Tuesday, December 3, 2013

Bailey v. State of Alabama case brief

Bailey v. State of Alabama case brief summary
219 U.S. 219 (1911)

Defendant sought review of a judgment from the Supreme Court of the State of Alabama, which upheld the constitutionality of Ala. Code § 4730 and affirmed a judgment of conviction. Defendant alleged that the statute upon which the conviction was based violated U.S. Constitutional amends. XIII and XIV.

Defendant was convicted under Ala. Code § 4730 of obtaining 15 dollars under a contract in writing with intent to injure or defraud his employer. Defendant had entered into a contract to perform a service and was paid the money under the contract. Defendant partially performed under the contract. Defendant appealed alleging that the statute was unconstitutional. The state supreme court upheld the validity of the statute and Defendant's conviction.


  • On writ of error, the United States Supreme Court reversed and remanded, finding that the statute violated U.S. Constitutional Amendment XIII. 
  • The Court held that the State could not punish the servant as a criminal for the mere failure or refusal to serve without paying his debt and was not permitted to accomplish the same result by creating a statutory presumption which upon proof of no other fact exposed him to conviction and punishment. 
  • The Court found that the statute provided a convenient instrument for the coercion which the Constitution and Congress prohibited. 
  • The statute, in essence, allowed for compulsory service to secure the payment of a debt and, as such, was unconstitutional.

The Court found the challenged statute unconstitutional and reversed the judgment of the state supreme court.

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