United States v. Jean Toviave, 2014 U.S. App. LEXIS 14906

Defendant Toviave, a Togolese immigrant in Michigan, brought four young relatives to live with him; they arrived with false immigration documents.
He required the children to do household chores (cooking, cleaning, laundry, packing), babysit occasionally, attend school, and complete extensive study periods; he sometimes paid for tutors and recreational activities.
Toviave frequently beat the children with hands and implements for disobedience or minor rule violations; Michigan authorities removed the children after abuse allegations.
DHS agents later found false immigration papers; Toviave pleaded guilty to visa and mail fraud, and was tried on four counts of forced labor under 18 U.S.C. § 1589 (one count per child).
At trial the jury convicted him of forced labor; on appeal the Sixth Circuit reversed those convictions, concluding the evidence did not establish federal forced labor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether requiring children to perform household chores can constitute "forced labor" under 18 U.S.C. § 1589	The government: chores and babysitting, enforced by abuse and immigration fraud, amounted to coercion and forced labor	Toviave: household chores are ordinary parental expectations and not federal forced labor	Reversed — chores enforced in this familial context did not meet § 1589 as proven here
Whether use of physical abuse to enforce chores transforms otherwise lawful parental demands into federal forced labor	Government: the abusive means show coercion sufficient for § 1589	Defendant: abuse makes the conduct state child-abuse, not a federal forced-labor offense	Reversed — abuse alone does not convert routine chores into federal forced labor absent other indicia of exploitation
Whether applying § 1589 here would improperly federalize traditional state child-abuse and family-regulation matters	Government: federal interest in combating trafficking/forced labor justifies application	Defendant: reading § 1589 to cover this would criminalize ordinary parental/locoparentis authority and intrude on state police powers	Court: declined expansive reading — statutes should not be read to displace traditional state crimes without clear Congressional intent

United States v. Kozminski, 487 U.S. 931 (discusses scope of Thirteenth Amendment protections and exceptions for traditional parental rights)
Jones v. United States, 529 U.S. 848 (cautions against reading federal statutes to encompass traditionally local crimes)
Bond v. United States, 134 S. Ct. 2077 (requires clear congressional intent before federalizing ordinary local wrongdoing)
United States v. Sabhnani, 599 F.3d 215 (example of forced labor/domestic-service convictions based on coercion and exploitation)
United States v. Djoumessi, 538 F.3d 547 (involuntary servitude conviction involving severe domestic exploitation)
United States v. Calimlim, 538 F.3d 706 (domestic servitude case involving isolation and control)
United States v. Dann, 652 F.3d 1160 (nanny forced-labor case where passport confiscation, nonpayment, and secrecy supported conviction)
United States v. Afolabi, [citation="508 F. App'x 111"] (scheme bringing girls to U.S. for extensive unpaid labor; courts found forced labor)
United States v. Nnaji, [citation="447 F. App'x 558"] (domestic-worker forced-labor case contrasted with this record)
United States v. King, 840 F.2d 1276 (cult/involuntary servitude precedent noting parental acquiescence does not automatically immunize defendants)