Anora v. Oasis Professional Management Group, Ltd., 1:19-cv-11732

Plaintiff Ceferino Anora, Jr. sued Oasis Professional Management Group, Ltd., Marissa Beck, and immigration lawyer Ramon Avena under the Trafficking Victims Protection Act (TVPA), alleging forced labor/human trafficking.
Oasis and Beck offered Anora a physical‑therapist job and EB‑2 immigration sponsorship; Avena prepared the immigration filings.
The first filing was denied for a defective notice of filing; Avena and others advised Anora he could lawfully continue working while a second application was filed.
The second application was only partially successful; Anora alleges Avena nonetheless misrepresented its effect so Anora would keep working at below‑market compensation.
Anora alleges Oasis employees threatened not to respond to USCIS requests unless he continued working, but does not allege Avena made threats or participated in that threat.
Avena moved to dismiss; Magistrate Judge Fox recommended dismissal and the district court adopted the R&R, dismissing the claims against Avena.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Avena "abused or threatened to abuse legal process" under 18 U.S.C. § 1589(a)(3)	Anora: Avena knowingly obtained his labor by misleading him about the effect of the second immigration filing, pressuring him to continue working	Avena: He gave (allegedly incorrect) legal advice but did not threaten or coerce; at most malpractice	Court: Dismissed — allegations show incorrect advice, not threats or abuse of legal process
Whether Avena engaged in a scheme causing belief of "serious harm" under § 1589(a)(4) (e.g., fear of deportation)	Anora: Avena’s advice about immigration consequences caused him to fear deportation and continue working	Avena: He warned about visa expiration/deportation risk as ordinary legal counsel; no intent to create coercive scheme; threats were by Oasis employees, not Avena	Court: Dismissed — mere legal advice about deportation risk is not a scheme to cause belief of serious harm
Whether Avena knowingly benefited from a venture that obtained labor by prohibited means under § 1589(b)	Anora: Avena received legal fees while participating in the venture that obtained his labor	Avena: He received routine payment for legal services and had no knowledge or reckless disregard of any TVPA violations	Court: Dismissed — routine legal fees do not establish knowledge of or participation in TVPA violations

Adia v. Grandeur Mgmt., Inc., 933 F.3d 89 (2d Cir. 2019) (deportation can constitute "serious harm" under Section 1589)
Geiss v. Weinstein Co. Holding LLC, 383 F. Supp. 3d 156 (S.D.N.Y. 2019) (attorney receipt of fees for representing a client engaged in TVPA violations alone does not state a claim under Section 1589)