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United States v. Kozminski
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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.
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. The defendants eventually pleaded guilty to misdemeanor violations of labor law.
Quotes
The Supreme Court’s “Kozminski” precedent in 1988 warned that expanding forced-labor law to psychological pressure would expose ordinary religious life to criminal prosecution. The Court described the risk with unusual clarity, observing that a religious leader who obtains services through doctrinal teaching could be accused of involuntary servitude.
Massimo Introvigne, "Trafficking Accusations Against Religion: Why the TVPA Should Be Amended", Bitter Winter (August 7, 2026)
External links
Category:United States case law
Category:1980s in the United States
Category:1988