Bailey v. Alabama

The U.S. Supreme Court resolved to hear Bailey v. Alabama because their decision would impact the authorization of "peonage laws." Finding that simple nonpayment of debt or refusal to work did not evidence nor prove intent to defraud an employer, the majority reasoned that the plaintiff's behavior could not be regarded as criminal and treated for penalties of hard labor. Consistent with the abolition of peonage in 1867 and the prohibition of any system that could force servitude for debt, the Court found that Alabama's statute was unconstitutional. This ruling expanded protection of laborers by finding that the plaintiff's breach of a labor contract could not be subjected to criminal penalty. The Court's ruling also provided significant instruction to state legislators and jurists regarding the applicability of the Thirteenth Amendment to safeguard individual rights and provide protection from forced labor.