Bailey v. Alabama
Case Date: 05/19/2024
|
Bailey v. Alabama, 219 U.S. 219 (1911), was a United States Supreme Court case which overturned the peonage laws of Alabama.[1]
The Supreme Court considered the validity of the Alabama state court’s ruling that Alabama statute (§ 4730 of the Code of Alabama of 1896, as amended in 1903 and 1907) was constitutional. The law read:[2]
"Any person who, with intent to injure or defraud his employer, enters into a contract in writing for the performance of any act of service, and thereby obtains money or other personal property from such employer, and with like intent, and without just cause, and without refunding such money, or paying for such property, refuses or fails to perform such act or service, must on conviction be punished. . . “[3]
Alonzo Bailey was an African American from Alabama who agreed to work for The Riverside Company for one year at $12 per month. He received an advance of $15. After working for a little over a month he stopped work, but did not refund any money. According to Alabama law such refusal to work and refund the money was prima facie evidence of intent to defraud. The evidence presented against Bailey at trial was testimony that he stopped working, without cause, failed to repay the $15 advanced to him and that he was a Negro.
The United States Supreme Court found that holding a person criminally liable for taking money for work not performed was akin to indentured servitude, outlawed by the Thirteenth Amendment, insofar as it required that person to work rather than be found guilty of a crime.
|