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Rana v. Islam
United States District Court for the Southern District of New York
305 F.R.D. 53 (2015)
Monirul Islam (defendant) served as the consul general of Bangladesh in New York City. Islam and his wife (defendant) employed Mashud Rana (plaintiff), a Bangladeshi citizen, as a personal household worker. Islam and his wife contracted with Rana in Bangladesh, offering to pay a monthly salary, provide days off, and renew Rana’s visa before it expired. Upon arrival in the United States, Rana was allegedly forced into involuntary servitude through threats, restraints, and physical force. Rana was not allowed to talk with anyone outside the house or to make phone calls. Rana was paid none of the promised salary and was provided no days off from work. Rana’s duties primarily consisted of household work for Islam and his family, but Rana also occasionally cooked for guests and at the Bangladesh Consulate. Islam and his family moved to Morocco for Islam to serve as the ambassador of Bangladesh. Islam instructed Rana to move to Morocco with the family, and Rana overheard Islam threaten Rana’s life if he refused to move. Rana fled the residence and filed suit in federal district court, alleging violations of human-trafficking laws, the Fair Labor Standards Act, and state labor laws. Among other arguments, Islam and his wife filed a motion to dismiss the suit for lack of subject-matter jurisdiction. Islam and his wife claimed that they were immune from civil actions due to consular immunity.
Rule of Law
Holding and Reasoning (Stein, J.)
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