to institutional discrimination of state actors. Other cases of involuntary servitude The Supreme Court has taken an especially narrow view of involuntary servitude claims made by people not descended from black (African) slaves. In Robertson v. Baldwin (1897), a group of merchant seamen challenged federal statutes which criminalized a seaman's failure to complete their contractual term of service. The Court ruled that seamen's contracts had been considered unique from time immemorial, and that "the amendment was not intended to introduce any novel doctrine with respect to certain descriptions of service which have always been treated as exceptional." In this case, as in numerous "badges and incidents" cases, Justice Harlan authored a dissent favoring broader Thirteenth Amendment protections. In Selective Draft Law Cases, the Supreme Court ruled that the military draft was not "involuntary servitude". In United States v. Kozminski, the Supreme Court ruled that the Thirteenth Amendment did not prohibit compulsion of servitude through psychological coercion.Risa Goluboff (2001), "The 13th Amendment and the Lost Origins of Civil Rights", Duke Law Journal, Vol 50, no. 228, p. 1609 Kozminski defined involuntary servitude for purposes of criminal prosecution as "a condition of servitude in which the victim is forced to work for the defendant by the use or threat of physical restraint or physical injury or by the use or threat of coercion through law or the legal process. This definition encompasses cases in which the defendant holds the victim in servitude by placing him or her in fear of such physical restraint or injury or legal coercion." The U.S. Courts of Appeals, in Immediato v. Rye Neck School District, Herndon v. Chapel Hill, and Steirer v. Bethlehem School District, have ruled that the use of community service as a high school graduation requirement did not violate the Thirteenth Amendment. Prior proposed Thirteenth Amendments During the six decades following the 1804 ratification of the Twelfth Amendment two proposals to amend the Constitution were adopted by Congress and sent to the states for ratification. Neither has been ratified by the number of states necessary to become part of the Constitution. Each is referred to as Article Thirteen, as was the successful Thirteenth Amendment, in the joint resolution passed by Congress. The Titles of Nobility Amendment (pending before the states since May 1, 1810) would, if ratified, strip citizenship from any United States citizen who accepts a title of nobility or honor from a