United States v. Ingalls
United States District Court for the Southern District of California
73 F. Supp. 76 (1947)

- Written by Emily Laird, JD
Facts
Elizabeth Ingalls (defendant) kept Dora L. Jones, a Black woman, as a household servant for 25 years. Ingalls never paid Jones for her labor. Ingalls fed Jones substandard food, provided poor accommodations, and did not allow Jones’s relatives to visit her. Ingalls gave Jones no vacation days and required Jones to stay in Ingalls’s household unless Ingalls gave Jones explicit permission to run an errand. When Jones threatened to leave, Ingalls threatened Jones with imprisonment for an abortion Jones had after years of an adulterous relationship with Ingalls’s first husband. Ingalls also threatened to have Jones committed to a mental institution if Jones ever ran away. Ingalls was tried and convicted in federal district court on the charge of moving Jones from one California county to another with the intent to hold Jones as a slave. The court instructed the jury that a slave is an involuntary servant with no freedom of action and who is wholly subject to another’s will and control. Ingalls filed a motion for a new trial, asserting that there was insufficient evidence that Ingalls enslaved Jones. Ingalls also argued in her motion that the court erroneously defined the term slave in its jury instructions.
Rule of Law
Issue
Holding and Reasoning (Weinberger, J.)
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