What was Bailey vs. Alabama?
The word peonage is usually used to describe laborers that have little or no control over their working conditions.
Alonzo Bailey was an African American from Alabama who agreed to work for $12.00 per month at The Riverside Company as a farm hand in 1908. The company gave him a $15.00 advance but quit a little after one month of working. He did not return any of the money and according to Alabama law this was a form of fraud. The city court found Bailey guilty and assessed a $30.00 fine. Bailey proceeded with a lawsuit.
The case went to trial and the Supreme Court found peonage laws of Alabama to be unconstitutional.
The Thirteenth Amendment absolutely declares that slavery and involuntary servitude shall not exist in any part of the United States, which includes peonage, the voluntary or involuntary service or labor in liquidation of any debt or obligation. The Thirteenth Amendment prohibits involuntary servitude except as punishment for crime, however, it does not mean to punish a person as a crime if he does not perform the service or pay the debt.
Bailey vs. Alabama was a Supreme Court case from 1911. In it, the Court overturned Alabama's laws of "peonage" which essentially made it easier for white employers to control black workers and force them to work.
Bailey was convicted of fraud because he took a $15 advance from his employer and then left after working one month (worth $12). The laws at the time made that criminal fraud.
The Supreme Court found that this law was unconstitutional under the 13th Amendment because it essentially allowed a person to be enslaved for failure to pay a debt.