Bailey v. Alabama

E934443

Bailey v. Alabama is a 1911 U.S. Supreme Court decision that struck down a state law effectively criminalizing breach of labor contracts, holding that it violated the Thirteenth Amendment’s prohibition of involuntary servitude.

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All labels observed (1)

Label Occurrences
Bailey v. Alabama canonical 1

Statements (40)

Predicate Object
instanceOf Thirteenth Amendment case
U.S. constitutional law case
United States Supreme Court case
areaOfLaw civil rights law
criminal law
labor law
citation 219 U.S. 219
constitutionalProvisionInterpreted Anti-Peonage Act NERFINISHED
Thirteenth Amendment to the United States Constitution NERFINISHED
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1911
effect restricted states’ ability to use criminal law to coerce labor performance
finding criminal penalties attached to labor contract breach could amount to involuntary servitude
presumption of fraudulent intent from mere nonperformance of labor contract was unconstitutional when used to compel labor
fullCaseName Bailey v. State of Alabama NERFINISHED
historicalContext post-Reconstruction regulation of Black labor in the American South
holding Alabama statute criminalizing breach of certain labor contracts violated the Thirteenth Amendment
State may not use criminal law to enforce labor contracts in a way that compels involuntary servitude
jurisdiction State of Alabama NERFINISHED
United States of America
surface form: United States
languageOfProceedings English
legalIssue constitutionality of criminal penalties for breach of labor contracts
involuntary servitude under the Thirteenth Amendment
peonage
majorityOpinionBy Charles Evans Hughes NERFINISHED
party Alonzo Bailey NERFINISHED
State of Alabama NERFINISHED
precedentFor interpretation of involuntary servitude beyond chattel slavery
limits on criminal sanctions for breach of employment contracts
recognizedAs landmark Thirteenth Amendment decision
relatedConcept debt peonage
forced labor
post–Civil War labor control statutes
result Alabama conviction reversed
stateLawInvolved Alabama statute making failure to perform labor contract prima facie evidence of intent to defraud
subsequentCitationIn later Thirteenth Amendment and peonage cases
timePeriod Progressive Era NERFINISHED
typeOfRemedyLimited criminal enforcement of private labor contracts GENERATED
vote 7–2

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