## Facts

- David I. Shackney operated a chicken farm in Connecticut and recruited Luis Oros, Oros’s wife, and their five children from Mexico to work on the farm.
- Shackney arranged transportation and immigration processing and provided room and board; the family signed promissory notes totaling about $1,200 to be worked off through labor.
- The government alleged the family’s work and living conditions were materially worse than promised and that Shackney used threats of deportation and indebtedness to keep them working.
- The government’s evidence also showed the family was not physically confined: the farm was in town, visitors came to the property, Shackney often left them unsupervised, and a truck was available that Luis was permitted to drive.
- Shackney was indicted on nine counts alleging peonage and involuntary servitude involving Luis, his wife, and the children.

## Issues

1. Whether “holding to involuntary servitude” under 18 U.S.C. § 1584 includes compulsion by threats of deportation and economic pressure absent physical force or legal coercion.
2. Whether the trial evidence was sufficient to prove beyond a reasonable doubt that Shackney knowingly and willfully held Luis Oros and the children to involuntary servitude.

## Decision

- The Second Circuit reversed the convictions.
- The district court had acquitted Shackney on counts involving Virginia Oros and, after election, the government dismissed the peonage count as to Luis and proceeded solely under § 1584.
- The jury convicted Shackney on six § 1584 counts (Luis and the five children), but the appellate court held the government’s proof did not establish involuntary servitude as defined by § 1584.
- The court construed § 1584 to reach compulsion comparable to slavery or peonage through physical force, threats of physical harm, or legal coercion, not threats of deportation or economic hardship that leave a real ability to leave.
- Given the evidence of practical means of exit and lack of physical or legal compulsion, the convictions could not stand.

## Legal Principles

- Under 18 U.S.C. § 1584, “holding to involuntary servitude” requires coercion through physical force, threats of physical harm, or legal coercion/abuse of legal process, producing compelled labor akin to slavery or peonage.
- Severe economic pressure, debt arrangements, harsh employment conditions, or threats such as deportation do not alone constitute involuntary servitude if the worker retains a meaningful choice to leave.
- Criminal statutes must provide clear notice of prohibited conduct; interpreting “involuntary servitude” to include broad categories of psychological or economic pressure risks vagueness and arbitrary enforcement.
- The statutory inquiry is distinct from moral blameworthiness; exploitative conduct may be wrongful yet fall outside § 1584 absent the required type of compulsion.

## Conclusion

The court reversed Shackney’s § 1584 convictions because the government proved, at most, coercive economic and immigration-related pressure, not the force- or law-based compulsion that the statute requires to establish involuntary servitude.


United States v. Shackney, 333 F.2d 475 (2d Cir. 1964)