United States v. Kozminski

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United States v. Kozminski
Seal of the United States Supreme Court
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
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]

Ike and Margarethe Kozminski 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 all the way 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[edit]


  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).

External links[edit]

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