A defendant who overdosed on Valium during jury deliberations at his trial on forced labor and immigration charges intentionally absented himself from court and waived his right to be present, the U.S. Court of Appeals for the Second Circuit said Thursday.

Joseph Yannai, an author, had tried to kill himself once before—the day the FBI came to arrest him for inducing young women from overseas to travel to his Westchester County home for work as part of a labor trafficking scheme that included allegations of sexual abuse.