## Facts

- Joseph and Evelyn Djoumessi arranged for 14-year-old Pridine Fru to enter the United States from Cameroon using a false name and fraudulent passport.
- Fru was brought to the Djoumessis’ home with the stated understanding that she would do household work and childcare in exchange for support and schooling.
- For about three years, Fru performed most household labor and nearly all childcare, worked long daily hours without pay, and was not sent to school.
- Fru lived in poor conditions in the home’s basement and was denied basic hygiene accommodations and menstrual supplies.
- The Djoumessis restricted Fru’s movement and contact with others and warned that contacting police would lead to jail because of her immigration status.
- Fru was subjected to beatings and threats; Joseph sexually abused her on multiple occasions.
- In 2000, after police intervention, Michigan prosecuted Joseph; he was convicted of third-degree criminal sexual conduct and third-degree child abuse and sentenced to a prison term.
- In 2005, federal prosecutors indicted Joseph (and Evelyn) based on the same general course of conduct; after a federal bench trial, Joseph was convicted of holding a minor in involuntary servitude (18 U.S.C. § 1584), conspiracy to do so (18 U.S.C. §§ 371, 1584), and harboring an alien for private financial gain (8 U.S.C. § 1324), and received a sentence partially consecutive to the state sentence.

## Issues

1. Whether the federal prosecution after state convictions violated the Double Jeopardy Clause under the dual-sovereignty doctrine, including whether the narrow *Bartkus* “sham prosecution” theory applied.
2. Whether the evidence was sufficient to prove willfully holding Fru in involuntary servitude and conspiring to do so under 18 U.S.C. § 1584.

## Decision

- The Sixth Circuit affirmed all convictions.
- The court held that the Double Jeopardy Clause did not bar the federal case because state and federal prosecutions are permitted under dual sovereignty and the record did not support a “sham prosecution” claim.
- The court held the evidence was sufficient to support the involuntary-servitude and conspiracy convictions, given proof of coercion through abuse, threats, and immigration-based intimidation.

## Legal Principles

- Under the dual-sovereignty doctrine, successive prosecutions by state and federal governments for the same conduct generally do not violate Double Jeopardy.
- The *Bartkus* “sham prosecution” theory is exceptionally narrow and requires proof that one sovereign was merely a tool of the other; routine cooperation or sequential prosecutions is insufficient.
- For 18 U.S.C. § 1584, involuntary servitude for “any term” can be established even if coercion is shown for only part of the relevant period; duration need not be substantial.
- Coercion for § 1584 may be shown through physical violence, threats, and abuse of legal process, including exploiting a victim’s immigration status to deter contact with authorities.
- A conspiracy to hold someone in involuntary servitude may be proven by coordinated conduct maintaining a coercive environment and benefiting from the victim’s compelled labor.

## Conclusion

The Sixth Circuit upheld Djoumessi’s federal convictions, rejecting his Double Jeopardy challenge under dual sovereignty and finding the trial evidence sufficient to prove that Fru’s labor was compelled through violence, threats, and immigration-based intimidation, supporting both involuntary servitude and conspiracy liability.


United States v. Djoumessi, 538 F.3d 547 (6th Cir. 2008)