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U.S. v. TOVIAVE

No. 13-1441.

761 F.3d 623 (2014)

UNITED STATES of America, Plaintiff-Appellee, v. Jean Claude Kodjo TOVIAVE, Defendant-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: August 4, 2014.

Attorney(s) appearing for the Case

ARGUED: Christopher Keleher , The Keleher Appellate Law Group, Chicago, Illinois, for Appellant. Mollie E. O'Rourke , United States Attorney's Office, Detroit, Michigan, for Appellee. ON BRIEF: Christopher Keleher , The Keleher Appellate Law Group, Chicago, Illinois, for Appellant. Mollie E. O'Rourke , United States Attorney's Office, Detroit, Michigan, for Appellee.

Before: SUHRHEINRICH, ROGERS, and SUTTON, Circuit Judges.

OPINION

ROGERS, Circuit Judge.

Child abuse is a state crime, but not a federal crime. Forced labor is a federal crime, 18 U.S.C. § 1589, but the statute obviously does not extend to requiring one's children to do their homework, babysit on occasion, and do household chores. Only by bootstrapping can this combination of two actions that are not federal crimes — child abuse and requiring children to do...

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