Forced Labor Statute Encompasses Domestic Familial Relationships: United States v. Chaudhri Precedent

Introduction

United States v. Mohammad Chaudhri, decided April 8, 2025 by the Fourth Circuit, cements the principle that the federal forced labor statute (18 U.S.C. § 1589) applies to abusive, coercive domestic labor even when the victim and perpetrators are related by marriage or blood. Zahida Aman and her sons Nauman and Rehan Chaudhri were convicted of conspiring to force M.B., Zahida’s daughter-in-law, to perform years of household work under threat of violence, deportation, and harm to her children. On appeal the Chaudhris challenged the statute’s reach, jury selection, evidence admitted at trial, and jury instructions. The Fourth Circuit rejected those claims and affirmed the convictions.

Summary of the Judgment

• The court held that the plain text of § 1589—“whoever knowingly provides or obtains the labor or services of a person by threats of serious harm … or by means of any scheme…intended to cause the person to believe…they would suffer serious harm”—contains no exception for familial relationships.

• Familial status neither immunizes abusers nor places forced domestic labor beyond federal reach. The Fourth Circuit distinguished but did not limit the Sixth Circuit’s narrow decision in Toviave, which turned on a state parental right to order child chores, and reaffirmed that forced labor prosecutions are not a mere “federalization of state domestic-abuse law.”

• The appellate court found no Batson error in the government’s non-racial peremptory strikes of certain jurors under age 30, unmarried, and childless, and no reversible abuse of discretion in allowing evidence of abuse after labor ceased (intrinsic to complete the story of the conspiracy).

• A minor jury-instruction error under Counterman v. Colorado, 600 U.S. 66 (2023) was harmless because the government had an independent theory—“scheme or pattern”—requiring proof of intentional coercion. The convictions for conspiracy (18 U.S.C. § 371), forced labor (18 U.S.C. § 1589), and document servitude (18 U.S.C. § 1592) were affirmed.

Analysis

Precedents Cited

1. Toviave v. United States, 761 F.3d 623 (6th Cir. 2014): held that a parent’s state-law right to require child chores precluded forced labor liability where child abuse and chores were distinct. The Fourth Circuit distinguished Toviave’s unique parental-rights holding and clarified that familial relationships pose no bar to § 1589.

2. Marcus (2d Cir.) and Barrientos (11th Cir.): defined “labor” and “services” by their ordinary dictionary meaning—“physical or mental effort” and “performance of work commanded”—and rejected any familial carve-outs.

3. Muchira v. Al-Rawaf, 850 F.3d 605 (4th Cir. 2017): discussed Congress’s authority under the Thirteenth Amendment to prohibit modern slavery, including forced labor.

4. Counterman v. Colorado, 600 U.S. 66 (2023): held that true-threat prosecutions under the First Amendment require proof of at least recklessness as to how speech will be perceived. The Fourth Circuit applied Counterman to jury instructions on mens rea for threats, concluding any error was harmless in light of the “scheme or pattern” theory.

Legal Reasoning

• Statutory Text: “Whoever…obtains the labor or services of a person” by coercion or threats plainly encompasses forced domestic labor. “Person” and “whoever” are unqualified.

• Structural Context: Section 1589 is part of the Trafficking Victims Protection Act, enacted under Congress’s Thirteenth Amendment power to abolish “badges and incidents of slavery.” That Act expressly addresses modern forms of slavery and “involuntary servitude” akin to historical forced household labor.

• Toviave Distinction: Toviave involved children with a state-law parental obligation to perform chores; here, M.B. was an adult daughter-in-law with no legal duty to serve.

• Jury Selection (Batson): Prosecutorial strikes of black jurors under age 30, unmarried, and childless were upheld. The district court credited the government’s age-based, non-racial rationale. Appellants failed to show purposeful discrimination under the deferential “clearly erroneous” standard.

• Admission of Abuse After Labor Ended: Evidence of continuing physical and psychological abuse was intrinsic to the forced labor story. It explained why M.B. stayed, how the conspiracy endured in fear, and completed the narrative of the crime. Any Rule 403 prejudice was not “unfair,” and any error was harmless given the sufficiency of the core evidence.

• Jury Instructions: The district court omitted a subjective-intent element for “threats,” but under Counterman recklessness is enough. Moreover, the government’s “scheme or pattern” theory itself required proof of Appellants’ intent to coerce—so any instructional shortcoming was harmless.

Impact on Future Cases

• Clarifies that § 1589 reaches forced domestic labor within families and in-law relationships.
• Disavows a broad “familial relationship” exception and confirms that coercive household servitude is modern slavery.
• Guides lower courts on evaluating Batson challenges when juror characteristics (e.g., age, marital status) are used non-racially.
• Reaffirms the “complete the story” doctrine for intrinsic evidence in long-running conspiracies.
• Illustrates the limited reach of Counterman to First Amendment “true threat” contexts and the sufficiency of alternate coercion theories under § 1589.

Complex Concepts Simplified

• Forced Labor (18 U.S.C. § 1589): When you make someone work by threatening violence, physical restraint, harm, or a plan that makes them fear such harm, you commit forced labor—no matter who they are or what relationship you have.
• Intrinsic vs. 404(b) Evidence: If an uncharged bad act naturally flows from or completes the story of the crime on trial, it is “intrinsic” and admissible. Only truly separate or propensity-driven acts must pass the strict 404(b) test.
• Batson Challenge: You can’t strike jurors just because of their race. If the prosecution gives a believable non-racial reason for a strike, and the court believes it, you lose.
• Complete the Story Doctrine: Jurors need a coherent narrative. If part of the crime’s timeline extends beyond the charged period or continues after labor ends, it may still be admitted to show why the victim stayed and how the scheme functioned.
• Recklessness in Threats: Under Counterman, you don’t have to mean to threaten someone—you just have to realize they might take your words as a serious threat and say them anyway.

Conclusion

United States v. Chaudhri confirms that the federal forced labor statute reaches abusive domestic servitude even within families. By applying a plain-text interpretation, respecting Congress’s Thirteenth Amendment mandate, and upholding key evidentiary principles, the Fourth Circuit decisively rejects any familial exemption to modern-day slavery laws. This ruling will guide prosecutions of coercive domestic labor schemes and ensure that no one remains beyond the reach of federal anti-slavery statutes.