United States v. Kaufman

Dr. Arlan Kaufman and his wife, Linda, a nurse (defendants), ran an unlicensed residential-care treatment center for the mentally ill on a rural farm. When deputy sheriffs visited, they discovered naked men working the fields, supervised by a clothed Dr. Kaufman. An investigation revealed that the Kaufmans were abusing the men and women in their care, requiring them to perform farm labor while unclothed and videotaping the victims being forced to perform sexual acts. The Kaufmans claimed these practices constituted legitimate psychotherapy. A grand jury charged the Kaufmans with violating the involuntary-servitude statute, 18 U.S.C. § 1584, the forced-labor statute, 18 U.S.C. § 1589, also known as the Trafficking Victims Protection Act, and a host of other healthcare and fraud offenses. In federal district court, the judge instructed the jury that involuntary servitude means a state of compulsory service in which the victim is forced to perform labor or services against the victim’s will. The judge instructed the jury that services are defined as “conduct or performance that assists or benefits someone or something.” The jury found the Kaufmans guilty of violating the involuntary-servitude and forced-labor statutes and the other charges. The Kaufmans appealed to the United States Court of Appeals for the Tenth Circuit, claiming that the judge should have limited the instruction on the definition of labor or services to work in an economic sense. The Kaufmans contended that a narrower definition was appropriate and would not have included the Kaufmans’ practices of coercing the nudity and sexual acts of their residents.