Bailey v. State of Alabama

Brief Fact Summary.

Defendant entered into a contract with a company, in which Defendant agreed to do labor in exchange for money for a year. The company gave Defendant money for consideration. After one month, Defendant refused to continue working and refused to return the money. Defendant was charged with a crime, was found guilty, and was compelled to do labor in the event he cannot pay the damages and fine.

Synopsis of Rule of Law.

A state statute that compels a person to do labor for another person in payment of a debt and that punishes that person as a criminal if he does not comply violates the Thirteenth Amendment.

Facts.

Bailey (Defendant) and Riverside Company (Riverside) entered into a contract in which Defendant agreed to work for $12/month for one year as a farm hand. As consideration for the agreement, Defendant was given $15 in cash. After one month of working, Defendant refused to continue working and refused to return the cash to Riverside. Afterwards, Defendant was charged with a crime. At trial, the court told the jury the following: “[T]he refusal of any person who enters into such contract to perform such act or service, or refund such money, or pay for such property, without just cause, shall be prima facie evidence of the intent to injure his employer, or to defraud him.” As such, Defendant requested a different jury instruction, which was refused by the court. Defendant was found guilty for damages of $15 and a fine of $30. In addition, if Defendant refused to pay or was unable to pay the fine, the court held that Defendant would be sentenced to 20 days of hard labor. Defendant appealed to the Alabama Supreme Court, which affirmed the conviction. The United States Supreme Court granted certiorari.

Issue.

Is the Thirteenth Amendment violated by a state statute that compels a person to do labor for another in payment of a debt and punishes him as a criminal if he does not comply?

Held.

Yes. The Thirteenth Amendment prohibits involuntary servitude by compelling personal hard labor to pay off a debt. Defendant argues that the Alabama statute used to convict him violates the Thirteenth Amendment. Defendant further argues that the Alabama statute violates the Fourteenth Amendment for depriving him of his liberty without due process of law. Since the U.S. Supreme Court found that the Alabama statute violates the Thirteenth Amendment, the Court did not address the Fourteenth Amendment issue. The Court reversed the judgment of the Alabama Supreme Court.

Dissent.

Defendant breached his contract with Riverside. Breaching a contract without an excuse is considered wrongful conduct, even if that contract is for labor and even if a state decides to add a criminal fine to civil liability. If a criminal fine may be imposed on a person, then imprisonment should be imposed in the event that the person fails to pay it. Since Defendant falsely represented that he would perform the obligations under the contract, such an act should be punished like any other crime. The Thirteenth Amendment is not violated, as it does not prohibit contracts for labor

Discussion.

According to the Thirteenth Amendment, “neither slavery nor involuntary servitude, except as a punishment for a crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.” Alabama’s state law subjects a person to criminal punishment if he simply fails or refuses to work. A state law may not compel a person to do labor for another in payment of a debt and punish him as a criminal if he does not comply. Alabama is not allowed to create a statutory presumption in which proof of no other fact causes him to be convicted and punished. Therefore, the Alabama statute violates the Thirteenth Amendment.