5th Amendment-Statutory Interpretation

7^th Circuit Court of Appeals

Case Name: Aleksey Ruderman v. Kenosha County

Case No.: 24-2939

Officials: Brennan, Chief Judge, and Easterbrook and Sykes, Circuit Judges.

Focus: 5^th Amendment-Statutory Interpretation

Three civil immigration detainees held in a county jail alleged that jail officials compelled them to perform unpaid custodial work, including cleaning and sweeping. According to the complaint, detainees who refused to perform this work were threatened with disciplinary sanctions, including the loss of privileges and placement in solitary confinement for up to ten days. The plaintiffs had not been convicted of any criminal offense. They were being detained pending immigration proceedings. The detainees brought suit under 18 U.S.C. § 1589, the federal forced labor statute, and sought relief through the civil remedy provided by 18 U.S.C. § 1595.

The Eastern District of Wisconsin dismissed the action at the pleading stage, concluding that § 1589 applies only in the context of human trafficking and that disciplinary measures imposed during lawful civil detention does not constitute trafficking or forced labor within the meaning of the statute. In reaching this conclusion, the court relied primarily on the title and perceived purpose of the broader legislative scheme in which § 1589 appears, the Trafficking Victims Protection Act of 2000, rather than on the text of § 1589 itself.

The Seventh Circuit rejected the district court’s interpretation,, ruling that the plain language of § 1589 is not limited to cases involving human trafficking and extends to forced labor imposed on civil immigration detainees, including those housed in county jails. The court further determined that counties fall within the statute’s use of the term “whoever” and that threats of solitary confinement used to compel unpaid labor may constitute a violation of § 1589. Accordingly, the court vacated the district court’s dismissal and remanded the case for further proceedings, including consideration of the defendants’ argument that the statute is unconstitutionally vague.

Vacated and remanded.

Decided 06/05/26

Full Text