## Facts

- Robert John Farrell and Angelita Magat Farrell owned and operated a Comfort Inn & Suites in Oacoma, South Dakota.
- In 2005, they recruited Filipino nationals to work at the hotel and arranged nonimmigrant visas, representing wages and terms to obtain entry.
- Workers were told not to disclose certain arrangements to consular authorities, including that travel expenses would not be reimbursed as the visa program required.
- After arrival, the Farrells imposed terms materially different from what was promised, paid substantially less than represented, and required workers to repay numerous expenses, creating and maintaining debt.
- Angelita required workers to surrender and then withheld passports, visas, and other immigration documents.
- Workers were required to work long hours and perform hotel duties; some were also directed to obtain second jobs that violated visa restrictions.
- The Farrells restricted workers’ movement and communications, including requiring permission to leave, discouraging contact with outsiders, and limiting interaction with non-Filipino workers.
- The government presented evidence of threats and intimidation, including threats to report workers to immigration authorities and to have them deported if they did not comply or repay debts.
- Local law enforcement became involved after the Farrells asked the police chief to speak to the workers; the chief suspected wrongdoing and helped remove workers from the situation.

## Issues

1. Whether the evidence was sufficient to support convictions for peonage and conspiracy to commit peonage under 18 U.S.C. §§ 1581 and 371.
2. Whether the evidence was sufficient to support the conviction for document servitude under 18 U.S.C. § 1592.
3. Whether the district court abused its discretion by admitting the government’s expert testimony concerning human trafficking and victim behavior.

## Decision

- The Eighth Circuit affirmed all convictions.
- Applying de novo review to sufficiency challenges, the court held a rational jury could find beyond a reasonable doubt that the Farrells compelled labor to satisfy debts through threats and coercive measures.
- The court held the evidence supported document servitude because the Farrells knowingly withheld passports and immigration documents as part of the coercive scheme.
- The court held the district court did not abuse its discretion in admitting expert testimony that assisted the jury in understanding victim behavior in coercive labor situations.

## Legal Principles

- Sufficiency of the evidence is reviewed de novo, viewing the evidence in the light most favorable to the government and reversing only if no reasonable jury could find guilt beyond a reasonable doubt.
- Peonage involves compulsory service to satisfy a debt, maintained through force, threats, or abuse or threatened abuse of legal process.
- Involuntary servitude may be established by compelling labor through physical restraint or injury, or by the use or threat of arrest, prosecution, or imprisonment; threats of civil litigation alone are insufficient.
- Coercion may be shown without constant physical confinement when threats (including immigration-related threats), imposed debt, isolation, and control of movement or communication operate together to prevent a reasonable person from feeling free to leave.
- Document servitude under 18 U.S.C. § 1592 is supported where a defendant knowingly confiscates or withholds passports or immigration documents in connection with, or to facilitate, trafficking-related offenses.
- Expert testimony is admissible when it is relevant and helpful to the jury and does not improperly decide credibility or guilt for the jury.

## Conclusion

The court upheld the Farrells’ convictions because the jury could reasonably find that they used debt, threats of deportation and legal consequences, isolation, and withheld immigration documents to compel workers to continue laboring, and because the challenged expert testimony assisted the jury without supplanting its role.


United States v. Farrell, 563 F.3d 364 (8th Cir. 2009)