United States v. Kozminski

Robert Fulmer and Louis Molitoris, two men in their 60s each with a mental age of eight to 10 years old, worked at the farm of Ike, Margarethe, and John Kozminski (defendants). The Kozminskis gave the men inadequate food, housing, and medical care. The Kozminskis punished Fulmer and Molitoris with physical and verbal abuse, isolated them, and threatened Molitoris with institutionalization. The Kozminskis were charged in federal district court with violating the involuntary-servitude statutes. The Kozminskis argued that criminal behavior under the statutes required physical or legal acts or threats against a victim. The prosecution (plaintiff) argued that other acts of coercion beyond physical and legal acts or threats could also violate the statutes. The district court instructed the jury that it could find the Kozminskis caused involuntary servitude if the Kozminskis used physical or legal acts or threats or other means of coercion. The jury found the Kozminskis guilty of violating the statutes. The Kozminskis appealed to the United States Court of Appeals for the Sixth Circuit, arguing the lower court’s definition of involuntary servitude was too broad. The appellate court first affirmed the convictions, and then it reconsidered the case. At the rehearing, the appellate court reversed the convictions and remanded the case for a new trial. The appellate court determined there should be no finding of involuntary servitude absent physical or legal threats or acts, except if the victim was a minor, immigrant, or mentally incompetent. The prosecutor petitioned the United States Supreme Court for a writ of certiorari to resolve the issue of what conduct constitutes involuntary servitude.