Immigration precedents

The Sixth Circuit upheld Djoumessi's convictions under 18 U.S.C. § 1584 for holding a minor female in involuntary servitude and for harboring an alien for financial gain. Applying Kozminski, the court held that threats of deportation can constitute coercion through the legal process, and that even if the victim had opportunities to escape, involuntary labor during at least some portion of her stay suffices to sustain the conviction.

The Fourth Circuit upheld the conviction of a couple for conspiring to hold a minor in involuntary servitude; the co-conspirator's sexual abuse of the victim was a form of force used to keep her in servitude and was properly admitted as evidence of the involuntary servitude conspiracy.