Skip to main content

Second Ala. Law Allowing Forced Labor Unconstitutional


Lonzo Bailey agreed to work for a year as a farmhand for $144. His employer gave him $15 upfront and was to pay the rest in equal amounts each month. However, after one month, Bailey quit and his employer sued him for the $15 he had been paid. Under a new Alabama law, a worker who broke an employment agreement without just cause could be charged as if he had stolen money and would face fines and jail time. While the Alabama law was written to prevent fraud – taking money for work without any intention of completing the work – it also caught people who simply decided to change jobs or leave a job. In deciding Bailey v. State of Alabama, the Supreme Court said that forcing people to work against their will amounts to involuntary servitude and is prohibited by the 13th Amendment.