In the United States v. Kozminski et al., 1987, the U.S Supreme Court ruled on a case involving involuntary servitude. The defendants, Ike and Margarethe Kozminski, were accused of holding two mentally disabled men in slavery-like conditions on their Michigan farm for more than a decade. They were charged under federal law prohibiting involuntary servitude but argued that they had not physically or legally coerced the men into service; rather, they exploited their mental disabilities to make them believe they had no alternative but to work on the farm. The Supreme Court held that such psychological coercion did not constitute "involuntary servitude" as defined by federal law. It stated that this term referred only to situations where an individual is compelled to work through physical force or legal threat (such as deportation). Therefore, it overturned lower court decisions convicting the Kozminskis and remanded for further proceedings consistent with its interpretation of what constitutes "involuntary servitude". This decision narrowed down interpretations of labor exploitation under U.S laws.

In the dissenting opinion for United States v. Kozminski et al., Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's interpretation of involuntary servitude was too narrow. They contended that it should not be limited to situations where physical force or legal coercion is used but should also include more subtle forms of psychological manipulation. The dissenters believed this broader definition better aligned with Congress' intent when they passed the 13th Amendment and subsequent legislation aimed at eradicating all vestiges of slavery. In their view, limiting involuntary servitude to cases involving overt threats or acts of physical violence would leave many victims without any legal recourse and fail to address modern-day forms of exploitation akin to slavery.