United States v. Mussry
United States Court of Appeals for the Ninth Circuit
726 F.2d 1448 (1984)
- Written by Emily Laird, JD
Facts
The prosecution (plaintiff) indicted employers (defendants) under the involuntary-servitude statutes, 18 U.S.C §§ 1581, 1583, 1584, and 371, for holding poor, uneducated, non-English-speaking Indonesian servants in their households. The servants lived in their employers’ homes and worked up to 15 hours a day, seven days a week, performing menial tasks. The servants received wages far below minimum wage. The employers held their servants’ passports and return airline tickets, refusing to return them until the servants worked long enough to pay off the cost of their transport to the United States. The servants had no work permits, identification, or other options for employment. The employers did not use physical force to make the servants work. The prosecution claimed the employers were holding the servants in a state of involuntary servitude by coercion and that coercion could be accomplished absent the use of law or physical force. The employers alleged that the involuntary-servitude statutes were void for vagueness. The federal district court dismissed the substantive counts against the employers, finding that holding another in involuntary servitude required the use of law or physical force. The government appealed the lower court’s dismissal.
Rule of Law
Issue
Holding and Reasoning (Reinhardt, J.)
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