Modern Slavery - In Maryland

Last Friday, the Fourth Circuit upheld a conviction based on behavior that you'd hope wouldn't surface in the 21st Century. In US v. Udeozor, the defendant and her husband convinced a family in Nigeria to allow their 14-year old daughter to emigrate to the United States, with promises of education and money sent back to the family. It didn't work out that way:

The victim lived with the Udeozors from October 1996 until October 2001. During that time, the Udeozors required her to care for their children, to clean their house, and to cook for them. The victim testified at trial that she was also required to work in Dr. Udeozor’s medical office, where she performed multiple tasks, including answering the phones, preparing patient charts, verifying patients’ insurance information, and cleaning out medical examination rooms. The victim received no compensation for her work. The victim’s father testified that he received only '[o]ne piece of cloth and a bag of rice.' The Udeozors never enrolled the victim in any school.

During this time, the Udeozors subjected the victim to repeated physical, emotional, and sexual abuse. In particular, at trial, the victim testified that Dr. Udeozor hit her with an 'open hand, and sometimes her fist, and then sometimes she would use her shoe.' She also testified that Dr. Udeozor threw things at her, and that Dr. Udeozor 'would twist and pull [her] ear.' During one particular beating, the Udeozors forced the young girl to kneel and raise her hands above her head, after which Dr. Udeozor beat her in her sides with a flexible wooden cane, and Mr. Udeozor struck her in the hand with the metal part of a belt. After the beating, Dr. Udeozor forced the victim to continue kneeling for an additional forty-five minutes. This beating left the victim with marks on her sides and breathing difficulties. During another beating, Dr. Udeozor struck the victim with a shoe, causing her wrist to be dislocated. The victim never received any medical attention after any of these beatings.

The Udeozors also emotionally abused the victim. The Udeozors threatened to send the victim back to Nigeria, and they told her that the government would deport her if she left the house because she did not have 'papers.' Finally, between 1997 and 1999, Mr. Udeozor forced the victim — on numerous occasions — to engage in sexual intercourse with him, conduct which the government characterized in its argument at trial as 'rape.' The victim testified that Mr. Udeozor threatened to and did sexually assault her more frequently and more forcefully if his children misbehaved or suffered harm while in her care. Mr. Udeozor also warned the victim that if she spoke to anyone about the sexual assaults, he would tell her parents that she had become a prostitute.

Udeozor was convicted of conspiracy to keep someone in a condition of involuntary servitude and harboring an alien for private gain. She received a sentence of 87 months in prison. The husband, it appears, has skipped the country.

The Fourth Circuit summed up the situation quite well:

In the jury’s view, Dr. Udeozor was part of a conspiracy that substituted for a promised education and compensation a regime of psychological cruelty and physical coercion that took some of the best years of a young girl’s life. For that, involuntary servitude is not too strong a term.

Indeed.