## Facts

- Ike and Margarethe Kozminski and their son John operated a dairy farm in Michigan.
- Two adult men with significant intellectual disabilities, Robert Fulmer and Louis Molitoris, worked on the farm.
- The men worked extremely long hours, often seven days a week and up to 17 hours per day, for minimal wages that eventually became no pay.
- They lived in poor health, squalid conditions, and relative isolation from the broader community.
- Evidence at trial described physical and verbal abuse, threats of physical harm, and a threat to reinstitutionalize one of the men if he did not comply.
- Federal authorities became involved after a farm worker alerted officials; the men were removed and a federal prosecution followed.
- The defendants were convicted under 18 U.S.C. § 241 (conspiracy to interfere with the Thirteenth Amendment right to be free from involuntary servitude) and 18 U.S.C. § 1584 (holding persons to involuntary servitude).
- The trial court instructed the jury that involuntary servitude could be shown by “any means of compulsion” sufficient to make a person in the victims’ situation believe there was no reasonable escape and no choice but to remain.

## Issues

1. For criminal prosecutions under 18 U.S.C. §§ 241 and 1584, whether “involuntary servitude” includes compulsion through general psychological coercion.
2. Whether the jury instructions were legally erroneous for permitting conviction based on compulsion not limited to threats or use of physical force or legal coercion.

## Decision

- The Supreme Court affirmed the judgment setting aside the convictions and requiring a new trial.
- The Court held that, for §§ 241 and 1584, “involuntary servitude” means labor compelled by the use or threat of physical restraint or physical injury, or by the use or threat of coercion through law or the legal process.
- The Court rejected an open-ended standard that would allow conviction based on any form of coercion, including purely psychological pressure, as too vague for criminal liability.
- The Court did not decide whether the evidence would support convictions under the correct, narrower standard; the case required jury instructions confined to physical or legal coercion.

## Legal Principles

- Under 18 U.S.C. §§ 241 and 1584, the government must prove the victim was forced to work by:
  - the use or threat of physical restraint,
  - the use or threat of physical injury, or
  - the use or threat of coercion through law or the legal process, including conduct that places the victim in fear of such sanctions.
- Purely psychological coercion, standing alone, does not satisfy “involuntary servitude” for purposes of these criminal statutes.
- A broad “any means of compulsion” definition risks unconstitutional vagueness in criminal enforcement by failing to give fair notice and by inviting arbitrary prosecution.
- Ambiguity in the scope of criminal statutes is resolved narrowly under the rule of lenity.

## Conclusion

The Court construed “involuntary servitude” in §§ 241 and 1584 to reach only labor compelled by threatened or actual physical force or legal coercion, and it required a new trial because the jury had been instructed under a broader psychological-coercion standard.


United States v. Kozminski, 487 U.S. 931 (1988)