Alonzo Bailey's Case Challenges Alabama Peonage Law Criminalizing Quitting Work

Alonzo Bailey, a Black Alabama farm laborer, was arrested for breach of contract after accepting a $15 advance and leaving before his year of labor was complete. Under Alabama law, this was presumptive fraud. The NAACP challenged the statute. In Bailey v. Alabama (1911), the Supreme Court struck down the law as a violation of the 13th Amendment's prohibition on involuntary servitude, striking at the legal infrastructure of peonage.