Tegete v. Maryknoll Sisters of Saint Dominic, Inc.

Background

Immaculata Tegete joined the Maryknoll Sisters after previously belonging to another Catholic religious order and working in Tanzania. Maryknoll helped her obtain a temporary religious-worker visa, and she traveled to New York in 2010. She later participated in Maryknoll’s formation program in Chicago, made temporary religious vows, and was assigned to a mission in Panama.

Tegete contended that Maryknoll promised her theological education and missionary work but instead required her to perform household, eldercare, farm, cooking, cleaning, and other manual labor. She also alleged that Maryknoll used threats of deportation and financial hardship to obtain her labor and retained her passport to restrict her movement. The opinion states, however, that Tegete had access to her passport when she requested it, sometimes retained it, traveled domestically and internationally, communicated with family and friends, and was not physically threatened or restrained. After Tegete decided not to return to Panama, Maryknoll released her from her vows and provided a plane ticket to Tanzania and money.

Tegete sued under the Trafficking Victims Protection Reauthorization Act, asserting claims for forced labor under 18 U.S.C. § 1589, enticement into slavery under § 1583, and document servitude under § 1592. Maryknoll moved for summary judgment, which asks whether the evidence requires judgment for one party without a trial because no reasonable jury could find for the other party.

Forced-Labor Claim

The court granted summary judgment to Maryknoll on the forced-labor claim. Under § 1589, labor must be obtained through specified forms of coercion, including force, physical restraint, serious harm or threats of serious harm, abuse of legal process, or a scheme intended to make the person believe that failing to work would cause serious harm. The court explained that the plaintiff also had to show that Maryknoll intended to make her believe she would suffer serious harm if she stopped working.

The court held that Tegete’s evidence did not meet that standard. It found no evidence of physical force, physical restraint, physical threats, extreme isolation, or an inability to leave. Tegete’s access to phones, the internet, family, friends, travel, and her passport undermined the claim that she was psychologically imprisoned. The court also held that the language in the sponsorship agreement describing immigration consequences was an accurate statement of federal visa rules, not an actionable threat of legal process. Finally, the court found that Tegete’s assertions about financial ruin were conclusory and speculative and were not supported by evidence that Maryknoll intended to cause her to fear such harm. The court concluded that no reasonable jury could find that Maryknoll obtained Tegete’s labor through the serious harm or coercion required by § 1589.

Enticement-Into-Slavery Claim

The court dismissed Tegete’s claim under § 1583. The court stated that a reasonable juror could potentially find that promises of theological education and missionary work helped entice her to travel to the United States and join Maryknoll. But enticement alone was not enough. Tegete also had to show that Maryknoll acted with the intent that she be held as a slave.

The court held that the record did not support that required intent. Tegete alleged no physical harm or threats intended to deprive her of freedom, and her testimony showed that she could communicate and travel freely. The court also held that the alleged deportation threat was not actionable and, standing alone, would not establish the slavery-like coercion required by the statute. Because Tegete knew she could leave and ultimately did leave Maryknoll, the court concluded that her claim failed as a matter of law.

Document-Servitude Claim

The court dismissed Tegete’s document-servitude claim as abandoned because she did not respond to or mention that claim in her opposition to summary judgment. The court added that the claim would also fail on the merits because Tegete had regular access to her passport, sometimes possessed it, and used it to travel. The court further stated that a document-servitude claim requires a related violation or intended violation of the forced-labor provisions, which the court had found unsupported.

Other Defense and Disposition

Maryknoll also argued that the religious-organization defense known as the ministerial exception barred Tegete’s claims. Because the court concluded that all of the claims failed on other grounds, it did not decide that argument.

Judge Cathy Seibel granted Maryknoll’s motion for summary judgment, directed the Clerk to enter judgment for Maryknoll, and closed the case.