US v. Chaudhri: This case involves a mother, Aman, and her two adult children, Nauman and Rehan. Aman arranged for another of her sons, Salman, to marry MB, who at the time lived in Pakistan. After a wedding there, MB came to Virginia to live with Salman’s family (Salman himself, a doctor, was frequently living in other states while working). Over the next 15 years, Aman and the others largely treated MB like a servant, requiring her to do chores and home maintenance (in addition to care of her own children), punctuated by verbal and physical abuse. As a result, they charged with and convicted of conspiracy to commit forced labor (all three), forced labor (Aman and Rehan), and document servitude (Aman).
On appeal, the Fourth Circuit affirmed their convictions. The defendants’ primary argument was that the district court erred in denying motions for judgements of acquittal because “the federal forced labor statute . . . does not apply to familial relationships like the one here.” Rather, the evidence showed “family domestic violence and abuse, a matter of traditional state law concern.” The court disagreed, holding that the “statutory language is broad” and “makes no exceptions for family relationships,” noting that there could be “no dispute” that MB was required to provide “labor or services” in the household. The court distinguished a case that involved children providing services and also concluded that the statute was not unconstitutionally vague.
Judge Berner, joined by Judge Thacker, wrote a concurrence emphasizing that the majority holding “aligns fully with the purpose of the Thirteenth Amendment, the promise of which the forced labore statute was enacted to implement.”
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