the Thirteenth Amendment.[14]

(2) "Services which have from time immemorial been treated as
exceptional." Thus, contracts of seamen, which have from earliest
historical times been treated as exceptional, and involving, to a
certain extent, the surrender of personal liberty may be enforced
without regard to the amendment.[15]

(3) "Enforcement of those duties which individuals owe the State, such
as services in the army, militia, on the jury, etc." Thus, "a State has
inherent power to require every able-bodied man within its jurisdiction
to labor for a reasonable time on public roads near his residence
without direct compensation."[16] Similarly, the exaction by Congress of
enforced military duty from citizens of the United States, as was done
by the Selective Service Act of May 18, 1917 (40 Stat. 76); and the
requirement, under the Selective Training and Service Act of 1940 (50
U.S.C.A. App. Sec. 305 (g)), that conscientious objectors be assigned to
work of national importance under civilian direction, were held not to
contravene the Thirteenth Amendment.[17]

(4) A State law which made it a misdemeanor for a lessor, or his agent
or janitor, intentionally to fail to furnish such water, heat, light,
elevator, telephone, or other service as may be required by the terms of
the lease and necessary to the proper and customary use of the building,
did not create an involuntary servitude.[18]

(5) Section 506 (a) of the Communications Act (47 U.S.C.A. Sec. 506) making
it unlawful to coerce, compel, or constrain a licensee to employ persons
in excess of the number of the employees needed by the licensee in the
conduct of a radio broadcasting business, on its face, was construed as
not violating this amendment.[19]

Enforcement

"* * * this amendment, besides abolishing forever slavery and
involuntary servitude * * *, gives power to Congress to protect all
persons within the jurisdiction of the United States from being in any
way subject to slavery or involuntary servitude, except as a punishment
for crime, and in the enjoyment of that freedom which it was the object
of the amendment to secure. * * *"[20] It "is undoubtedly
self-executing without any ancillary legislation, * * * [but]
legislation may be necessary and proper to meet all the various * * *
circumstances to be affected by it, and to prescribe proper modes of
redress for its violation in letter or spirit." This legislation,
moreover, "may be direct and prim