BAILEY v. ALABAMA
Bailey contracted to work on a farm for a year at $12 a month. He quit after a month and did not return $15 advanced to him. Under Alabama law, Bailey's act was criminal. He was convicted and sentenced to 136 days of hard labor under the Alabama peonage law.
Did the Alabama law violate the Thirteenth Amendment?
The Court, through Hughes, argued that the law was a restriction on personal rights. Judged by its effect and not by its pretense, the law violated the Thirteenth Amendment. Involuntary servitude meant more than slavery.