## Facts

- Elizabeth Ingalls kept Dora L. Jones, a Black woman, as a household servant for more than 25 years.
- Jones performed most household labor daily, arose early, had no days off or vacations, and received no compensation.
- Jones was forbidden to leave except to run errands, was isolated from friends and family, and was required to turn away at least one visiting relative.
- Jones lived in poor quarters, received inferior food compared to customary servant standards, and was physically abused on several occasions.
- When Jones sought to leave, Ingalls used coercion including threats to have Jones prosecuted and imprisoned based on an old adulterous relationship and an abortion, and threats to have her committed to a mental institution.
- The indictment alleged that on or about October 11, 1946, Elizabeth and Alfred Wesley Ingalls enticed, persuaded, and induced Jones to travel from Berkeley to Coronado, California, intending that she be held as a slave.
- The government’s evidence linked the 1946 travel to the continuing pattern of coercion and domination used to keep Jones in uncompensated servitude, including conditions after the trip (such as being made to sleep in an automobile for about a month while continuing to work).

## Issues

1. Whether the evidence was sufficient to support the jury’s finding that the defendant induced Jones’s travel with the intent that Jones be held as a “slave” under former 18 U.S.C.A. § 443.
2. Whether the court’s jury instruction defining “slave” was erroneous and required a new trial.

## Decision

- The court denied Elizabeth Ingalls’s motion for a new trial.
- The court held the evidence supported the conviction under § 443, including proof of intent to hold Jones in slavery following the transportation.
- The court held its definition of “slave” for the jury was legally correct and not prejudicial.

## Legal Principles

- For § 443, “slavery” is not limited to formal chattel ownership; it includes a practical condition of enforced or extorted servitude in which a person has no meaningful freedom of action and is subject to another’s will and control.
- Coercion sufficient to establish slavery/involuntary servitude may be shown through threats and other nonphysical pressures, including threats of legal process and institutionalization, when they function to compel labor and prevent departure.
- Intent under § 443 may be inferred from a long-running coercive relationship and the use of the same coercive methods to induce travel and continue compelled service after the transportation.

## Conclusion

The court left the jury’s guilty verdict in place, concluding that decades of uncompensated labor maintained through domination, isolation, and threats of prosecution or commitment constituted extorted servitude, and that the 1946 inducement to travel was undertaken with the intent that the victim remain in that condition within the meaning of former 18 U.S.C.A. § 443.


United States v. Ingalls, 73 F. Supp. 76 (S.D. Cal. 1947)