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Keywords

contractlawsuitplaintiffliabilitystatuteclass action
contractstatutestatutory interpretationappelleeliens

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Barrientos v. CoreCivic, Inc.

Facts

The case involved a class action lawsuit brought by alien detainees against CoreCivic, a private contractor operating the Stewart Detention Center in Georgia. The plaintiffs alleged that CoreCivic's 'voluntary work program' was coercive, as detainees were threatened with serious harm, including solitary confinement and deprivation of basic necessities, if they did not participate. The complaint asserted that CoreCivic's actions violated the forced-labor prohibition in the TVPA.

Appellees' complaint alleged that, far from operating a 'voluntary' work program, CoreCivic coerces alien detainees to perform labor at Stewart by, inter alia, the use or threatened use of serious harm, criminal prosecution, solitary confinement, and the withholding of basic necessities.

Issue

Whether the Trafficking Victims Protection Act (TVPA) applies to work programs in federal immigration detention facilities operated by private for-profit contractors.

the narrow, purely legal question of '[w]hether the TVPA applies to work programs in federal immigration detention facilities operated by private for-profit contractors.'

Rule

The TVPA prohibits knowingly obtaining the labor or services of a person through illegal coercive means, including threats of serious harm or physical restraint.

The TVPA prohibits knowingly 'obtain[ing] the labor or services of a person' by any one of, or combination of, the following means: (1) by means of force, threats of force, physical restraint, or threats of physical restraint to that person or another person; (2) by means of serious harm or threats of serious harm to that person or another person; (3) by means of the abuse or threatened abuse of law or legal process; or (4) by means of any scheme, plan, or pattern intended to cause the person to believe that, if that person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint. 18 U.S.C. 1589(a) (collectively, the 'illegal coercive means').

Analysis

The court analyzed the plain language of the TVPA and determined that it applies to private contractors like CoreCivic. The court found that the statute does not exempt federal contractors from liability under the TVPA, even in the context of federally mandated work programs. The court emphasized that if CoreCivic coerced detainees to work through illegal means, it would be in violation of the TVPA.

The question of statutory interpretation is a legal issue we review de novo. 'The interpretation of a statute begins with its language.' United States v. St. Amour, 886 F.3d 1009, 1013 (11th Cir.) , cert. denied , 139 S. Ct. 205, 202 L. Ed. 2d 141 (2018); see also Artis v. District of Columbia, 583 U.S. , , 138 S. Ct. 594, 603, 199 L. Ed. 2d 473 (2018) ('In determining the meaning of a statutory provision, we look first to its language, giving the words used their ordinary meaning.' (quotation marks omitted)).

Conclusion

The Eleventh Circuit affirmed the district court's decision, concluding that the TVPA applies to CoreCivic's operations and that the plaintiffs' allegations warranted further proceedings.

After review, and with the benefit of oral argument, we conclude that: (1) under the plain language of the statute, the TVPA covers the conduct of private contractors operating federal immigration detention facilities; (2) the TVPA does not bar private contractors from operating the sort of voluntary work programs generally authorized under federal law for aliens held in immigration detention facilities; but (3) private contractors that operate such work programs are not categorically excluded from the TVPA and may be liable if they knowingly obtain or procure the labor or services of a program participant through the illegal coercive means explicitly listed in the TVPA.

Who won?

The plaintiffs prevailed in the case as the court affirmed the applicability of the TVPA to CoreCivic's actions, allowing their claims to proceed.

The district court disagreed, finding 'the plain language of the statute' clearly encompassed claims brought by alien detainees held in privately run detention facilities.

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