United States v. Jordie Callahan
801 F.3d 606
| 6th Cir. | 2015Background
- Victims S.E. (developmentally disabled adult) and her toddler daughter B.E. lived with defendants Jessica Hunt and Jordie Callahan after S.E. had no other housing; Defendants confined them to locked rooms/basement, deprived them of hygiene and food, and subjected them to repeated physical and psychological abuse.
- Defendants forced S.E. to perform continuous household labor, errands, child abuse (including recorded beatings), and to obtain prescription painkillers after intentionally injuring her; Defendants confiscated and sold the medications.
- S.E. and B.E. escaped briefly but were coerced back; law enforcement removed B.E. after observing signs of severe neglect and deterioration.
- A jury convicted Hunt and Callahan of conspiracy (18 U.S.C. § 371), forced labor (18 U.S.C. §§ 1589(a), 2) with a finding that the forced-labor offenses included kidnapping under § 1589(d), and acquiring controlled substances by deception (21 U.S.C. § 843(a)(3)).
- District court denied acquittal and new-trial motions, imposed lengthy sentences (longest: Hunt 384 months; Callahan 360 months); Sixth Circuit affirmed in all respects.
Issues
| Issue | Government's Argument | Defendants' Argument | Held |
|---|---|---|---|
| Applicability of § 1589 forced-labor statute | §1589(a) reaches any "person" coerced to provide labor/services; legislative history does not limit victims to foreign nationals or sex trafficking | §1589 was meant mainly for international/sex-trafficking contexts and should not apply to a local/domestic abuse situation | Affirmed: statutory text is unambiguous; §1589 covers coerced labor of any person, including cognitively impaired victims |
| Sufficiency of evidence for forced labor | Testimony and corroborating evidence showed force, threats, deprivation, confinement, and that coercion was used to obtain labor/services | Defendants argued chores were ordinary roommate/parental tasks and that coercion was not used to obtain labor | Affirmed: viewing evidence in government’s favor, rational juror could find elements and mens rea beyond a reasonable doubt |
| Applicability and sufficiency under § 843(a)(3) (obtaining controlled substances by deception) | Statute applies to "any person" who acquires controlled substances by deception; evidence showed defendants injured S.E., coached false narratives, obtained and kept Vicodin | Defendants argued statute targets healthcare professionals / regulatory conduct and required proof that misrepresentation was the but-for cause of the prescription | Affirmed: text covers any person; evidence supported deception to obtain Vicodin; but-for causation need not defeat conviction here because sufficient causal proof existed |
| Pretrial psychological exam & use of leading questions on direct examination | Court may permit leading questions and allow witness testimony if witness understands oath; cautionary instructions suffice | Defense sought psychiatric exam to test S.E.’s competency; objected to leading questions | Affirmed: district court did not abuse discretion denying exam and permitting leading questions given S.E.’s impairment and jury instructions to assess credibility |
| Limits on cross-examination of cooperating co-conspirator | Government allowed extensive impeachment (plea, bias, prior convictions, motive); limits on certain inquiry (charging decisions) avoided confusion | Defense argued confrontation right impaired by barring questioning why co-conspirator faced different charges | Affirmed: court reasonably limited repetitive/irrelevant lines; jury had sufficient information to assess bias |
| Kidnapping enhancement & special verdict form / reasonable-doubt instruction | Jury instructed on reasonable-doubt generally; special verdict asked whether offense included kidnapping; jury polled; defense later objected to form lacking explicit "not guilty" box | Defendants argued failure to repeat reasonable-doubt standard for kidnapping and defective special verdict form | Affirmed: overall instructions repeatedly stated reasonable-doubt standard; defendants waived complaint about verdict form by counsel’s acquiescence during deliberations |
| Sentencing enhancements (serious bodily injury, dangerous weapon, duration, cross-reference to kidnapping) | Presentence findings (serious injury, use of weapon, confinement >1 year, kidnapping cross-reference) supported Guidelines enhancements and were applied without impermissible double-counting | Defendants disputed factual findings, foreseeability, double-counting, and comparative disproportionality | Affirmed: factual findings supported each enhancement; cross-reference to kidnapping permitted and did not impermissibly double-count; sentence was procedurally and substantively reasonable |
Key Cases Cited
- Kozminski v. United States, 487 U.S. 931 (Sup. Ct. 1988) (predecessor involuntary servitude jurisprudence; coercion of developmentally disabled persons can support conviction)
- Bond v. United States, 134 S. Ct. 2077 (Sup. Ct. 2014) (caution against expansive federal construction that criminalizes traditional local matters)
- United States v. Toviave, 761 F.3d 623 (6th Cir. 2014) (reversing § 1589 conviction where court viewed conduct as parental/household chores rather than forced labor)
- United States v. Moore, 423 U.S. 122 (Sup. Ct. 1975) (statutory focus on nature of drug transaction, not defendant status)
- Delaware v. Van Arsdall, 475 U.S. 673 (Sup. Ct. 1986) (Confrontation Clause limits on cross-examination but deference to reasonable trial-court limits)