United States v. Kozminski
1988 United States Supreme Court case / From Wikipedia, the free encyclopedia
United States v. Kozminski, 487 U.S. 931 (1988), was a United States Supreme Court case involving the Thirteenth Amendment to the United States Constitution and involuntary servitude.[1]
Quick Facts United States v. Kozminski, Argued February 23, 1988 Decided June 29, 1988 ...
United States v. Kozminski | |
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Argued February 23, 1988 Decided June 29, 1988 | |
Full case name | United States v. Kozminski, et al. |
Citations | 487 U.S. 931 (more) 108 S. Ct. 2751; 101 L. Ed. 2d 788 |
Holding | |
For purposes of criminal prosecution, the term "involuntary servitude" necessarily means a condition of servitude in which the victim is forced to work for the defendant 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. This definition encompasses cases in which the defendant holds the victim in servitude by placing him or her in fear of such physical restraint or injury or legal coercion. | |
Court membership | |
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Case opinions | |
Majority | O'Connor, joined by Rehnquist, White, Scalia, Kennedy |
Concurrence | Brennan, joined by Marshall |
Concurrence | Stevens, joined by Blackmun |
Laws applied | |
U.S. Const. amend. XIII |
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Ike and Margarethe Kozminski and their son John were accused of enslaving two men on their farm. A federal jury convicted the husband and wife of holding the men against their will and conspiring to do so, and John was convicted on the conspiracy charge. The case was appealed to the U.S. Supreme Court.
The Supreme Court held that the jury had been improperly instructed as to the nature of involuntary servitude under existing law and remanded the case for a new trial.[2] The defendants eventually pleaded guilty to misdemeanor violations of labor law.[3]