Ruderman v. Kenosha County, Wisconsin

Federal 7th Circuit Court
Civil Court
Civil Detainees
Citation
Case Number: 
No. 24-2939
Decision Date: 
June 5, 2026
Federal District: 
E.D. Wis.
Holding: 
Vacated and remanded.
Judge: 
EASTERBROOK

A group of civil detainees held in a county jail on behalf of federal agencies filed a lawsuit under 18 U.S.C. ยง 1589 for civil damages alleging that they were unlawfully required to perform unpaid custodial work and if they did not, they were subject to disciplinary measures. The district court dismissed the lawsuit by finding that the statute only applies to cases involving human trafficking. The Seventh Circuit vacated and remanded, finding that the language of the statute did not limit it solely to human trafficking and that nothing in the text of the law permits a local jail to compel civil detainees to work on pain of solitary confinement or loss of phone contact with the outside world and that the complaint alleged threats that could not be dismissed as too slight to activate the statute. (BRENNAN and SYKES, concurring)