Case source

United States v. Kozminski

United States v. Kozminski, 487 U.S. 931 (1988)

Source reviewed November 4, 2026

What the source establishes

The majority construed involuntary servitude under both § 241 and § 1584 to require compulsion through physical restraint or injury, or coercion through law or the legal process, including threats of those means. Other coercive conduct, poor conditions, and vulnerability may be relevant as corroboration or to assess whether the required coercion could compel the particular victim, but cannot substitute for it. The Court affirmed reversal of the convictions and remanded for a new trial; it found the evidence sufficient for a jury to consider conviction under the stricter rule, but did not decide guilt.