United States v. Papantoniadis — Forced Labor Under § 1589 May Be Proven Through a Workplace-Wide Climate of Fear (Including Threatened Deportation) and Contextual Evidence Beyond the Named Victim

Court: United States Court of Appeals for the First Circuit  |  Date: January 21, 2026

Introduction

In United States v. Papantoniadis, the First Circuit affirmed the forced-labor and attempted forced-labor convictions of Stavros Papantoniadis, a Massachusetts pizzeria owner, under 18 U.S.C. § 1589(a) and 18 U.S.C. § 1594(a), and affirmed a 102-month prison sentence. The prosecution’s theory was not merely that Papantoniadis was “demanding” or “quick-tempered,” but that he intentionally exploited undocumented kitchen workers—through surveillance, intimidation, violence, and immigration-related threats—to keep them working long hours under harsh conditions.

The appeal raised four clusters of issues: (1) sufficiency of the evidence on five counts; (2) evidentiary rulings (primarily testimony about third-party incidents and trauma); (3) Guidelines calculations (attempt reduction, duration enhancement, and “other felony” enhancement); and (4) denial of a longer continuance and a new trial based on alleged delayed discovery disclosures.

Summary of the Opinion

A central theme is the court’s rejection of a “divide-and-conquer” view of forced labor: jurors may consider the entire workplace context, including acts and threats directed at other employees, in determining whether a particular named victim reasonably believed they had to keep working to avoid harm.

Analysis

Precedents Cited

1) Standards of review and sufficiency methodology

• United States v. Coleman (recounting facts “in the light most favorable” for sufficiency but “balanced treatment” for other claims) and its reliance on United States v. Katana and United States v. Greaux-Gomez.
  Impact in this case: framed how the panel narrated the record depending on the issue under review.
• United States v. Falcón-Nieves (sufficiency test: whether any rational juror could find the elements beyond a reasonable doubt).
• United States v. Cedeño-Pérez and United States v. Morillo (evidence must be considered “as a whole,” and “equal or nearly equal circumstantial support” for guilt and innocence requires reversal).

2) Preservation of sufficiency claims (Rule 29)

• United States v. Acevedo and United States v. Hernández (a Rule 29 motion at the close of the government’s case preserves sufficiency if the defendant presents no evidence).
• United States v. Rivera-Ortiz and United States v. Maldonado-García (waiver occurs with the combined omission of proper pre- and post-verdict motions; here, preservation existed because the defense rested without presenting evidence).

Although the Rule 29 preservation point was not novel in the abstract, the panel applied it to reject the government’s waiver argument and proceed with de novo sufficiency review—often determinative of how aggressively an appellate court scrutinizes the evidence.

3) Forced labor doctrine under § 1589 and contextual proof

• United States v. Bradley (First Circuit’s foundational forced-labor decision; “serious harm” includes nonphysical coercion; prior treatment of other employees can reinforce an inference of a deliberate intimidation scheme).
• United States v. Chaudhri (Fourth Circuit; treated threat of deportation as “serious harm”; quoted for the idea that a defendant may “create[] a climate of fear and violence through repeated physical abuse and threats of deportation”).
• United States v. Zhong (Second Circuit; whether threatened consequences are “legitimate” depends on “surrounding circumstances,” undercutting categorical defenses that immigration-related statements are always permissible warnings).
• Martínez-Rodríguez v. Giles (Ninth Circuit; coercion need not be indefinitely successful—later quitting does not negate earlier compelled labor).

These authorities anchored the panel’s refusal to confine forced-labor analysis to facts resembling Bradley’s “involuntary servitude”-like conditions. The panel emphasized statutory mapping: if a rational juror can find labor was obtained by one of § 1589(a)’s prohibited means, the conviction may stand even in a conventional workplace setting.

4) Evidentiary harmlessness

• United States v. Turner and United States v. Casas (harmless error: “highly probable” the error did not influence the verdict).

5) Sentencing review and harmless Guidelines error

• United States v. Burgos and United States v. Newton (procedural reasonableness; clear error standard for factual findings).
• United States v. Wright and United States v. Graham (Guidelines error may be harmless if the Guidelines sentencing range would be unchanged; sometimes still examine whether it influenced the judge).

6) Attempt liability and attempt Guideline

• United States v. Concepcion-Guliam and United States v. Gobbi (elements of attempt: intent plus substantial step).

7) Continuances and Brady/Giglio timing claims

• United States v. Carbone and Delgado v. Pawtucket Police Dep't (continuance discretion; must show “substantial prejudice” and an “unreasonable and arbitrary insistence upon expeditiousness”).
• United States v. Williams and United States v. Rodríguez-Durán (continuance factors; inconvenience and preparation time).
• Brady v. Maryland, Giglio v. United States, Kyles v. Whitley (government’s affirmative duty to disclose exculpatory and impeachment evidence).
• United States v. Montoya and Roe v. Lynch (Brady/Giglio scope).
• United States v. Lemmerer and United States v. Ingraldi (delayed disclosure: must show the delay prevented effective use).
• United States v. Josleyn, United States v. Cruz-Feliciano, United States v. Van Anh, and United States v. Pérez-Ruiz (delayed disclosure: key concern is whether defense strategy changed; must show a plausible strategic option foreclosed).
• United States v. Martínez-Hernández, United States v. Martínez-Mercado, and United States v. Tucker (deference to trial judge on likely impact of belatedly disclosed evidence).

8) State-law assault concepts used for the “other felony offense” enhancement

• Commonwealth v. Melton and Commonwealth v. Gorassi (Massachusetts assault may be “attempted battery” or “immediately threatened battery”).
• Commonwealth v. Leonard and Commonwealth v. Oswaldo O. (menacing conduct placing the victim in fear; intent to put in fear).
• Commonwealth v. Tevlin, Commonwealth v. Mercado, and Commonwealth v. Appleby (dangerous weapon analysis: whether the object, as used, is capable of producing serious bodily harm; plus definition of “dangerous per se”).
• United States v. Colón-De Jesús, United States v. Candelario-Ramos, and United States v. Blewitt (plain error framework for unpreserved sentencing issues).

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Legal Reasoning

1) Forced labor: coercion can be inferred from climate, context, and credible fear

The panel applied § 1589(a)’s structure as written: liability turns on whether the defendant knowingly obtained labor by any of four “prohibited means,” including force/threats, serious harm/threats, abuse of legal process, or a scheme intended to make the victim believe harm would follow quitting. The court also relied on § 1589(c)(2)’s definition of “serious harm” as an objective test calibrated to “a reasonable person of the same background and in the same circumstances.”

Three reasoning moves are especially significant:

• Rejection of “divide-and-conquer” proof. The court held that the jury could consider “the entire factual context” of a workplace with multiple employees, consistent with United States v. Bradley. This undermines defenses that attempt to compartmentalize each count to only those words and acts directly aimed at the named victim.
• Threats related to immigration enforcement fit § 1589. The court reaffirmed that nonphysical coercion can qualify, and treated threats of deportation and the threatened manipulation of police involvement as potentially falling within “serious harm” and/or “abuse or threatened abuse of law or legal process.” It relied on the statutory text and reinforced the point with United States v. Chaudhri.
• “Demanding boss” framing is not dispositive where the record supports coercion. The court emphasized that a rational juror could view surveillance, underpayment, denial of days off, intimidation, physical violence, and deportation threats as a scheme to keep undocumented workers laboring.

2) Attempted forced labor: “substantial step” and intent supported by conduct at quitting points

For attempted forced labor (counts involving Teixeira and Yanes), the panel focused on whether the evidence allowed jurors to infer intent to coerce continued labor and a substantial step toward that coercion. The court treated “You cannot leave,” violence, pursuit by vehicle, a gesture understood as signaling arrest, and a false police report as classic attempt evidence—conduct that goes beyond mere anger and can be read as using force, threats, and legal-process intimidation to keep a worker from leaving.

3) Evidentiary rulings: limiting instructions and harmless error carry the day

Even where evidentiary relevance and prejudice were arguable—e.g., testimony about an alleged prior assault on another employee (not proven) and Bonilla’s childhood trauma—the panel did not need to decide all admissibility questions definitively. Instead, it applied the First Circuit’s harmless error standard (United States v. Turner; United States v. Casas) and relied heavily on:

• the breadth of other, properly admitted evidence of abuse and intimidation;
• the district court’s limiting instructions (state-of-mind use, not truth of third-party events); and
• the fact that similar testimony about Bonilla’s father’s murder came in without objection later.

Notably, the panel recognized United States v. Bradley’s caution against convictions driven by a victim’s “hidden emotional flaw or weakness” unknown to the defendant, yet still found any error harmless because fear was independently supported by the assault-on-Teixeira evidence and other witnesses’ reactions.

4) Sentencing: attempt reduction rejected; duration enhancements upheld; “other felony” issues largely harmless

• Attempt reduction (U.S.S.G. § 2X1.1(b)(1)). The court upheld denial of the three-level reduction because the district court could find, by a preponderance, that Papantoniadis “completed all the acts he felt necessary” (assault plus police misrepresentation; vehicle pursuit and false report).
• Duration enhancement (U.S.S.G. § 2H4.1(b)(3)). The panel emphasized the district court’s correct framing: “not the length of employment but the length of the forced labor.” It affirmed the “more than one year” findings for multiple victims based on ongoing threats, surveillance, denial of time off, and intimidation over extended periods.
• “Other felony offense” enhancement (U.S.S.G. § 2H4.1(b)(4)). For Passos, the court sustained a Massachusetts assault-with-a-dangerous-weapon theory via “immediately threatened battery” (Commonwealth v. Melton) and rejected the unpreserved “pan not dangerous” argument under plain-error review.

For Teixeira, the panel declined to resolve a “complicated question” about whether a state-law misdemeanor punishable by more than one year can qualify as a “felony offense” under the Guideline commentary because any potential error did not change the Guidelines sentencing range under the grouping rules (U.S.S.G. § 3D1.4), making the issue harmless under United States v. Wright.

5) Continuance and new trial: prejudice is the fulcrum

The panel deferred to the district court’s docket management and emphasized that reversal requires specific, concrete prejudice (United States v. Carbone). The court credited the district judge’s findings that the case was not unusually complex, defense counsel were experienced, many late-produced documents were the defendant’s own business records and indexed, and inconvenience to witnesses mattered.

On Brady/Giglio delay, the panel applied the “delayed disclosure” framework (United States v. Lemmerer): the defendant must show the delay prevented effective use and plausibly foreclosed a strategic option (United States v. Cruz-Feliciano). The asserted “collusion for immigration benefits” theory was deemed insufficiently developed to demonstrate that additional time would have produced a materially different trial strategy rather than marginal closing-argument themes.

Impact

• Forced-labor prosecutions in ordinary workplaces. The decision reinforces that § 1589 is not limited to paradigmatic “slavery-like” confinement scenarios; intimidation, surveillance, immigration threats, and selective violence in a regular business can support convictions when tied to compelled labor.
• Context evidence across multiple employees. The panel’s express rejection of “divide-and-conquer” proof strengthens prosecutors’ ability (and trial courts’ willingness) to present a workplace “climate of fear” narrative—while still requiring a named victim per count.
• Sentencing in forced-labor cases. The opinion signals that (i) duration enhancements will be upheld where coercive conduct is shown to persist over time (not merely because employment lasted long), and (ii) attempt reductions are hard to obtain if the defendant has already employed the coercive mechanisms he believed sufficient.
• Discovery-timing litigation. The decision underscores that even identified disclosure missteps may not warrant a new trial absent a concrete showing that defense strategy or effectiveness was materially impaired.

Complex Concepts Simplified

• “Forced labor” under 18 U.S.C. § 1589. Not limited to chains or locked doors. It includes getting someone to work (or keep working) through threats—physical, psychological, financial, reputational, or immigration-related—so long as the pressure would compel a reasonable person in the victim’s circumstances.
• “Serious harm.” Defined broadly in § 1589(c)(2). The question is objective: would a reasonable person with the victim’s background and circumstances feel compelled to keep working to avoid the harm?
• “Abuse of law or legal process.” Using (or threatening to use) police, courts, or administrative processes for improper leverage—e.g., leveraging immigration enforcement to pressure labor.
• Attempted forced labor. Requires intent plus a “substantial step” beyond preparation—conduct strongly corroborating the intent (assault to stop quitting; threatening arrest; filing a false police report).
• Harmless error vs. plain error. Harmless error asks whether it is “highly probable” the mistake did not affect the verdict; plain error (for unpreserved issues) is harder and requires a clear, obvious mistake that affected substantial rights and seriously undermined the proceeding’s fairness.
• Guidelines grouping (U.S.S.G. § 3D1.4). Multiple counts can be grouped into “units.” Sometimes removing an enhancement from one count does not change the overall range because the highest count and the unit math still drive the final offense level.

Conclusion

United States v. Papantoniadis affirms a robust, text-driven application of § 1589: a jury may find forced labor where an employer exploits undocumented workers through a workplace-wide climate of fear—combining surveillance, intimidation, selective violence, and immigration-related threats—to compel continued labor. The opinion also illustrates the First Circuit’s practical appellate posture: evidentiary disputes often resolve through harmlessness, sentencing disputes through Guidelines-range harmlessness, and trial-management/disclosure disputes through a demanding prejudice requirement tied to concrete strategic impairment.