Bailey v. State of Alabama
Author: Livia Lin

Parties:

Plaintiff: Bailey

Defendant: State of Alabama

Facts:

Plaintiff contracted The Riverside Co. (Riverside in brief) to be farm hand from Dec. 30, 1907 to Dec. 30, 1908 for the sum of $12.00 per month. Riverside paid $15 as a consideration. Bailey ceased the work without just cause after working through January and three or four days of February and refused to refund the money. The Montgomery City Court found the accused guilty under the statute, fixed the damages sustained by Riverside at $15 and assessed a fine of $30. The Supreme Court confirmed the judgment. Bailey sued.

Issue:

Whether a statute of punishing a person, as conviction for crime, who fails or refuses to perform contracts for personal service in liquidation of a debt, is constitutional?

Reasoning:

The Thirteenth Amendment absolutely declares that slavery and involuntary servitude shall not exist in any part of the United States, which includes peonage, the voluntary or involuntary service or labor in liquidation of any debt or obligation.

The Thirteenth Amendment prohibits involuntary servitude except as punishment for crime, however, it does not mean to punish a person as a crime if he does not perform the service or pay the debt.

Holding:

The court made a decision in favor of the plaintiff. The judgment was reversed and cause remanded.