United States v. Kozminski

PETITIONER: United States
RESPONDENT: Ike Kozminski, et al.
LOCATION: Chelsea, Michigan

DOCKET NO.: 86-2000
DECIDED BY: Rehnquist Court (1988-1990)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 487 US 931 (1988)
ARGUED: Feb 23, 1988
DECIDED: Jun 29, 1988
GRANTED: Oct 13, 1987

ADVOCATES:
Carl Ziemba - on behalf of the respondent
William Bradford Reynolds - on behalf of the petitioner

Facts of the case

In 1983, Robert Fulmer and Louis Molitoris — who have IQs of 67 and 60, respectively — were discovered working on the Kozminski dairy farm in Chelsea, Michigan. Ike Kozminski, his wife Margarethe, and his son John used the labor of Fulmer and Molitoris seven days a week, for approximately 17 hours a day since they brought the men to the farm. Margarethe picked up Fulmer from the side of road in 1967, and by doing so took him away from a farm where he previously worked. Ike Kozminski found Molitoris living on the streets in Ann Arbor in the early 1970s and brought him to the farm to work. At first, the men received $15 per day, and later they received no pay at all. Although both men were in their sixties, they had the mental capacity of children between 8 and 10 years old. The Kozminskis told Fulmer and Molitoris that they could not leave the farm, and on one occasion John Kozminski threatened Molitoris with institutionalization. They also failed to provide the men with adequate nutrition, housing, and medical care, and told them not to contact their families or any other outsiders.

Eventually, a herdsman who worked for the Kozminskis became concerned for the welfare of Fulmer and Molitoris and alerted the authorities. County officials removed the men, and the Kozminskis were tried in federal district court for holding Fulmer and Molitoris in involuntary servitude. Based on jury instructions that included forms of coercion other than purely physical, the jury found the Kozminskis guilty. The Court of Appeals for the Sixth Circuit reversed the convictions on the grounds that the District Court’s definition of involuntary servitude was too broad.

Question

Does the protection from involuntary servitude guaranteed by the Thirteenth Amendment extend to the use of psychological coercion?

Media for United States v. Kozminski

Audio Transcription for Oral Argument - February 23, 1988 in United States v. Kozminski

Audio Transcription for Opinion Announcement - June 29, 1988 in United States v. Kozminski

William H. Rehnquist:

The opinions of the Court in two cases will be announced by Justice O'Connor.

Justice O'Connor::

The first is No. 86-2000, United States versus Kozminski.

This case comes to us on writ of certiorari to the United States Court of Appeals for the Sixth Circuit.

In 1983, two mentally retarded men were found living and working on a Michigan dairy farm in squalid conditions and in relative isolation from the rest of society.

Dairy farmer, Ike Kozminski and his wife and their son John, were charged with violating Section 1584 of Title 18 of the U.S. Code which makes it a crime to hold another person in involuntary servitude.

The Kozminskis were also charged with violating Section 241 of the same code which prohibits conspiracies to interfere with rights secured by the constitutional laws of the United States.

And the conspiracy charged was a conspiracy to interfere with the Thirteenth Amendment right to be free from involuntary servitude.

The Government relied in part on evidence that the Kozminskis had used psychological coercion to cause the victims to believe they had no alternative but to work on the farm.

The District Court gave the jury a broad definition of the term involuntary servitude.

It encompassed situations involving purely psychological coercion.

The jury found the defendants guilty of some of the charges and a divided panel of the Court of Appeals affirmed.

The case was reheard en banc and the Court of Appeals reversed the convictions and remanded the case for a new trial.

The Court of Appeals ruled that the District Court's definition of involuntary servitude was too broad and also held that it generally can't exists absent the use or threatened use of physical or legal coercion to compel labor.

And the Court found an exception to the rule in cases where the defendant uses fraud or deceit to compel services from a minor and immigrant or one who is mentally incompetent.

We granted certiorari to resolve the conflict among the Courts of Appeals on the meaning of the phrase involuntary servitude for purposes of criminal prosecutions under the statutes.

In the opinion filed today, we hold that absent further guidance from Congress, the term involuntary servitude under Sections 241 and 1584 necessarily means a condition of servitude in which the victim is forced to work for the defendant either use or threat of physical restraint or physical injury or by the use or threat of coercion through law or the legal process.

We agree with the Court of Appeals that the convictions must be reversed because the District Court's instruction on involuntary servitude was too broad.

Justice Brennan with whom Justice Marshall joins and Justice Stevens, with whom Justice Blackmun joins, have filed opinions concurring in the judgment.