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Bailey v. Alabama

Supreme Court of the United States · 1911 · Constitutional Law

Constitutional LawThirteenth AmendmentInvoluntary ServitudePeonageDue ProcessStatutory PresumptionsThirteenth Amendmentpeonage

Facts

Bailey entered a written contract with the Riverside Company to work as a farm hand for one year and received $15 in advance. He worked through January and part of February, then stopped working and did not refund the money. At trial, the State's proof showed only the contract, the advance, Bailey's partial performance, his later refusal or failure to continue, and his failure to refund. Under Alabama law, Bailey could not testify as to his uncommunicated intent, and the jury was instructed that refusal or failure to perform or refund without just cause was prima facie evidence of intent to injure or defraud.

Issue

May a state, consistent with the Thirteenth Amendment and the federal anti-peonage statute, make a worker's refusal or failure to perform a personal service contract or refund an advance prima facie evidence of criminal fraud, where the practical effect is to compel labor in payment of a debt? Also, is such a statutory presumption valid where it authorizes conviction on proof of breach of contract and nonpayment alone?

Rule

A legislature may prescribe evidentiary presumptions only where there is a rational connection between the fact proved and the fact presumed and the accused has a reasonable opportunity to present all facts bearing on the issue. But a state may not, directly or indirectly, compel service or labor in liquidation of a debt by criminal penalties or by a statutory presumption that turns breach of a labor contract and failure to repay an advance into sufficient evidence of crime, because that conflicts with the Thirteenth Amendment and Congress's anti-peonage legislation.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Jackson, Mississippi, Nolan Price signed a written contract to work for Delta Pine Hauling for eight months and received a $300 advance. After six weeks, he quit without a legally sufficient excuse and did not return the money. A state statute makes a worker's refusal to continue the contracted service or refund the advance prima facie evidence that he obtained the advance with intent to defraud.

If Nolan is prosecuted and the State proves only the contract, the advance, his quitting, and his nonpayment, what is the strongest constitutional objection to the statute as applied?

Explanation. The majority held that a state may not do indirectly what it cannot do directly: compel personal service in liquidation of a debt. A statute that makes quitting work and failing to repay an advance prima facie evidence of crime exposes a worker to conviction based on breach and debt alone, thereby coercing labor through fear of punishment. Voluntary entry into the contract does not cure the problem, and racial discrimination was not the basis of decision.