).
For evidence of uncharged conduct to be admissible to complete the story of a
charged offense, “the evidence must be probative of an integral component of the crime on
trial or provide information without which the factfinder would have an incomplete or
inaccurate view of other evidence or of the story of the crime itself.” Brizuela, 962 F.3d at
795. It must also be “necessary” to complete the story, meaning there must be a “clear link
or nexus between the evidence and the story of the charged offense,” and “the purpose for
which the evidence is offered is actually essential. Otherwise, the ‘complete the story’
doctrine might be used to disguise the type of propensity evidence that Rule 404(b) is
meant to exclude.” Id.
On appeal, Appellants challenge all of the evidence of their continued abuse of M.B.
after she stopped performing household labor. This includes evidence about Appellants
forcing M.B. to live in the laundry room and then the garage annex, depriving her of food
and money, cutting off her relationship with her children, and evidence regarding
Appellants’ continued physical and psychological abuse.
We have little trouble concluding that what happened between the end of M.B.’s
forced labor and her finally being freed from Appellants’ grasp “is inextricably intertwined
with the evidence regarding the charged offense [because] it forms an integral and natural
part of the witness’s accounts of the circumstances surrounding the offenses for which the
defendant was indicted.” Hoover, 95 F.4th at 770. The evidence Appellants challenge
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comes from M.B.’s own testimony about the crimes Appellants perpetrated against her. It
is a natural part of her account to tell the jury what happened from the beginning to the
end. Without this evidence, the jury could not have had a complete picture, and the jurors
would have been left to wonder how they were hearing a case in 2020 over crimes that
occurred from 2002 to roughly 2010. The challenged evidence completes the picture that
what happened here was not simply a daughter-in-law helping out with household chores
as Appellants would have the jury believe, but, rather, involuntary servitude.
Because the district court’s decision was not “guided by erroneous legal principles”
and did not “rest[] upon a clearly erroneous factual finding,” we conclude that it did not
abuse its discretion in admitting the evidence. Bush, 944 F.3d at 195 (citation omitted).
Even still, Appellants argue the evidence of their continued abuse should have been
excluded as unduly prejudicial pursuant to Federal Rule of Evidence 403. Rule 403 is a
rule of inclusion that allows courts to “exclude relevant evidence if its probative value is
substantially outweighed by a danger of one or more of the following: unfair prejudice,
confusing the issues, misleading the jury, undue delay, wasting time, or needlessly
presenting cumulative evidence.” Fed. R. Evid. 403.
Of course, “all evidence suggesting guilt is prejudicial to a defendant.” United
States v. Siegel, 536 F.3d 306, 319 (4th Cir. 2008) (citation omitted). “That kind of general
prejudice, however, is not enough to warrant exclusion of otherwise relevant, admissible
evidence.” Id. Rather, to warrant exclusion, the prejudice must be unfair, and “even then
. . . the unfair prejudice [must] substantially outweigh[] the probative value of the
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evidence.” Id. (emphasis in original). “Evidence is unfairly prejudicial and thus should be
excluded under Rule 403 when there is a genuine risk that the emotions of a jury will be
excited to irrational behavior, and this risk is disproportionate to the probative value of the
offered evidence.” United Stated v. Williams, 445 F.3d 724, 730 (4th Cir. 2006) (cleaned
up). Where the evidence is substantially similar, or at least no more sensational, than the
crimes charged, there is no unfair prejudice. See Siegel, 536 F.3d at 319–20; see also
United States v. Boyd, 53 F.3d 631, 637 (4th Cir. 1995).
Here, too, we readily conclude that the evidence was not unfairly prejudicial. The
evidence of Appellants’ continued abuse of M.B. was no more sensational than the
evidence related to their years-long conspiracy to obtain her forced labor. And, in any
event, we can say “with fair assurance, after pondering all that happened without stripping
the erroneous action from the whole, that the judgment was not substantially swayed by”
the admission of this evidence. Brizuela, 962 F.3d at 798 (citation omitted). As discussed
above, the Government presented sufficient evidence to demonstrate that Appellants forced
M.B. to labor in their home using threats of violence or a scheme or plan intended to make
her believe she or her children would be hurt, or that she would be deported, if she did not
comply. And, notably, Appellants do not challenge the sufficiency of the evidence in this
appeal beyond arguing that the statute simply does not apply. Therefore, any error on the
district court’s part was harmless.
D.
Finally, Appellants argue that they are entitled to a new trial because the district
court improperly rejected their proposed jury instruction as to the applicable mens rea.
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“We review the district court’s decision to give or refuse to give a jury instruction
for abuse of discretion.” United States v. Lighty, 616 F.3d 321, 366 (4th Cir. 2010) (citation
omitted). Where a district court declines to provide a proposed jury instruction, we will
find reversable error “only when the instruction (1) was correct; (2) was not substantially
covered by the court’s charge to the jury; and (3) dealt with some point in the trial so
important, that failure to give the requested instruction seriously impaired the defendant’s
ability to conduct his defense.” Id. (citation omitted). “[W]e do not view a single
instruction in isolation; rather we consider whether taken as a whole and in the context of
the entire charge, the instructions accurately and fairly state the controlling law.” Id.
(citation omitted).
“[A]n error in instructing the jury harmless if it is ‘clear beyond a reasonable doubt
that a rational jury would have found the defendant guilty absent the error.’” United States
v. Ramos-Cruz, 667 F.3d 487, 496 (4th Cir. 2012) (quoting Neder v. United States, 527
U.S. 1, 18 (1999)).
The applicable version of 18 U.S.C. § 1589 prohibits “knowingly provid[ing] or
obtain[ing] the labor or services of a person” by (1) “threats of serious harm to, or physical
restraint against, that person or another person”; (2) “means of any scheme, plan or pattern
intended to cause the person to believe that, if the person did not perform such labor or
services, that person or another person would suffer serious harm or physical restraint”; or
(3) “means of the abuse or threatened abuse of law or the legal process.”
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During the charge conference, the parties each proposed jury instructions related to
the meaning of “threats.” The Government proposed that the district court explain that “a
threat can be verbal or non verbal” to clarify that the first prohibited means of obtaining
labor was not limited to verbal threats. J.A. 1555. Appellants disagreed and proposed an
instruction that “a ‘threat’ is a serious statement expressing an intention to inflict harm”
and “the defendant(s) must have made the statement intending it to be a threat, or with the
knowledge that the statement would be viewed as a threat.” J.A. 186.
The district court declined to give Appellants’ proposed instruction. Instead, it
concluded that a threat can be verbal or nonverbal, and so instructed the jury. The court
also did not include Appellants’ requested instruction that they must have intended any
statements to be threats. But the court did instruct the jury that it must find beyond a
reasonable doubt that the defendants (1) provided or obtained M.B.’s labor or services; (2)
did so by any one or combination of statutorily prohibited means; and (3) acted knowingly.
The court further instructed the jury regarding the meaning of the terms “threat” and
“knowingly.” As to “threat,” the court explained,
A “threat” can be verbal or non-verbal. A verbal threat is a serious statement expressing an intention to inflict harm, at once or in the future, as distinguished from idle or careless talk, exaggeration, or something said in a joking manner. For a statement to be a threat, the statement must have been made under such circumstances that a reasonable person who heard or read the statement would understand it as a serious expression of an intent to cause harm.
J.A. 1690. And as to “knowingly”:
The term “knowingly,” as used in these instructions to describe the alleged state of mind of the defendant, means that he or she
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was conscious and aware of his or her action, realized what he or she was doing or what was happening around him or her, and did not act because of ignorance, mistake, or accident.
The intent of a person or the knowledge that a person possesses at any given time may not ordinarily be proven directly because there is no way of directly scrutinizing the workings of the human mind. In determining what a person knew or what a person intended at a particular time, you may consider any statements made or acts done by that person and all other facts and circumstances received in evidence that may aid in your determination of that person’s knowledge or intent.
You may infer, but you are certainly not required to infer, that a person intends the natural and probable consequences of acts knowingly done or knowingly omitted. It is entirely up to you, however, to decide what facts to find from the evidence received during the trial.
J.A. 1694.
According to Appellants, the district court erred when it declined to give their
requested jury instruction that, in order to convict, the jury had to find that Appellants
subjectively intended to threaten M.B. In support of their argument, Appellants rely on
Counterman v. Colorado, 600 U.S. 66 (2023).
In that case, the Supreme Court considered whether the First Amendment requires
proof, in a “true threat” criminal case, of a defendant’s subjective intent to threaten the
victim. Importantly, per Counterman, a “true threat” of violence is an “unprotected
category of communications” because true threats are “serious expressions conveying that
a speaker means to commit an act of unlawful violence.” Counterman, 600 U.S. at 74
(cleaned up). In other words, those charged in true threat cases are prosecuted solely for
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their words. To address the concern about a chilling effect on speech, the Court determined
that the First Amendment requires some subjective mental state in true threat cases, but
that “a mental state of recklessness is sufficient.” Id. at 69. That is, the Government need
only prove that the defendant “is aware that others could regard his statements as
threatening violence and delivers them anyway.” Id. at 79 (cleaned up).
In Appellants’ view, the district court’s instructions were insufficient to inform the
jury that Appellants must have at least acted with reckless disregard for the fact that their
statements could be taken as threats. The Government argues that Counterman is
inapplicable because this is not a true threat case, that the district court’s instruction was
correct even applying Counterman, and that any error was harmless.
We disagree with the Government that Counterman is inapplicable here. One theory
of criminal liability the Government pursued against Appellants was that they forced M.B.
to perform labor in their home by threatening her with violence if she failed to comply. As
in Counterman, this case presents the question of whether Appellants’ statements could be
considered criminal without running afoul of the free speech protections of the First
Amendment. See In re Rendelman, 129 F.4th 248, 252–54 (4th Cir. 2025). Counterman
instructs that the answer to this question lies in whether Appellants possessed the requisite
mens rea, or state of mind, when they made the threats. 600 U.S. at 72. The Government
was required to establish that Appellants were aware M.B. could have regarded their
statements as threatening violence. See id. at 78–80. Appellants’ proposed jury instruction
on threats would have required the jury make such a finding. See J.A. 186 (requiring the
jury to find that “the defendant(s) must have made the statement intending it to be a threat,
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or with the knowledge that the statement would be viewed as a threat”). This proffered
jury instruction correctly reflects the mandate of Counterman, but the district court
declined to give the instruction.
Further, Appellants’ proposed instruction on “threats” was not “substantially
covered” by instructions provided to the jury. See United States v. Spirito, 36 F.4th 191,
209 (4th Cir. 2022). Although the district court’s instruction on forced labor required the
jury to find that the defendants acted “knowingly,” J.A. 186, the district court’s instructions
made no mention of Appellants’ state of mind at the time they threatened M.B. Therefore,
the district court erred.
Nonetheless, the district court’s error was harmless because the Government offered
sufficient evidence for the jury to convict based on the second prohibited means: “any
scheme, plan, or pattern intended to cause the person to believe that, if the person did not
perform such labor or services, that person or another person would suffer serious harm or
physical restraint.” 18 U.S.C. § 1589 (2000). That portion of the statute independently
requires that Appellants intended to cause M.B. to believe she would be harmed, and it
criminalizes only conduct. Taking the evidence in the light most favorable to the
Government, we conclude that the Government presented sufficient evidence that
Appellants created a climate of fear and violence through repeated physical abuse and
threats of deportation when they were dissatisfied with M.B.’s work or with her attitude,
and that was a scheme, plan, or pattern intended to make M.B. believe she would be
deported and/or separated from her children if she did not continue making Appellants
happy by completing the assigned labor.
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III.
Because we conclude that 18 U.S.C. § 1589 applies here, and that the district court
did not otherwise err at trial, Appellants’ convictions are
AFFIRMED.
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BERNER, Circuit Judge, with whom Judge THACKER joins, concurring:
Today we affirm that the domestic labor to which Appellants subjected M.B. for
years is properly considered “forced labor” within the scope of the federal forced labor
statute. Our holding that the proper scope of the forced labor statute includes domestic
labor aligns fully with the purpose of the Thirteenth Amendment, the promise of which the
forced labor statute was enacted to implement.
The Thirteenth Amendment provides that “[n]either slavery nor involuntary
servitude, except as a punishment for crime whereof the party shall have been duly
convicted, shall exist within the United States, or any place subject to their jurisdiction.”
U.S. Const. amend. XIII, § 1. One of the primary purposes of the Amendment was to
“abolish the institution of African slavery as it had existed in the United States at the time
of the Civil War.” United States v. Kozminski, 487 U.S. 931, 942 (1988). The Thirteenth
Amendment’s invocation of “the term ‘involuntary servitude’ was intended to cover those
forms of compulsory labor akin to African slavery.” Butler v. Perry, 240 U.S. 328, 332
(1916).
The Thirteenth Amendment further authorizes Congress to “pass all laws necessary
and proper for abolishing all badges and incidents of slavery in the United States.” Jones
v. Alfred H. Mayer Co., 392 U.S. 409, 439 (1968) (emphasis and citation omitted).
Congress enacted the Trafficking Victim Protection Act of 2000 (TVPA), which includes
the federal forced labor statute, pursuant to this authority. See Muchira v. Al-Rawaf, 850
F.3d 605, 617 (4th Cir. 2017) (describing congressional authority to “implement the
Thirteenth Amendment against slavery or involuntary servitude” in passing the forced
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labor statute (quoting United Stats v. Toviave, 761 F.3d 623, 629 (6th Cir. 2014)). The
TVPA aimed to “combat trafficking in persons, a contemporary manifestation of slavery
whose victims are predominantly women and children, to ensure just and effective
punishment of traffickers, and to protect their victims.” TVPA, Pub. L. No. 106-386,
§ 102(a) (codified at 22 U.S.C. § 7101(a)). It “address[es] the increasingly subtle methods
of traffickers who place their victims into modern-day slavery.” H.R. Rep. No. 106-939, at
101 (2000) (Conf. Rep.) (emphasis added). In passing the TVPA, Congress specifically
sought to empower prosecutors “to bring more cases in which individuals have been
trafficked into domestic service.” Id. (emphasis added).
The Thirteenth Amendment promised to end the subjugation of enslaved Black
people. Enslavers forced enslaved Black people to engage in physical labor against their
will and to toil in brutal conditions in fields. In addition to labor outdoors, enslavers
compelled Black people, predominantly women, to endure “hard, steady, often strenuous
labor as [they] juggled the demands made by [enslavers] and other members of the
[enslavers’] family.” See Jacqueline Jones, Labor of Love, Labor of Sorrow: Black Women,
Work, and the Family from Slavery to the Present 22–23, 27 (1985). Black women were
required to be constantly on call, to carry wood and water, cook meals, clean, iron, and sew
clothes, while caring for enslavers’ children, livestock, gardens, and yards. Id. at 23, 27;
Jane E. Dabel, Domestic Workers, Oxford African American Studies Ctr. 1 (May 19,
2005); John W. Blassingame, The Slave Community: Plantation Life in the Antebellum
South 251 (rev. ed. 1979). Forced domestic labor “rivaled cotton picking as back-breaking
labor.” Jones at 27. Enslavers tortured Black women with harsh punishments, including
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physical attacks, while they labored indoors. Id. at 25–26; Blassingame at 251. Enslavers
forced Black women to work during pregnancy up until giving birth and soon thereafter,
with some even giving birth in the fields between rows of cotton. Jones at 19.
Appellants maintain that the labor M.B. was forced to perform falls outside of the
scope of the forced labor statute because it was domestic in nature. Such an interpretation
would undermine the very purpose of the law. The history of forced labor as it pertains to
enslaved Black women makes clear that the reach of the TVPA extends to forced work
beyond that which takes place outdoors or outside of family homes. Just as the Thirteenth
Amendment was intended to prohibit all “forms of compulsory labor akin to African
slavery,” Butler, 240 U.S. at 332; see also Jones, 392 U.S. at 421–23, there can be no doubt
that the forced labor statute criminalizes labor compelled by private actors inside of private
homes. The prohibition against forced labor is neither limited to non-familial relationships
nor restricted in venue to the public sphere.
Forced labor is no less forced once it passes the threshold of the home. The
Thirteenth Amendment was enacted to abolish the institution of slavery and to prohibit
compulsory labor akin to slavery. The forced labor statute was enacted to make real this
promise.