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, leaving work after taking an advance was presumptive evidence of intent to defraud — a crime. The NAACP and Department of Justice 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. The case struck at the legal infrastructure of peonage that trapped hundreds of thousands of Black workers.