United States v. Kozminski

Last updated
United States v. Kozminski
Seal of the United States Supreme Court.svg
Argued February 23, 1988
Decided June 29, 1988
Full case nameUnited States v. Kozminski, et al.
Citations487 U.S. 931 ( more )
108 S. Ct. 2751; 101 L. Ed. 2d 788
Holding
For purposes of criminal prosecution, the term "involuntary servitude" necessarily means a condition of servitude in which the victim is forced to work for the defendant by the use or threat of physical restraint or physical injury or by the use or threat of coercion through law or the legal process. This definition encompasses cases in which the defendant holds the victim in servitude by placing him or her in fear of such physical restraint or injury or legal coercion.
Court membership
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr.  · Byron White
Thurgood Marshall  · Harry Blackmun
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
Case opinions
MajorityO'Connor, joined by Rehnquist, White, Scalia, Kennedy
ConcurrenceBrennan, joined by Marshall
ConcurrenceStevens, joined by Blackmun
Laws applied
U.S. Const. amend. XIII

United States v. Kozminski, 487 U.S. 931 (1988), was a United States Supreme Court case involving the Thirteenth Amendment to the United States Constitution and involuntary servitude. [1]

Contents

Ike and Margarethe Kozminski and their son John were accused of enslaving two men on their farm. A federal jury convicted the husband and wife of holding the men against their will and conspiring to do so, and John was convicted on the conspiracy charge. The case was appealed to the U.S. Supreme Court.

The Supreme Court held that the jury had been improperly instructed as to the nature of involuntary servitude under existing law and remanded the case for a new trial. [2] The defendants eventually pleaded guilty to misdemeanor violations of labor law. [3]

See also

Related Research Articles

<span class="mw-page-title-main">Thirteenth Amendment to the United States Constitution</span> 1865 Reconstruction amendment abolishing slavery except as punishment for a crime

The Thirteenth Amendment to the United States Constitution abolished slavery and involuntary servitude, except as punishment for a crime. The amendment was passed by the Senate on April 8, 1864, by the House of Representatives on January 31, 1865, and ratified by the required 27 of the then 36 states on December 6, 1865, and proclaimed on December 18. It was the first of the three Reconstruction Amendments adopted following the American Civil War.

Schenck v. United States, 249 U.S. 47 (1919), was a landmark decision of the U.S. Supreme Court concerning enforcement of the Espionage Act of 1917 during World War I. A unanimous Supreme Court, in an opinion by Justice Oliver Wendell Holmes Jr., concluded that Charles Schenck, who distributed flyers to draft-age men urging resistance to induction, could be convicted of an attempt to obstruct the draft, a criminal offense. The First Amendment did not protect Schenck from prosecution, even though, "in many places and in ordinary times, Schenck, in saying all that was said in the circular, would have been within his constitutional rights. But the character of every act depends upon the circumstances in which it is done." In this case, Holmes said, "the words used are used in such circumstances and are of such a nature as to create a clear and present danger that they will bring about the substantive evils that Congress has a right to prevent." Therefore, Schenck could be punished.

<span class="mw-page-title-main">Peon</span> Social category

Peon usually refers to a person subject to peonage: any form of wage labor, financial exploitation, coercive economic practice, or policy in which the victim or a laborer (peon) has little control over employment or economic conditions. Peon and peonage can refer to both the colonial period and post-colonial period of Latin America, as well as the period after the end of slavery in the United States, when "Black Codes" were passed to retain African-American freedmen as labor through other means.

<span class="mw-page-title-main">Involuntary servitude</span> Legal term which may constitute slavery

Involuntary servitude or involuntary slavery is a legal and constitutional term for a person laboring against that person's will to benefit another, under some form of coercion, to which it may constitute slavery. While laboring to benefit another occurs also in the condition of slavery, involuntary servitude does not necessarily connote the complete lack of freedom experienced in chattel slavery; involuntary servitude may also refer to other forms of unfree labor. Involuntary servitude is not dependent upon compensation or its amount.

<span class="mw-page-title-main">Civil Rights Act of 1866</span> U.S. law defining citizenship and equal protection

The Civil Rights Act of 1866 was the first United States federal law to define citizenship and affirm that all citizens are equally protected by the law. It was mainly intended, in the wake of the American Civil War, to protect the civil rights of persons of African descent born in or brought to the United States.

<i>Hernandez v. Texas</i> 1954 United States Supreme Court case

Hernandez v. Texas, 347 U.S. 475 (1954), was a landmark case, "the first and only Mexican-American civil-rights case heard and decided by the United States Supreme Court during the post-World War II period." In a unanimous ruling, the court held that Mexican Americans and all other nationality groups in the United States have equal protection under the 14th Amendment of the U.S. Constitution. The ruling was written by Chief Justice Earl Warren. This was the first case in which Mexican-American lawyers had appeared before the Supreme Court.

Bailey v. Alabama, 219 U.S. 219 (1911), was a United States Supreme Court case that overturned the peonage laws of Alabama.

United States v. Ball, 163 U.S. 662 (1896), is one of the earliest United States Supreme Court cases interpreting the Double Jeopardy Clause.

Thompson v. Oklahoma, 487 U.S. 815 (1988), was the first case since the moratorium on capital punishment was lifted in the United States in which the U.S. Supreme Court overturned the death sentence of a minor on grounds of "cruel and unusual punishment." The holding in Thompson was expanded on by Roper v. Simmons (2005), where the Supreme Court extended the "evolving standards" rationale to those under 18 years old.

Morgan v. Illinois, 504 U.S. 719 (1992), is a case decided by the United States Supreme Court. The case established the right of defendants to challenge for cause any juror that would automatically impose the death penalty in all capital cases.

Kansas v. Hendricks, 521 U.S. 346 (1997), was a United States Supreme Court case in which the Court set forth procedures for the indefinite civil commitment of prisoners who are convicted of a sex offense and are deemed by the state to be dangerous because of a mental abnormality.

Perry v. Louisiana, 498 U.S. 38 (1990), was a United States Supreme Court case over the legality of forcibly medicating a death row inmate with a mental disorder, to render him competent to be executed.

Riggins v. Nevada, 504 U.S. 127 (1992), is a U.S. Supreme Court case in which the court decided whether a mentally ill person can be forced to take antipsychotic medication while they are on trial to allow the state to make sure they remain competent during the trial.

Lowenfield v. Phelps, 484 U.S. 231 (1988), is a United States Supreme Court case in which the Court held that the two jury polls and the supplemental charge did not impermissibly coerce the jury to return a death sentence, and that the death sentence does not violate the Eighth Amendment simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.

Teague v. Lane, 489 U.S. 288 (1989), was a United States Supreme Court case dealing with the application of newly announced rules of law in habeas corpus proceedings. This case addresses the Federal Court's threshold standard of deciding whether Constitutional claims will be heard. Application of the "Teague test" at the most basic level limits habeas corpus.

Ludwig v. Massachusetts, 427 U.S. 618 (1976), was a case in which the Supreme Court of the United States held that the Massachusetts two-tier court system did not deprive Ludwig of his U.S. Const., Amend. XIV right to a jury trial and did not violate the double jeopardy clause of the U.S. Const., Amend. V.

Hodges v. United States, 203 U.S. 1 (1906), was a decision by the United States Supreme Court limiting the power of Congress to make laws under the Thirteenth Amendment. Three white men had been convicted in the Eastern Arkansas District Court for conspiring against black sawmill workers.

Murray v. United States, 487 U.S. 533 (1988), was a United States Supreme Court decision that created the modern "independent source doctrine" exception to the exclusionary rule. The exclusionary rule makes most evidence gathered through violations of the Fourth Amendment to the United States Constitution inadmissible in criminal trials as "fruit of the poisonous tree". In Murray, the Court ruled that when officers conduct two searches, the first unlawful and the second lawful, evidence seized during the second search is admissible if the second search "is genuinely independent of [the] earlier one."

<span class="mw-page-title-main">Polly Strong</span> Enslaved woman in the US Northwest Territory (c. 1796–unknown)

Polly Strong was an enslaved woman in the Northwest Territory, in present-day Indiana. She was born after the Northwest Ordinance prohibited slavery. Slavery was prohibited by the Constitution of Indiana in 1816. Two years later, Strong's mother Jenny and attorney Moses Tabbs asked for a writ of habeas corpus for Polly and her brother James in 1818. Judge Thomas H. Blake produced indentures, Polly for 12 more years and James for four more years of servitude. The case was dismissed in 1819.

References

  1. United States v. Kozminski, 487 U.S. 931, 934 (1988).
  2. Kozminski, 487 U.S. at 953.
  3. James Dickson, 1983: Slavers arrested, Red Berenson inducted into Hall of Honor, and Hands-On Museum celebrates first birthday , The Ann Arbor News (Oct. 19, 2010). Archived from the original on March 6, 2022

Text of United States v. Kozminski, 487 U.S. 931(1988) is available from:  CourtListener    Justia    Library of Congress    Oyez (oral argument audio)