United States v. Calimlim
United States Court of Appeals for the Seventh Circuit
538 F.3d 706 (2008)

- Written by Emily Laird, JD
Facts
Jefferson and Elnora Calimlim (defendants) brought Irma Martinez to the United States (plaintiff) from the Philippines to work as their housekeeper and nanny. The Calimlims confiscated Martinez’s passport. The Calimlims told Martinez that she had to work off the cost of her plane ticket and her housing. For 19 years, Martinez worked 14 hours a day, seven days a week. The Calimlims ordered Martinez to hide from all outsiders. The Calimlim children were forbidden to talk about Martinez to anyone outside their family. Martinez was not allowed to seek medical or dental care. The Calimlims threatened Martinez with deportation, arrest, and imprisonment. Over 19 years, the Calimlims sent Martinez’s family only approximately $19,000 in wages for her work. The United States charged the Calimlims with violating the federal forced-labor and harboring statutes. The Calimlims were convicted in federal district court. The Calimlims appealed to the United States Court of Appeals for the Seventh Circuit, arguing that the forced-labor statute was void for vagueness and overbreadth and that there was insufficient evidence to sustain their conviction under the harboring statute.
Rule of Law
Issue
Holding and Reasoning (Wood, J.)
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