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Bailey v. Alabama

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Bailey v. Alabama, 219 U.S. 219 (1911).

Facts: Peonage case. (Bailed out at trial for labor, bought out of that for more, etc.) An Alabama statute made criminal the breach of contract for labor if the money was paid in advance and the employee was unable to repay the advance. Breach was considered prima facie evidence of intent to defraud. Bailey was convicted under the statute. State Supreme Court held the statute sound. Bailey appeals.

Issue: Does the Alabama statute, with its presumption of intent, violate the 13th Amendment forbidding involuntary servitude?

Holding: Yes.

  • To enforce the 13th Amendment, Congress passed legislation that nullified any state law that est. or enforced service or labor in liquidation of any debt or obligation.
    • Wasn’t enforced against anyone but blacks.
  • The prohibition of involuntary servitude cannot be avoided by enforcement of contracts.
  • The statute is in conflict with the 13th Amendment and therefore unconstitutional.

Judgment: Reversed.

Dissent (Holmes & Lurton):

  • The 13th Amendment does not outlaw contracts for labor. A person who breaches a contract without excuse should have to face legal consequences.
  • State should throw its weight on the side of performance.