Manliguez v. Joseph
United States District Court for the Eastern District of New York
226 F. Supp. 2d 377 (2002)
- Written by Caitlinn Raimo, JD
Facts
Elma Manliguez (plaintiff), a native of the Philippines, was employed as a domestic servant by Martin and Somanti Joseph (the Josephs) (defendants) in Malaysia while the Josephs resided there. In November 1998, the Josephs returned to the United States. Manliguez accompanied them under the belief that they were visiting rather than moving. Once in the United States, Manliguez learned the Josephs were staying long-term only when she saw a moving truck outside their home. Although Manliguez protested, the Josephs refused to purchase her plane ticket home or return her passport to her and pressured her to stay with them. While employed by the Josephs, Manliguez endured 18-hour workdays with no days off. She was not provided with adequate food or any personal-care items, was locked inside the home, was isolated from her family abroad, was verbally abused, and was paid only $1,050 for two years of work. In October 2000, Manliguez escaped, and neighbors assisted her in relocating to a safe house. In 2001, Manliguez sued, contending, among other claims, that she was subjected to involuntary servitude by the Josephs and seeking civil damages. The Josephs moved to dismiss on the grounds that Manliguez failed to state a claim upon which relief could be granted. Manliguez opposed the motion.
Rule of Law
Issue
Holding and Reasoning (Garaufis, J.)
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