United States v. Ike Kozminski, Margarethe Kozminski, and John Kozminski

MERRITT, Circuit Judge.

A jury convicted the defendants, a dairy farmer and his wife, of two federal crimes: (1) “willfully holding to involuntary servitude” two retarded farm workers,1 and (2) conspiring to deprive the workers of their constitutional right to be free from “involuntary servitude” as guaranteed by the Thirteenth Amendment.2 Their son was *1188also convicted on the conspiracy charge. On appeal the defendants contend that the court below erred in broadly defining “involuntary servitude” to include purely psychological coercion in addition to slavery, peonage, serfdom and other forms…