Supreme Court Defines Involuntary Servitude

1988

After two mentally retarded men were found laboring on a farm in poor health, in unclean conditions and in relative isolation from the rest of society, their employers were charged with civil rights violations for conspiring to hold the men in involuntary servitude. 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. They were threatened with physical abuse and told that if they did not work, they would be sent back to an institution. A lower court found the employers guilty and defined involuntary servitude to include “psychological coercion.” In this case, United States v. Kozminski, the U.S. Supreme Court reverses the convictions, finding that the lower court used the wrong definition of “involuntary servitude” when instructing the jury. The Supreme Court finds that “involuntary servitude” means “a condition 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 the law or the legal process.” However, because the evidence clearly shows that a conviction might be proper, the Court orders the lower courts to hold a new trial.