N.Y. Laws » CHAPTER Penal / PART Specific Offenses / TITLE Offenses Against the Person Involving Physical Injury, Sexual Conduct, Restraint and Intimidation / ARTICLE Kidnapping, Coercion and Related Offenses
New York Consolidated Laws

N.Y. Penal Law § 135.35 (2026)

Labor trafficking

✓ current as of May 2026
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§ 135.35 Labor trafficking.
  A person is guilty of labor trafficking if he or she compels or
induces another to engage in labor or recruits, entices, harbors, or
transports such other person by means of intentionally:
  1. requiring that the labor be performed to retire, repay, or service
a real or purported debt that the actor has caused by a systematic
ongoing course of conduct with intent to defraud such person;
  2. withholding, destroying, or confiscating any actual or purported
passport, immigration document, or any other actual or purported
government identification document, of another person with intent to
impair said person's freedom of movement; provided, however, that this
subdivision shall not apply to an attempt to correct a social security
administration record or immigration agency record in accordance with
any local, state, or federal agency requirement, where such attempt is
not made for the purpose of any express or implied threat;
  3. using force or engaging in any scheme, plan or pattern to compel or
induce such person to engage in or continue to engage in labor activity
by means of instilling a fear in such person that, if the demand is not
complied with, the actor or another will do one or more of the
following:
  (a) cause physical injury, serious physical injury, or death to a
person; or
  (b) cause damage to property, other than the property of the actor; or
  (c) engage in other conduct constituting a felony or unlawful
imprisonment in the second degree in violation of section 135.05 of this
article; or
  (d) accuse some person of a crime or cause criminal charges or
deportation proceedings to be instituted against such person; provided,
however, that it shall be an affirmative defense to this subdivision
that the defendant reasonably believed the threatened charge to be true
and that his or her sole purpose was to compel or induce the victim to
take reasonable action to make good the wrong which was the subject of
such threatened charge; or
  (e) expose a secret or publicize an asserted fact, whether true or
false, tending to subject some person to hatred, contempt or ridicule;
or
  (f) testify or provide information or withhold testimony or
information with respect to another's legal claim or defense; or
  (g) use or abuse his or her position as a public servant by performing
some act within or related to his or her official duties, or by failing
or refusing to perform an official duty, in such manner as to affect
some person adversely.
  Labor trafficking is a class D felony.
Notes of Decisions
Cited in 8 cases (2 in the last 5 years), 1984–2026 · leading case: Ross v. Jenkins, 325 F. Supp. 3d 1141 (D. Kan. 2018).
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Ross v. Jenkins, 325 F. Supp. 3d 1141 (D. Kan. 2018). · cites it 2× “Law § 483 -bb(c) provides a civil action for victims of labor trafficking, as defined by N.Y. Penal Law § 135.35 . The definition of human trafficking in § 135.”
Bassik v. Scully, 588 F. Supp. 895 (E.D.N.Y 1984). “FACTS In June 1977, following a jury trial, petitioner was convicted by the Nassau County Court of kidnapping in the first degree (N.Y.Penal Law Section 135.35). It is undisputed that petitioner committed the kidnapping; petitioner’s defense was insanity.”
People v. Khan, 127 A.D.3d 1250 (N.Y. App. Div. 2015). “Defendant was charged with two counts of labor trafficking alleging that she improperly compelled Gunness to work for her, both by threatening to disclose to immigration officials that his marriage with an American citizen was a sham and by withholding travel documentation from…”
People v. L.F., 2026 NY Slip Op 03186 (N.Y. App. Div. 2026). · cites it 4× “10 to vacate the judgment on the grounds that she was a victim of sex and labor trafficking pursuant to Penal Law §§ 135.35 and 230.34, and that she was deprived of the effective assistance of counsel by her counsel's alleged failure to adequately advise her of the immigration…”
Contreras v. Castro (E.D.N.Y 2024). · cites it 2× “Compare N.Y. Penal Law § 135.35 and N.Y. Soc. Servs.”
People v. Jagota, 128 A.D.3d 1092 (N.Y. App. Div. 2015). “The evidence was also legally sufficient to establish the defendant’s guilt of two counts of labor trafficking beyond a reasonable doubt (see Penal Law § 135.35 [3], [4] [a]). Moreover, upon our independent review pursuant to CPL 470.”
People v. Jagota, 128 A.D.3d 1091 (N.Y. App. Div. 2015). “The defendant’s contention that the evidence was legally insufficient to support her convictions of two counts of labor trafficking (Penal Law § 135.35 [3], [4] [a]) is partially unpreserved for appellate review (see People v Hawkins, 11 NY3d 484 [2008]).”
People v. L.G., 41 Misc. 3d 428 (N.Y. City Crim. Ct. 2013). “New York did so alongside the passage of the labor trafficking statute (Penal Law § 135.35), which created a D felony offense for the crime of exploiting someone’s labor through a number of specified means similar to the statutory framework of sex trafficking.”
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