Bailey v. State of Alabama
United States Supreme Court
219 U.S. 219 (1911)
Bailey (defendant) signed a year-long farm-labor contract with Riverside Company for $12 a month and took a $15 cash advance, but quit after about a month without repaying the advance. He was criminally charged under an Alabama statute that treated a worker's unexcused refusal to perform the contracted service or refund the money as prima facie evidence of intent to defraud the employer. Convicted at trial and fined (with hard labor as the alternative if he could not pay), Bailey appealed, and the Alabama Supreme Court affirmed; the U.S. Supreme Court granted certiorari.
Whether a state statute that criminally punishes a worker's mere failure or refusal to perform a labor contract or repay an advance, by treating that failure as presumptive evidence of fraud, violates the Thirteenth Amendment's prohibition on involuntary servitude.