2nd instance:

In 2005, a federal grand jury indicted Joseph Djoumessi for holding F in involuntary servitude, conspiring to hold F in involuntary servitude, and harboring an alien for private financial gain. The bench trial resulted in a verdict of guilty on all three counts, and a sentence of 204 months’ imprisonment (to run concurrently with his state sentence) and $100,000 in restitution to F.

3rd instance:

Joseph appealed his federal convictions arguing (1)  they  violated the Double Jeopardy Clause of the U.S. Constitution and (2) specifically argued the involuntary servitude conviction was not supported by sufficient evidence.

Djoumessi argued that his state prosecution, where he was acquitted of charges similar to involuntary servitude, precluded his federal convictions. Generally, the Double Jeopardy Clause does not bar different sovereigns (here, Michigan State and the U.S. Federal Government) from prosecuting the same individual for similar conduct. However, an exception exists when the second prosecution is really a sham-prosecution, a “different” sovereign in name only.  This exception is described in a case called Bartkus v. Illinois, 359 U.S. 121, 122–24 (1959).

The appellate court found that federal charges against him, although similar to the state charges he was acquitted of, did not constitute double-jeopardy.  First, the Court noted the Bartkus exception has not been discussed much since and questioned whether it was real. Assuming it was, the Court found that Djoumessi failed to establish the Bartkus sham-prosecution exception applied in his case. For the Bartkus exception to apply, the federal prosecutors had to be “merely a tool” of the State. To the Court, this is a “startling showing” that Djoumessi did not make.

For the second appeal regarding involuntary-servitude, the Court upheld the conviction. The evidence for involuntary-servitude was sufficient for any rational trier of fact to find him guilty of all elements of the crime.  To prove sufficiency of the evidence, the evidentiary standard is whether any rational trier of fact, viewing the evidence in a light most favourable to the prosecution, could have found the essential elements of the crime beyond a reasonable doubt.

Involuntary servitude requires proof that a defendant  held the victim in service against her will: (1) by physical restraint or force, (2) by legal coercion or (3) by threats of physical force or legal coercion.  The trier of fact may consider “the vulnerabilities of the victim” as well as “evidence of other means of coercion or of extremely poor working conditions” when considering the victim’s perspective.  The Court considered special vulnerabilities to be the F’s young age, illegal status, lack of financial support or contact with anyone other than the defendants. These vulnerabilities made F more prone to believing the defendants’ threats of deportation that perhaps adults of normal intelligence may not have. Believing these threats, F stayed under this coercion. Viewing the evidence in a light most favourable to the prosecution, the Court believed a rational trier of fact could have convicted based on the evidence available at the trial-level.

Subsequent federal appeals to vacate the sentence were denied in 2010.  US Supreme Court denied certiorari (hearing the case) in 2009.