Forced Labor Statute Encompasses Familial Domestic Servitude

Introduction

United States v. Zahida Aman (4th Cir. Apr. 8, 2025) arises from a forced labor conspiracy in which a mother-in-law, Zahida Aman, and her two adult sons, Nauman and Rehan Chaudhri (collectively “Appellants”), compelled their daughter-in-law, referred to as M.B., to perform exhaustive household labor under threat of violence, deprivation, and deportation. M.B., brought to the United States from Pakistan as a newlywed in 2002, endured physical abuse, verbal degradation, and the confiscation of her identity documents for over a decade. The Government charged the family under 18 U.S.C. §§ 371 (conspiracy), 1589 (forced labor) and 1592 (document servitude). On appeal the Appellants challenged (1) the statute’s applicability to familial relationships, (2) the Government’s peremptory strikes under Batson v. Kentucky, (3) admission of post-labor abuse evidence, and (4) jury instructions on mens rea.

Summary of the Judgment

The Fourth Circuit unanimously affirmed the convictions. Judge Thacker, writing for the panel, held that:

• 18 U.S.C. § 1589 applies to forced domestic labor within a family; no familial exception exists.
• The Government’s peremptory strikes of young, unmarried, childless jurors—some of whom were Black—did not violate Batson once the court credited its race-neutral explanation.
• Evidence of continued abuse after forced labor ceased was intrinsic to the charged crimes, necessary to “complete the story,” and not unduly prejudicial.
• The district court’s refusal to give a subjective-intent instruction on “threats” was harmless because the jury could convict under an alternate “scheme or plan” theory that itself requires intent.

Judge Berner filed a concurrence (joined by Judge Thacker) emphasizing that the Thirteenth Amendment’s ban on “involuntary servitude” covers domestic labor in private homes just as it did forced labor of enslaved African-Americans.

Analysis

1. Precedents Cited

United States v. Toviave (6th Cir. 2014)
The Sixth Circuit vacated a forced labor conviction where a caretaker’s authority arose from state parental rights to assign chores. This Court distinguished Toviave: Appellants had no lawful parental right to compel M.B.’s labor, and the TVPA’s plain language contains no familial exception.

Barrientos v. CoreCivic, Inc. (11th Cir. 2020)
The Eleventh Circuit held “whoever” and “person” in § 1589 are broad terms—Congress did not carve out family members.

Kozminski (1988) and Jones v. Alfred H. Mayer Co. (1968)
Supreme Court decisions underscore that Congress may abolish “all badges and incidents of slavery.” TVPA was enacted under the Thirteenth Amendment to combat modern-day slavery.

2. Legal Reasoning

Statutory Interpretation and Plain Language:
The Court began with 18 U.S.C. § 1589’s text—“Whoever knowingly provides or obtains the labor or services of a person by threats… or by means of any scheme, plan, or pattern…”—noting no exception for family. “Labor” and “services” include household chores under ordinary dictionary definitions. Thus, the statute’s reach extends to forced domestic labor.

Thirteenth Amendment Purpose:
Congress enacted the TVPA to abolish involuntary servitude “akin to African slavery,” which historically encompassed domestic labor of enslaved women. A narrow construction excluding familial domestic servitude would undercut both the Amendment and the TVPA’s purpose.

Batson Challenge:
Under the three-step Batson inquiry the district court credited the Government’s race-neutral reason for striking jurors—targeting prospective jurors under 30, unmarried, and childless—over Appellants’ prima facie showing. Deference to the trial court’s credibility assessment meant no clear error.

Evidentiary Rulings:
The Fourth Circuit held abuse evidence occurring after forced labor ceased was “intrinsic” to complete M.B.’s narrative and explain why she remained trapped. Rule 403 did not bar that testimony because it was no more sensational than the charged offenses and was necessary for context.

Jury Instructions on Mens Rea:
Although Counterman v. Colorado (2023) requires at least recklessness for “true threats,” the Court found any failure to instruct on subjective intent harmless. The Government also prosecuted under § 1589(2)—“schemes or plans” requiring intent to cause fear—so no reversal was warranted.

3. Impact on Future Cases

This decision clarifies that federal prosecutors may pursue forced labor claims when family members coerce domestic labor through violence, threats or psychological coercion. State law domestic-abuse claims may now invoke federal TVPA remedies where the statutory elements are met. Defense counsel should anticipate broader federal jurisdiction in familial servitude cases. Trial courts will rely on United States v. Zahida Aman to admit a victim’s continuous abuse narrative as intrinsic evidence.

Complex Concepts Simplified

Forced Labor (18 U.S.C. §1589): The crime of compelling work against a person’s will by threats, force, or a “scheme or plan” to instill fear of harm or deportation.

Document Servitude (18 U.S.C. §1592): Illegally taking or holding someone’s passport, green card, or other identity papers to control them.

Batson v. Kentucky: A landmark rule forbidding prosecutors from striking jurors based on race. If a defendant makes a prima facie showing, the Government must offer a race-neutral reason, and the court must decide if that reason is pretextual.

Intrinsic vs. 404(b) Evidence: Intrinsic evidence arises from the same transaction as the charged crime or completes its story. Rule 404(b) forbids “other-act” evidence to show character, but intrinsic evidence is exempt.

Mens Rea—“Knowingly”: A defendant must be aware of their actions and the circumstances, not acting by mistake. Under Counterman, for “true threats” the Government need only prove recklessness—awareness of risk that statements would be taken as threats.

Conclusion

United States v. Zahida Aman establishes a pivotal precedent: federal forced labor laws sweep broadly to cover domestic servitude—even among family members—when coercion, threats, or abuse create involuntary conditions. By enforcing § 1589 according to its plain language and Thirteenth Amendment mandate, the Fourth Circuit reaffirmed that modern-day “slavery” in private homes is a federal concern. Prosecutors and courts should henceforth recognize that no familial relationship immunizes forced labor, ensuring stronger protection for victims trapped behind the veneer of traditional domestic roles.