Pollock v. Williams
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 supreme court, 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 Florida Supreme 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 prima facie 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, and this presumption "had a coercive effect in producing the plea of guilty."
Jackson seemed to show some impatience with the Florida legislature's use of the 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 the mere 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 state can make the quitting of work any component of a crime . . .
Chief Justice Stone and Justice Reed dissented. Reed, in his dissent, argued that the Court had placed too much emphasis on the prima facie portion of the law, using its supposed unconstitutionality to strike down the entire law. 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.