United States v. Supawan Veerapol

On August 12, 1999, Supawan Veerapol was convicted by a jury of one count of holding another to involuntary servitude in violation of 18 U.S.C. § 1584 , three counts of mail fraud in violation of 18 U.S.C. § 1341 , and three counts of harboring aliens in violation of 8 U.S.C. § 1324 (a)(1)(A)(iii). Veerapol challenges for the first time the sufficiency of the evidence supporting her conviction on the count of involuntary servitude. She also appeals the district court’s application of the vulnerable victim enhancement, U.S.S.G. § 3A1.1 (b)(1), to adjust her base offense level upward by two levels, contending that the vulnerability of the victim was taken into account in the offense of conviction. She further challenges the district court’s order of restitution to the victim held to involuntary servitude. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm the conviction, sentence, and order of restitution.

I. Background

Veerapol, a native of Thailand and the common-law wife of a Thai ambassador, operated a Thai restaurant in Los Angeles for which she recruited Thai nationals as workers. While in Thailand in the summer of 1989, Veerapol approached Nobi…