Legal Opinion

United States v. Jean Toviave

Court of Appeals for the Sixth Circuit

Decided August 4, 2014No. 13-1441PublishedCited by 17 opinions

1Opinion of the Court

OPINION

ROGERS, Circuit Judge.

Child abuse is a state crime, but not a federal crime. Forced labor is a federal crime, 18 U.S.C. § 1589, but the statute obviously does not extend to requiring one’s children to do their homework, babysit on occasion, and do household chores. Only by bootstrapping can this combination of two actions that are not federal crimes — child abuse and requiring children to do household chores — be read as a federal crime.

Defendant Toviave brought four young relatives from Togo to live with him in Michigan. After they arrived, Toviave made the children cook, clean, and…

2Cases cited18 opinions

  1. United States v. BassSupreme Court of the United States · 1971
  2. Moore v. SimsSupreme Court of the United States · 1979
  3. Gregory v. AshcroftSupreme Court of the United States · 1991
  4. Equal Employment Opportunity Commission v. Arabian American Oil Co.Supreme Court of the United States · 1991
  5. Jones v. United StatesSupreme Court of the United States · 2000

13 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. United States v. Jordie CallahanCourt of Appeals for the Sixth Circuit · 2015
  2. Winfred Muchira v. Halah Al-RawafCourt of Appeals for the Fourth Circuit · 2017
  3. United States v. Jeff LevenderisCourt of Appeals for the Sixth Circuit · 2015
  4. Gonzalez v. CoreCivicCourt of Appeals for the Fifth Circuit · 2021
  5. United States v. Mohammad ChaudhriCourt of Appeals for the Fourth Circuit · 2025

12 more not listed; retrieve them via the Exa API.

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