On This Day in History: United States v. Kozminski – Trafficking Matters

In 1983, after Robert and Louis had been working on the Kozminski farm for more than 10 years, a concerned local herdsman noticed the physical condition of the men and reported it to authorities. Upon investigation, the two men were found to be living “in poor health, in squalid conditions, and in relative isolation from the rest of society.” The trailer where the two lived was “filthy, having no running water, a broken refrigerator and maggot-infested food.” In response, county officials removed the men from the Kozminski farm and a case was opened by the U.S. Government in the Eastern District of Michigan. The Kozminskis were charged with 18 U.S.C. § 1584 by knowingly holding the men in involuntary servitude.

Based on the facts presented by the U.S. Government in the Federal District Court, the jury found the Kozminskis guilty, and the three received sentences.

As a result of the judgment, the Kozminskis appealed the District Court’s decision to the Sixth Circuit Court of Appeals, asserting that the District Court erred in broadly defining the term “involuntary servitude” to include psychological coercion.

Once the case reached the Sixth Circuit, the charges were reversed in agreement with the Kozminskis. In response, the case was sent back to the original Federal District Court to be heard once again with amended language to aid in determining the definition of involuntary servitude. Now, per the Sixth Circuit’s decision, in order to convict the Kozminskis on the basis of psychological coercion, the U.S. Government had to prove that Robert and Louis were members of a vulnerable class – a minor, an immigrant, or mentally incompetent.

— Read on www.traffickingmatters.com/on-this-day-in-history-united-states-v-kozminski/


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