Pollock v. Williams
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 no intent 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 someone to 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 forced labor (other than in prisons).
After Reconstruction, many southern states tried to limit employment opportunities for African Americans. Without special licenses, African Americans were often 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 a crime 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 and then did not honor their contract were committing fraud and would be charged with a misdemeanor. If someone arrested under the law refused to pay back the money or honor the contract, that was prima facie, or implied, proof of 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.