New Precedent: Federal Forced Labor Statute Encompasses Coercive Familial Domestic Service

Introduction

United States v. Mohammad Nauman Chaudhri, et al., decided April 8, 2025 by the Fourth Circuit, clarifies that the federal forced labor statute (18 U.S.C. § 1589) applies to coercive domestic labor imposed by adult family members. The appellants—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 uncompensated household labor under threat of violence, deportation, and separation from her children. On appeal, the defendants challenged the statute’s applicability to familial relationships, alleged racial bias in jury selection, contested admission of post‐labor abuse evidence, and disputed jury instructions on mens rea. The Fourth Circuit rejected each challenge and affirmed the convictions.

Summary of the Judgment

The court held that:

The plain language of 18 U.S.C. § 1589—“whoever knowingly provides or obtains the labor or services of a person by threats… or any scheme… intended to cause the person to believe that… they would suffer serious harm”—extends without exception to forced domestic labor within a family.
The statute is not unconstitutionally vague as applied, since its terms “whoever” and “person” are broad, and “labor” and “services” carry ordinary dictionary meanings.
No Batson violation occurred: the Government’s peremptory strikes against younger, unmarried, childless jurors of any race were race‐neutral and not clearly erroneous.
Evidentiary rulings admitting uncharged post‐2010 abuse were proper as intrinsic to complete the story of the conspiracy and harmless even under Rule 403.
The district court’s refusal to give a subjective‐intent jury instruction on “threats” was an error, but it was harmless because the jury also could find guilt under § 1589’s second clause (“scheme… intended to cause belief of harm”).

Accordingly, the Fourth Circuit affirmed all convictions.

Analysis

1. Precedents Cited

Key precedents shaped the court’s reasoning:

United States v. Marcus (2d Cir. 2010): Defined “labor” and “services” by ordinary dictionary definitions, endorsing a broad reading.
Barrientos v. CoreCivic, Inc. (11th Cir. 2020): Emphasized that “whoever” and “person” show Congress intended no exception for family relationships in § 1589.
United States v. Toviave (6th Cir. 2014): Narrowly held that a Michigan caretaker’s parental rights to assign chores to minors prevented a forced‐labor conviction—but acknowledged no facial family exemption in the statute.
Counterman v. Colorado (U.S. 2023): Ruled that First Amendment “true threat” prosecutions require at least recklessness—invoked by appellants to challenge jury instructions on mens rea.
Kozminski (U.S. 1988): Interpreted the Thirteenth Amendment’s involuntary servitude clause, informing § 1589’s historical and constitutional backdrop.

2. Legal Reasoning

The Fourth Circuit applied a plain‐text approach:

§ 1589’s unqualified “whoever… obtains the labor or services of a person” sweeps in all exploitative labor, without kinship-based carve‐outs.
The statutory means—threats, schemes, abuse of process—match the evidence of violence, psychological coercion, confiscation of documents, and threats of deportation used by Zahida and her sons.
Ambiguity would require consulting legislative history, but here the text is clear and consistent with the Trafficking Victims Protection Act’s purpose to abolish all “modern-day slavery,” including domestic servitude.
Challenges under the Fifth Amendment’s vagueness doctrine failed because ordinary definitions of “labor” and “services” and the expansive terms “whoever” and “person” give fair notice to “a person of ordinary intelligence.”
Batson challenges require clear error to overturn a trial court’s credibility findings regarding race‐neutral reasons for peremptory strikes. Here, striking all very young, unmarried, childless jurors—black or white—was a permissible, race‐neutral strategy.
Evidence of continued abuse after the alleged end of forced labor (2010–2016) was “intrinsic” to complete the story of the defendants’ scheme and not unfairly prejudicial under Rule 403.
Although the court declined a subjective‐intent instruction on threats, the conviction was sustainable under § 1589’s second clause, which requires proof of an “intent to cause belief of serious harm.”

3. Impact

This decision has far‐reaching implications:

It cements that familial relationships do not immunize domestic exploiters from federal forced labor charges.
It enables federal prosecutors to pursue cases of long-term domestic servitude even within private homes, advancing the TVPA’s goal of eradicating all forms of involuntary servitude.
The ruling offers guidance on Batson challenges: broad-based demographic‐profile strikes (e.g., all jurors under 30, childless, unmarried) can be upheld if applied uniformly.
Evidentiary principles reaffirm the “complete the story” doctrine for uncharged acts intrinsic to the offense.
It signals that jury instructions on mens rea in forced labor cases need not mirror “true threat” First Amendment standards if alternative statutory grounds (e.g., scheme‐or‐pattern clause) suffice to prove an intent element.

Complex Concepts Simplified

Forced Labor (18 U.S.C. § 1589): Criminalizes obtaining someone’s labor by threats, physical force, schemes intended to induce fear, or abuse of legal process.
Intrinsically Intertwined Evidence: Uncharged misconduct that completes the narrative of the crime rather than serving only to show bad character.
Batson Challenge: A defendant’s claim that peremptory jury strikes were motivated by racial discrimination, triggering a three‐step burden‐shifting inquiry.
404(b) vs. Intrinsic Evidence: Rule 404(b) bars extrinsic act evidence used to show propensity; intrinsic evidence is exempt because it is part of the charged scheme.
Rule 403 Balancing: Allows exclusion of relevant evidence if its unfairly prejudicial effect substantially outweighs its probative value.
Plain‐Text Statutory Interpretation: Courts enforce the unambiguous terms of a statute without resort to legislative history.
True Threats Doctrine (Counterman): First Amendment requires at least a reckless mental state for speech to be criminalized as a “true threat,” but § 1589 can be violated under non‐speech‐only clauses.

Conclusion

United States v. Mohammad Chaudhri affirms that federal forced labor laws reach coercive domestic servitude imposed by family members, reinforcing Congress’s intent—rooted in the Thirteenth Amendment—to abolish all forms of involuntary servitude. The Fourth Circuit’s careful analysis of statutory text, persuasive legislative purpose, and trial‐level rulings on jury selection, evidence, and instructions provides a robust roadmap for future forced labor prosecutions. This precedent ensures that private homes cannot be sanctuaries for modern-day slavery, and it underscores the judiciary’s commitment to dismantling every “badge and incident” of involuntary servitude in the United States.