Dennis Warren provided migrant farm workers for the farm of Cecil Williams in Nash County, North Carolina, during the summer of 1981, and also supervised the workers. Dennis assisted in running the crew with his brother, Richard Warren, John Harris, and Halsey Norwood. Many of the workers were recruited by methods ranging from deception to kidnapping. The workers were charged for their consumption in the camp where they lived, and the costs were deducted from their wages. The workers were guarded at night, and anyone who tried to flee would be picked up and returned by Harris or others. Both physical and threatened violence were used to prevent workers from leaving, and to force them to work faster. Workers who complained of illness or injuries were denied medical assistance.
On September 13, 1981, R.A., a migrant worker from Philadelphia, died on a bus he had been placed in after collapsing in the fields. Two autopsies established that the primary cause of death was heat stroke. His death and reports of civil rights violations at the farm precipitated an investigation of the camp by the FBI.
The court of 1st instance was the U.S. District Court for the Eastern District of North Carolina. All 3 defendants appealed their convictions with the exceptions noted below.
Harris appealed his conviction except for kidnapping J.S., and the holding of H.R. in involuntary servitude.
Dennis Warren appealed his conviction except for holding C.C. in involuntary servitude.
The appeal challenged the sufficiency of the evidence supporting the conviction for holding laborer H.R. in involuntary servitude. The court held that the evidence was sufficient to support his conviction (e.g. Dennis Warren told H.R. that if he left, he would hurt him; H.R. heard him threatening to shoot C.C.; H.R. had seen him with a gun).
Only Harris has appealed his conviction for holding C.C. in involuntary servitude. The court held that sufficient evidence was supplied to convict Harris of the charge. Harris physically beat other workers, contributed to the reign of physical terror, and stood guard at night in order to prevent laborers from leaving. The court held that these actions sufficed to convict Harris as an accomplice.
The court affirmed all of the substantive convictions, however, it reversed Richard Warren’s judgment of acquittal on the conspiracy count.
The jury found Dennis Warren and Harris guilty of conspiracy in which a death resulted, while acquitting Richard Warren of that charge and convicting him of the lesser included offense of conspiracy. The district court upheld the convictions of Dennis Warren and Harris, but entered a judgment of acquittal as to Richard Warren on the conspiracy charge. It concluded that the verdicts were logically inconsistent, either the conspiracy resulted in R.A.’s death, or it did not. The court of appeals argued that convicting Richard Warren of the lesser offense was permissible, as the jury was exercising leniency to avoid the legal rule that co-conspirators are equally responsible and equally punishable for the acts of their partners. Therefore, the Court of Appeal reversed Richard Warren’s judgment of acquittal on the conspiracy count, and reinstated the judgment of conviction and the sentence imposed thereon.
Richard Warren challenged the sufficiency of the evidence supporting his conviction for holding laborer H.R. in involuntary servitude. The evidence showed that he fraudulently induced H.R. to go to the labor camp, H.R. knew that he was not free to leave, and that Richard Warren agreed with Dennis Warren when he was threatening H.R. to assault him. Therefore, the court concluded that the evidence was sufficient.
United States Court of Appeals for the Fourth Circuit
http://www.law.umich.edu/clinical/HuTrafficCases/Pages/searchdatabase.aspx
LexisNexis No. 82-5049; 82-5052; 82-5157; 82-5181; 81-11-CR-8
The verdict was issued in 1982.