18 U.S.C. § 1592

Unlawful conduct with respect to documents in furtherance of trafficking, peonage, slavery, involuntary servitude, or forced labor

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(a) Whoever knowingly destroys, conceals, removes, confiscates, or possesses any actual or purported passport or other immigration document, or any other actual or purported government identification document, of another person—(1) in the course of a violation of section 1581, 1583, 1584, 1589, 1590, 1591, or 1594(a);(2) with intent to violate section 1581, 1583, 1584, 1589, 1590, or 1591; or(3) to prevent or restrict or to attempt to prevent or restrict, without lawful authority, the person’s liberty to move or travel, in order to maintain the labor or services of that person, when the person is or has been a victim of a severe form of trafficking in persons, as defined in section 103 of the Trafficking Victims Protection Act of 2000,shall be fined under this title or imprisoned for not more than 5 years, or both.(b) Subsection (a) does not apply to the conduct of a person who is or has been a victim of a severe form of trafficking in persons, as defined in section 103 of the Trafficking Victims Protection Act of 2000, if that conduct is caused by, or incident to, that trafficking.(c) Whoever obstructs, attempts to obstruct, or in any way interferes with or prevents the enforcement of this section, shall be subject to the penalties described in subsection (a).(Added Pub. L. 106–386, div. A, § 112(a)(2), Oct. 28, 2000, 114 Stat. 1488; amended Pub. L. 110–457, title II, § 222(b)(6), Dec. 23, 2008, 122 Stat. 5070.)Editorial NotesReferences in Text

Section 103 of the Trafficking Victims Protection Act of 2000, referred to in subsecs. (a)(3) and (b), is classified to section 7102 of Title 22, Foreign Relations and Intercourse.

Amendments

2008—Subsec. (c). Pub. L. 110–457 added subsec. (c).

Notes of Decisions
Cited in 56 cases (29 in the last 5 years), 2000–2026 · leading case: United States v. Dann, 652 F.3d 1160 (9th Cir. 2011).
United States v. Dann, 652 F.3d 1160 (9th Cir. 2011). · cites it 3× “§§ 1589 and 1594; (iv) document servitude in violation of 18 U.S.C. § 1592 ; and (v) harboring an illegal alien for private financial gain in violation of 8 U.”
Lagayan v. Odeh, 199 F. Supp. 3d 21 (D.D.C. 2016). · cites it 3× “§ 1590 , which prohibits recruiting, harboring, or transporting a person to provide or obtain such person’s labor or services; and (3) 18 U.S.C. § 1592 , which prohibits destroying, concealing, removing, confiscating, or possessing a passport or other immigration document of…”
United States v. Zhong, 26 F.4th 536 (2d Cir. 2022). · cites it 2× “with forced labor, in violation of 18 U.S.C. § 1592 (a); (4) alien smuggling conspiracy, in violation of 8 U.”
Elat v. Ngoubene, 993 F. Supp. 2d 497 (D. Maryland 2014). · cites it 2× “Although her search was fruitless and therefore did not lead to a violation of 18 U.S.C. § 1592 (a), it raises the inference that Roxane Ngou-bene was part of a scheme to keep Plaintiff in the Ngoubene household as a domestic servant.”
Winfred Muchira v. Halah Al-Rawaf, 850 F.3d 605 (4th Cir. 2017). “§ 1584 ; (5) unlawful conduct with respect to documents in furtherance of trafficking, peonage, slavery, *616 involuntary servitude, or forced labor, in violation of 18 U.S.C. § 1592 ; and (6) bene-fitting financially from trafficking in persons, in violation of 18 U.”
United States v. Farrell, 563 F.3d 364 (8th Cir. 2009). · cites it 2× “§ 1546 , and one count of document servitude in violation of 18 U.S.C. § 1592 . The Farrells appeal, arguing that the evidence was insufficient to support the jury’s verdict as to the charges of peonage, conspiracy to commit peonage, and document servitude.”
Nuñag-Tanedo v. East Baton Rouge Par. Sch. Bd., 790 F. Supp. 2d 1134 (C.D. Cal. 2011). · cites it 2× “§ 1589”; “[tjrafficking persons with respect to forced labor in violation of 18 U.S.C. § 1592 (a)”; “[u]nlawful document-related practices in furtherance of trafficking in violation of 18 U.”
Franco v. Diaz, 51 F. Supp. 3d 235 (E.D.N.Y 2014). · cites it 2× “18 U.S.C. § 1592 (a) Finally, the TVPRA also provides for liability of any person who “knowingly destroys, conceals, removes, confiscates, or possesses any actual or purported passport or other immigration document, or any other actual or purported government identification…”
Lagasan v. Al-Ghasel, 92 F. Supp. 3d 445 (E.D. Va. 2015). · cites it 3× “§§ 1590 , 1595; (4) unlawful conduct with respect to documents in furtherance of trafficking, peonage, slavery, involuntary servitude, or forced labor in violation of the TVPA, 18 U.S.C. §§ 1592 , 1595; (5) benefiting financially from trafficking in persons in violation of the…”
United States v. Raniere, 55 F.4th 354 (2d Cir. 2022). “18 U.S.C. § 1592 (a). 7 The racketeering act of sex trafficking of Nicole was referred to on the verdict sheet as Act 10A.”
United States v. Daron Lee Jungers, 702 F.3d 1066 (8th Cir. 2013). “§ 1588 (limiting application of a statute prohibiting the transport of slaves to the “master or owner or person having charge of any vessel”); 18 U.S.C. § 1592 (b) (excepting victims of severe forms of trafficking from a statute prohibiting certain conduct with respect to…”
United States v. Bradley, 390 F.3d 145 (1st Cir. 2004). “§ 1590 (2000); and two counts of document servitude, 18 U.S.C. § 1592 (2000). These counts dealt solely with Bradley and O’Dell’s treatment of Flynn and Hutchinson.”
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