Bailey v. Alabama

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Bailey v. Alabama

Submitted October 20, 1910
Decided January 3, 1911

Full case name:	Bailey v. State of Alabama

Citations:	211 U.S. 452; 29 S. Ct. 141; 53 L. Ed. 278; 219 U.S. 219 (1911)

Prior history:	Error to the Supreme Court of Alabama

Holding

Court membership

Chief Justice: Edward Douglass White
Associate Justices: John Marshall Harlan, Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day, William Henry Moody, Horace Harmon Lurton, Charles Evans Hughes

Case opinions

Majority by: Hughes
Joined by: Harlan, Day, White, McKenna, Moody
Dissent by: Holmes, Lurton

Bailey v. Alabama, 211 U.S. 452 (1908), was a United States Supreme Court case which overturned the peonage laws of Alabama. The Alonzo Bailey case is regarded as being the most important case of its kind after the Dred Scott v. Sandford decision.

Alonzo Bailey was a African American from Alabama who agreed to work for one year at $12 per month. He received an advance of $15. After working for a little over a month he stopped work, but did not refund any money. According to Alabama law such refusal to work and refund the money was prima facie evidence of intent to defraud.

The Supreme Court found that holding a person criminally liable for taking money for work not performed was akin to indentured servitude, outlawed by the Thirteenth Amendment, insofar as it required that person to work rather than be found guilty of a crime. The case is important because the peonage laws of the State of Alabama were found to be unconstitutional.