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United States v. Farrell

United States Court of Appeals for the Eighth Circuit
563 F.3d 364 (2009)


Facts

The federal government (plaintiff) prosecuted Robert John Farrell and Angelita Magat Farrell (defendants) for several offenses, including the imposition of peonage, conspiracy to impose peonage, and the imposition of document servitude, in violation of 18 U.S.C. §§ 1581, 371, and 1592. The trial evidence established that the Farrells recruited nine Filipino women to come to the United States and work as housekeepers in the Farrells' hotel. The Farrells deceived immigration officials into issuing temporary visas, and then forced the women to pay the visa-processing fee and their travel expenses. Once the women arrived in this country, the Farrells confiscated their passports and visas. The Farrells paid the women far less than they had been promised, and then charged the women excessive fees for their transportation, housing, and personal items. This caused the women to run up large debts, which the Farrells made them repay by forcing them to take second jobs and work 17 hours every day. The Farrells forbade the women from socializing, verbally abused them, deprived them of their privacy, required them to request permission to perform the most mundane tasks, and threatened them with deportation if they failed to comply with the Farrells' demands. Despite being terrified of the Farrells, the women eventually alerted authorities, who investigated their plight and arrested the Farrells. The jury found the Farrells guilty. On appeal to the Eighth Circuit Court of Appeals, the Farrells contended that the evidence was insufficient to sustain their convictions.

Rule of Law

Issue

Holding and Reasoning (Melloy, J.)

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