House Cases
that peonage was comprehended within the slavery and involuntary
servitude proscribed by the Thirteenth Amendment,[6] the Court has had
frequent occasion to determine whether State legislation or the conduct
of individuals has contributed to reestablishment of that prohibited
status. Defined as a condition of enforced servitude by which the
servitor is compelled to labor in liquidation of some debt or
obligation, either real or pretended, against his will, peonage was
found to have been unconstitutionally sanctioned by an Alabama statute,
directed at defaulting sharecroppers, which imposed a criminal liability
and subjected to imprisonment farm workers or tenants who abandoned
their employment, breached their contracts, and exercised their legal
right to enter into employment of a similar nature with another person.
The clear purpose of such a statute was declared to be the coercion of
payment, by means of criminal proceedings, of a purely civil liability
arising from breach of contract.[7] Several years later, in Bailey _v._
Alabama,[8] the Court voided another Alabama statute which made the
refusal without just cause to perform the labor called for in a written
contract of employment, or to refund the money or pay for the property
advanced thereunder, _prima facie_ evidence of an intent to defraud and
punishable as a criminal offense; and which was enforced subject to a
local rule of evidence which prevented the accused, for the purpose of
rebutting the statutory presumption, from testifying as to his
"uncommunicated motives, purpose, or intention." Inasmuch as a State
"may not compel one man to labor for another in payment of a debt by
punishing him as a criminal if he does not perform the service or pay
the debt," the Court refused to permit it "to accomplish the same result
[indirectly] by creating a statutory presumption which, upon proof of no
other fact, exposes him to conviction."[9] In 1914, in United States
_v._ Reynolds,[10] a third Alabama enactment was condemned as conducive
to peonage through the permission it accorded to persons, fined upon
conviction for a misdemeanor, to confess judgment with a surety in the
amount of the fine and costs, and then to agree with said surety, in
consideration of the latter's payment of the confessed judgment, to
reimburse him by working for him upon terms approved by the court,
which, the Court pointed out, might prove more onerous than if the
convict had been