United States v. Djoumessi

Joseph Djoumessi (defendant) brought 14-year-old P. to the United States from Cameroon on a fraudulent passport. Djoumessi and his wife promised P. that she would receive room, board, and schooling in exchange for light housekeeping and nannying services. When P. arrived, the Djoumessis made her work 14-hour days caring for the house and children. P. was neither paid nor allowed to attend school. P. had no contact with outsiders and was forbidden to leave. P. slept in the Djoumessis’ often-flooded basement, where she was not allowed to bathe or use menstrual products. Djoumessi threatened P. with deportation and jail and punished P. with beatings, threats, and rape. Four years after P. arrived at the Djoumessis’ home, a neighbor called the police. P. was removed from the home. A state trial court convicted Djoumessi of criminal sexual conduct and child abuse. Four years later, Djoumessi was changed in federal district court with violating the involuntary-servitude statute. Djoumessi was convicted after a bench trial and sentenced to 204 months’ imprisonment and ordered to pay P. $100,000 in restitution. Djoumessi appealed to the Sixth Circuit, arguing there was insufficient evidence for his conviction for violating the involuntary-servitude statute because P. was not restrained, did not take any opportunities to escape, stated she wanted to remain in the United States, and would have endured worse circumstances in her native Cameroon. [Ed.’s note: Djoumessi also appealed this second sentence on double-jeopardy grounds, but the court’s discussion and ultimate rejection of the double-jeopardy argument is not included in the casebook excerpt.]