January 1911

In Bailey v. Alabama, the Supreme Court ruled 7-2 that Alabama's criminal contract law — which made it a crime to break a labor contract after accepting an advance, with no opportunity to rebut the presumption of fraud — violated the 13th Amendment's prohibition on involuntary servitude. The case was brought by the NAACP and ACLU. Justice Oliver Wendell Holmes wrote the dissent. While the ruling struck down one specific statute, Southern states quickly enacted variations that achieved the same result through slightly different legal mechanisms, demonstrating how legal victories were routinely nullified by legislative workarounds.

In Bailey v. Alabama, the Supreme Court ruled 7-2 that Alabama's criminal contract law violated the 13th Amendment's prohibition on involuntary servitude. The case was brought by the NAACP. While the ruling struck down one specific statute, Southern states quickly enacted variations achieving the same result through slightly different legal mechanisms.