Bailey v. Alabama 219 U.S. 219 (1911)
BAILEY v. ALABAMA 219 U.S. 219 (1911)
After the demise of the black codes some southern states resorted to other devices to insure a steady supply of labor. One Alabama statute effectively converted civil breach of contract into the crime of fraud by making it prima facieevidence of intent to defraud that a worker accept an advance on wages and then neither repay the advance nor perform the work contracted for.
In Bailey the Supreme Court held (7–2) that the Alabama law constituted a system of peonage in violation of the thirteenth amendment's prohibition of involuntary servitude. Justice charles evans hughes, for the majority, argued that involuntary servitude was a broader concept than slavery and included schemes for enforced labor.
Justice oliver wendell holmes, dissenting, argued that Alabama was acting within its power to define crimes and their punishments.
Dennis J. Mahoney
(1986)