Appellant
Emanuel Pollock
Appellee
H. T. Williams
Appellant's Claim
That a Florida law regarding the failure to perform labor after receiving anadvance was unconstitutional, under the Thirteenth Amendment.
Chief Lawyer for Appellant
Raymer R. Maguire
Chief Lawyer for Appellee
John C. Wynn
Justices for the Court
Hugo Lafayette Black, William O. Douglas, Felix Frankfurter, Robert H. Jackson (writing for the Court), Frank Murphy, Owen Josephus Roberts, Wiley BlountRutledge
Justices Dissenting
Stanley Forman Reed, Harlan Fiske Stone
Place
Washington, D.C.
Date of Decision
10 April 1944
Decision
Upheld appellant's claim.
Significance
The Court, drawing on its reasoning in previous "peonage" cases, ruled that the Florida law had a coercive effect. Under the law, a person who failed to honor a work contract could be arrested for fraud, even if the accused had nointent to commit fraud. The ruling offered further legal protection to rural,southern African Americans, who were the target of the peonage laws.
The Thirteenth Amendment officially abolished slavery and any form of involuntary servitude. The amendment also gave Congress the power to enact laws to enforce those provisions. To address involuntary servitude, Congress passed the Peonage Abolition Act of 1867. Congress defined peonage as forcing someoneto work in order to extract payments for a debt. In the twentieth century, the Supreme Court heard a number of cases, all originating in the South, that defined peonage more broadly, and struck at the heart of any system of forcedlabor (other than in prisons).
After Reconstruction, many southern states tried to limit employment opportunities for African Americans. Without special licenses, African Americans wereoften limited to farm work, and to get those jobs they had to sign labor contracts. Some laws made it a crime for workers to break their contracts, or forced them to pay off debts to their employers by working off what they owed.In Bailey v. Alabama (1911), the Court said states could not make it acrime for a worker to break a labor contract. At that time, Florida had a similar statute, and it passed a revised version in 1919.
The Florida law said contract workers who received money from an employer andthen did not honor their contract were committing fraud and would be chargedwith a misdemeanor. If someone arrested under the law refused to pay back the money or honor the contract, that was prima facie, or implied, proofof fraudulent intent. Since African Americans and migrant workers were typically forced to sign labor contracts and often received advances on their wages, the law was implicitly directed at them.
Emanuel Pollock's $5 Debt
In October of 1942, Emanuel Pollock, a resident of Brevard County, Florida, agreed to work for J. V. O'Albora. Pollock, an illiterate African American laborer, received a $5 advance from O'Albora. Three months later, Pollock was charged and convicted for breaking the 1919 Florida statute. Pollock did not have a lawyer during the trial and said he did not understand the charges against him; nevertheless, he pleaded guilty, admitting he had quit his job without repaying the $5 and had no money to pay it back. The trial judge ordered Pollock to serve 60 days in jail, since he could not pay a $100 fine. Pollock was placed in the custody of H. T. Williams, sheriff of Brevard County.
On 11 January 1943, the county circuit court ordered Williams to release Pollock, ruling that the Florida statute was unconstitutional. The state supremecourt, however, reversed the lower court's order, and Pollock v. Williams went to the Supreme Court.
On a 7-2 vote, the Court struck down the Florida law, saying that the FloridaSupreme Court had misread the precedents on the matter. In his opinion, Justice Jackson traced the history of federal attempts to end peonage, starting with the Thirteenth Amendment. He also pointed out the attempt by various states to circumvent the intent of the Antipeonage Act. "The present Act," he wrote, "is the latest of a lineage, in which its antecedents were obviously associated with the practice of peonage."
A key point in the Florida Supreme Court's decision had been the prime facie section of the 1919 law. The court ruled that since Pollock pleaded guilty, the implied guilt defined by that part of the statute was not relevant.Jackson, however, disagreed. According to the facts of the case, Jackson said, "the crime cannot be gleaned from the record." The law, under its primafacie provision, "purported to supply the element of intent." By pleading guilty, Pollock only went along with what the law already seemed to dictate. The presumption of Pollock's intent to defraud was written in the law, andthis presumption "had a coercive effect in producing the plea of guilty."
Jackson seemed to show some impatience with the Florida legislature's use ofthe prima facie tacit as a way to pin criminal guilt on someone who broke a labor contract:
Chief Justice Stone and Justice Reed dissented. Reed, in his dissent, arguedthat the Court had placed too much emphasis on the prima facie portionof the law, using its supposed unconstitutionality to strike down the entirelaw. Reed wrote that the first part of the law was valid: states have a right to criminally punish fraud in a labor contract, just as they might with other types of fraud. The Court however, has not wavered since Pollock from its attacks on any form of peonage.
Related Cases
Emanuel Pollock
Appellee
H. T. Williams
Appellant's Claim
That a Florida law regarding the failure to perform labor after receiving anadvance was unconstitutional, under the Thirteenth Amendment.
Chief Lawyer for Appellant
Raymer R. Maguire
Chief Lawyer for Appellee
John C. Wynn
Justices for the Court
Hugo Lafayette Black, William O. Douglas, Felix Frankfurter, Robert H. Jackson (writing for the Court), Frank Murphy, Owen Josephus Roberts, Wiley BlountRutledge
Justices Dissenting
Stanley Forman Reed, Harlan Fiske Stone
Place
Washington, D.C.
Date of Decision
10 April 1944
Decision
Upheld appellant's claim.
Significance
The Court, drawing on its reasoning in previous "peonage" cases, ruled that the Florida law had a coercive effect. Under the law, a person who failed to honor a work contract could be arrested for fraud, even if the accused had nointent to commit fraud. The ruling offered further legal protection to rural,southern African Americans, who were the target of the peonage laws.
The Thirteenth Amendment officially abolished slavery and any form of involuntary servitude. The amendment also gave Congress the power to enact laws to enforce those provisions. To address involuntary servitude, Congress passed the Peonage Abolition Act of 1867. Congress defined peonage as forcing someoneto work in order to extract payments for a debt. In the twentieth century, the Supreme Court heard a number of cases, all originating in the South, that defined peonage more broadly, and struck at the heart of any system of forcedlabor (other than in prisons).
After Reconstruction, many southern states tried to limit employment opportunities for African Americans. Without special licenses, African Americans wereoften limited to farm work, and to get those jobs they had to sign labor contracts. Some laws made it a crime for workers to break their contracts, or forced them to pay off debts to their employers by working off what they owed.In Bailey v. Alabama (1911), the Court said states could not make it acrime for a worker to break a labor contract. At that time, Florida had a similar statute, and it passed a revised version in 1919.
The Florida law said contract workers who received money from an employer andthen did not honor their contract were committing fraud and would be chargedwith a misdemeanor. If someone arrested under the law refused to pay back the money or honor the contract, that was prima facie, or implied, proofof fraudulent intent. Since African Americans and migrant workers were typically forced to sign labor contracts and often received advances on their wages, the law was implicitly directed at them.
Emanuel Pollock's $5 Debt
In October of 1942, Emanuel Pollock, a resident of Brevard County, Florida, agreed to work for J. V. O'Albora. Pollock, an illiterate African American laborer, received a $5 advance from O'Albora. Three months later, Pollock was charged and convicted for breaking the 1919 Florida statute. Pollock did not have a lawyer during the trial and said he did not understand the charges against him; nevertheless, he pleaded guilty, admitting he had quit his job without repaying the $5 and had no money to pay it back. The trial judge ordered Pollock to serve 60 days in jail, since he could not pay a $100 fine. Pollock was placed in the custody of H. T. Williams, sheriff of Brevard County.
On 11 January 1943, the county circuit court ordered Williams to release Pollock, ruling that the Florida statute was unconstitutional. The state supremecourt, however, reversed the lower court's order, and Pollock v. Williams went to the Supreme Court.
On a 7-2 vote, the Court struck down the Florida law, saying that the FloridaSupreme Court had misread the precedents on the matter. In his opinion, Justice Jackson traced the history of federal attempts to end peonage, starting with the Thirteenth Amendment. He also pointed out the attempt by various states to circumvent the intent of the Antipeonage Act. "The present Act," he wrote, "is the latest of a lineage, in which its antecedents were obviously associated with the practice of peonage."
A key point in the Florida Supreme Court's decision had been the prime facie section of the 1919 law. The court ruled that since Pollock pleaded guilty, the implied guilt defined by that part of the statute was not relevant.Jackson, however, disagreed. According to the facts of the case, Jackson said, "the crime cannot be gleaned from the record." The law, under its primafacie provision, "purported to supply the element of intent." By pleading guilty, Pollock only went along with what the law already seemed to dictate. The presumption of Pollock's intent to defraud was written in the law, andthis presumption "had a coercive effect in producing the plea of guilty."
Jackson seemed to show some impatience with the Florida legislature's use ofthe prima facie tacit as a way to pin criminal guilt on someone who broke a labor contract:
As we have seen, Florida persisted in putting upon its statute books a provision creating a presumption of fraud from themere nonperformance of a contract for labor service three times after the courts ruled that such a provision violates the prohibition against peonage . .. The undoubted aim of the Thirteenth Amendment as implemented by the Antipeonage Act was not merely to end slavery but to maintain a system of completely free and voluntary labor throughout the United States . . . Congress has put it beyond debate that no indebtedness warrants a suspense of the right to be free from compulsory service. This congressional policy means that no statecan make the quitting of work any component of a crime . . .
Chief Justice Stone and Justice Reed dissented. Reed, in his dissent, arguedthat the Court had placed too much emphasis on the prima facie portionof the law, using its supposed unconstitutionality to strike down the entirelaw. Reed wrote that the first part of the law was valid: states have a right to criminally punish fraud in a labor contract, just as they might with other types of fraud. The Court however, has not wavered since Pollock from its attacks on any form of peonage.
Related Cases
- Bailey v. Alabama, 219 U.S. 219 (1911).
- Whitney v. California, 274 U.S. 357 (1927).
Further Readings
- Biskupic, Joan, and Elder Witt, eds. Guide to the U.S. Supreme Court. Washington, DC: Congressional Quarterly, Inc., 1997.
- Elliott, Stephen P., ed. A Reference Guide to the U.S. Supreme Court. New York: Facts on File Publications, 1986.
- Hall, Kermit L., ed. The Oxford Companion to the Supreme Court of theUnited States. New York: Oxford Press, 1992.
- New York Times, April 11, 1944.
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