Santee Kimes v. United States

Santee Kimes was convicted of various counts of involuntary servitude, transportation of illegal aliens, conspiracy, aiding and abetting and escape. She now appeals the district court’s order denying her post-conviction motion to vacate that conviction under 28 U.S.C. § 2255 . Her most important contention is that, because of a change in the interpretation of 18 U.S.C. § 1584 , which prohibits holding another in involuntary servitude, the conduct for which she was convicted on the involuntary servitude counts is no longer illegal. See United States v. Kozminski, 487 U.S. 931 , 108 S.Ct. 2751 , 101 L.Ed.2d 788 (1988). She also alleges that she was denied a fair trial because of the presence on the jury of her neighbor, whom Kimes claims was biased. In this connection she further asserts that her attorney’s failure to object to the service of this juror rendered his assistance ineffective. We affirm.

Involuntary Servitude

At Kimes’ trial, the government presented evidence that Kimes and her husband recruited young, female illegal aliens from Mexico to work for them as maids. The evidence showed that Kimes isolated these women, allowing them no contact with their families, no use…