Case source

Bailey v. Alabama

Bailey v. Alabama, 219 U.S. 219 (1911)

Source reviewed November 4, 2026

What the source establishes

The majority held that Alabama could not use a criminal presumption to expose a worker to conviction on evidence of only breach of a personal-service contract and failure to repay an advance, because that mechanism could compel labor for debt in violation of the Thirteenth Amendment and federal anti-peonage law. The statute originated as a law requiring fraudulent intent; the 1903 amendment, enlarged in 1907, made unjustified nonperformance or nonpayment prima facie evidence of that intent. The decision distinguishes such coercion from a voluntary agreement to repay by labor, which may be broken subject to damages, and does not treat unpaid debt or bad labor conditions alone as peonage. The Court reversed and remanded; it did not reach the Fourteenth Amendment claims.