United States v. Kozminski (1987)
- Docket
- 86-2000
- Decided
- 1987-01-01
Summary
Question: Does the protection from involuntary servitude guaranteed by the Thirteenth Amendment extend to the use of psychological coercion? Conclusion: No. Justice Sandra Day O’Connor delivered the opinion of the unanimous Court. The Court held that precedent had established that the type of involuntary servitude prohibited by the Thirteenth Amendment is limited to that “enforced by the use or threatened use of physical or legal coercion.” Involuntary servitude had never before been extended to cover labor compelled by the use of psychological coercion. The government’s use of a broader interpretation makes the criminal nature of the action dependent on the victim’s state of mind, which cannot always be foreseen. The mental state of the victim is only relevant in determining whether or not the physical or legal coercion was effective. In his concurring opinion, Justice William J. Brennan, Jr. wrote that the Court unnecessarily narrowed the definition of the involuntary servitude. He argued that there are many different methods of coercion that can all be equally effective in reducing the victim to a state of involuntary servitude. The proper understanding of the term is defined by the conditions of servitude that the Thirteenth Amendment was meant to eradicate: conditions similar to those of slaves before the Civil War. Justice Thurgood Marshall joined in this concurring opinion. Justice John Paul Stevens concurred in the judgment. He argued that the attempt to define “involuntary servitude” based on hypothetical situations is irrelevant to the legal issues at hand. Rather, he found that the statute was written to be decided on a case-by-case basis. In this case, the defendants were rightfully convicted on the basis of jury instructions, but Justice Stevens agreed with the Court of Appeals finding that expert testimony was erroneously admitted. Therefore, he agreed with judgment of the Court that the case should be remanded. Justice Harry A. Blackmun joined in the concurrence in the judgment.