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er and were written by Justice White and Justice Holmes. Several conclusions of importance may be drawn from the court's decision. 1. That Congress may forbid transactions of purchase and sale when such transactions confer on an individual or group of individuals the power to destroy competition. 2. No State can create corporations and confer upon them power to interfere with interstate commerce. 3. The Sherman law is not to be interpreted as forbidding the reasonable restraints of trade which are not objectionable at common law. The Bailey case is one of importance by reason of the fact that the decision handed down by the Supreme Court was an effective blow against the "peonage system," which is an evasion of the constitutional prohibition of slavery. The Alabama law provides, in effect, that the mere act of quitting work on the part of a contract laborer is conclusive evidence that he is guilty of the crime of defrauding his employer. Alonzo Bailey was engaged by a corporation to do farm work and signed a contract for a year, the wages being $12 a month. The company, to bind the contract, paid Bailey $15 down and it was agreed that thereafter he should be paid at the rate of $10.75 a month. After working a month and a few days he left. Instead of suing him for a breach of contract and recovery of damages, the company caused the arrest of Bailey on the charge of an attempt to defraud. No direct evidence could be produced that this was his intention, but the law expressly authorized the jury to find him guilty of fraud, on the ground that he quitted work. The accused was not allowed to testify as to his unexpressed intention. His opportunity to escape prison was to pay back the $15 or to work out the sum. In case neither was done, he was to be fined double the amount paid at the time of making the contract or go to work at hard labor. The attorneys for Bailey, wishing to test the constitutionality of the Alabama law, carried the case to the Supreme Court of the United States. The constitutionality of the law was called into question on the following grounds: (1) That it violated the prohibition against involuntary service; (2) it denied the plaintiff in error the right of due process of law; (3) that by laying a burden on the employee and no equivalent burden on the employer, the law denied to the plaintiff the constitutional right of equal protection of the laws. The decision of the court was not una
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