United States v. Shackney

David I. Shackney (defendant) was charged with violating the Involuntary Servitude Act, which criminalized involuntary servitude. Shackney went to Mexico and hired Luis and Virginia Oros and their children to work on his chicken farm. In exchange for $1,200 worth of promissory notes, Shackney promised to cover the Oros family’s travel from Mexico, immigration paperwork, and room and board at his farm. The conditions on Shackney’s chicken farm were worse than what Shackney had promised the Oros family. Each month the family worked, Shackney ripped up two $100 promissory notes. Shackney was charged under 18 U.S.C §§ 1581(a) and 1584 with seven counts of involuntary servitude for Luis, Virginia, and their five children. At trial, the prosecution argued that Shackney forced the Oros family into a condition of involuntary servitude because of his threats of deportation. The Oros family testified they were rarely allowed to leave the farm. Other evidence indicated that Shackney’s farm was in the middle of town, that many visitors entered the farm with whom the Oros family interacted, that Shackney often left the Oros family unsupervised at the farm, and that there was a farm truck with a key in its ignition that Luis Oros was allowed to drive. After a jury trial in federal district court, the court granted Shackney’s motion for acquittal for the count related to Virginia Oros. The jury returned a guilty verdict on the counts of involuntary servitude for Shackney’s treatment of Luis and his children. Shackney filed motions for an acquittal and for a new trial.