United States v. Toviave, No. 13-1441 (6th Cir. 2014)
Annotate this CaseToviave immigrated to the U.S. in 2001, and, using false immigration documents, later brought four young relatives from Togo to live with him. He made the children cook, clean, and do laundry. He occasionally made the children babysit for his girlfriend and relatives. Toviave would beat the children if they misbehaved or failed to follow rules. Toviave provided for the children by working two jobs and did yard work. Toviave bought the children sports equipment and let them play soccer. The children exercised with him and went on family trips together. Toviave emphasized education; many of his punishments stemmed from problems related to schoolwork. He hired a tutor to teach the children English. He imposed mandatory study periods. The children always attended school. Teachers began to suspect abuse. Michigan authorities investigated. The children were removed from the house. The Department of Homeland Security obtained a warrant and discovered false immigration documents in Toviave’s home. Toviave pled guilty to visa and mail fraud charges, and the government dropped a human trafficking charge. Toviave was convicted of four counts of forced labor, 18 U.S.C. 1589. The Sixth Circuit reversed, stating that Toviave’s treatment of the children was “reprehensible,” but was not forced labor.
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