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The validity of a statute that authorizes a jury to convict on prima facie evidence must be judged by the fact that the jury may convict even if it is not made the duty of the jury to do so.
Although a state statute in terms be to punish fraud, if its natural and inevitable purpose is to punish for crime for failing to perform contracts of labor, thus compelling such performance, it violates the Thirteenth Amendment, and is unconstitutional.
A constitutional prohibition cannot be transgressed indirectly by creating a statutory presumption any more than by direct enactment, and a state cannot compel involuntary servitude in carrying out contracts of personal service by creating a presumption that the person committing the breach is guilty of intent to defraud merely because he fails to perform the contract.
While states may, without denying due process of law, enact that proof of one fact shall be prima facie evidence of the main fact in issue, the inference must not be purely arbitrary; there must be rational relation between the two facts, and the accused must have proper opportunity to submit all the facts bearing on the issue.
While its immediate concern was African slavery, the Thirteenth Amendment was a charter of universal civil freedom for all persons of whatever race, color, or estate, under the flag. The words "involuntary servitude" have a larger meaning than slavery, and the Thirteenth Amendment prohibited all control by coercion of the personal service of one man for the benefit of another.
United States, U. A peon is one who is compelled to work for his creditor until his debt Page U. The federal anti-peonage acts are necessarily violated by any state legislation which seeks to compel service or labor by making it a crime to fail or refuse to perform it.
Although this Court may not impute to a state an actual Writing page 219 to oppress by a statute which that state enacts, it must consider the natural operation of such statute and strike it down if it becomes an instrument of coercion forbidden by the federal Constitution.
Section of the Code of Alabama as amended ininsofar as it makes the refusal or failure to perform labor contracted for without refunding the money or paying for property received prima facie evidence of the commission of the crime defined by such section, and, when read in connection with the rule of evidence of that state, that the accused cannot testify in regard to uncommunicated motives, is unconstitutional as in conflict with the Thirteenth Amendment and of the legislation authorized by it and enacted by Congress Quaere, and not necessary now to decide, whether such section is, under the Fourteenth Amendment, an unconstitutional deprivation of property without due process of law or denial of equal protection of the laws.
This is a writ of error to review a judgment of the Supreme Court of the State of Alabama, affirming a judgment of conviction in the Montgomery City Court. The statute upon which the conviction was based is assailed as in violation of the Fourteenth Amendment of the Constitution of the United States upon the ground that it deprived the plaintiff in error of his liberty without due process of law and denied him the equal protection of the laws, and also of the Thirteenth Amendment, and of the act of Congress providing for the enforcement of that Amendment, in that the effect of the statute is to enforce involuntary servitude by compelling personal service in liquidation of a debt.
The section of the Code as it stood before the amendments provided that any person who, with intent to injure or defraud his employer, entered into a written contract for service, and thereby obtained from his employer money or other personal property, and with like intent and without just cause, and without refunding the money or paying for the property, refused to perform the service, should be punished as if he had stolen it.
This amendment was enlarged by that of The section, thus amended, reads as follows: And the refusal or failure of any person who enters into such contract to perform such act or service or to cultivate such land or refund such money or pay for such property without just cause shall be prima facie evidence of the intent to injure his employer or landlord or defraud him.
That all laws and parts of laws in conflict with the provisions hereof be and the same are hereby repealed.
Bailey, the plaintiff in error, was committed for detention on the charge of obtaining fifteen dollars under a Page U. He sued out a writ of habeas corpus challenging the validity of the statute. His discharge was refused, and the supreme court of the state affirmed the order, holding the statute to be constitutional.
On writ of error from this Court, it was held that the case was brought here prematurely, and the questions now presented were expressly reserved.
Having failed to obtain his release on habeas corpus, Bailey was indicted on the following charge: Upon the trial, the following facts appeared: No other evidence was introduced.
The court, after defining the crime in the language of the statute, charged the jury, in accordance with its terms, as follows: The jury found the accused guilty, fixed the damages sustained by the injured party at fifteen dollars, and assessed a fine of thirty dollars.
Thereupon Bailey was sentenced by the court to pay the fine of thirty dollars and the costs, and in default thereof to hard labor "for twenty days in lieu of said fine, and one hundred and sixteen days on account of said costs.
We at once dismiss from consideration the fact that the plaintiff in error is a black man. While the action of a state, through its officers charged with the administration of a law fair in appearance, may be of such a character as to constitute a denial of the equal protection of the laws Yick Wo v.
The statute, on its face, makes no racial discrimination, and the record fails to show its existence in fact. No question of a sectional character is presented, and we may view the legislation in the same manner as if it had been enacted in New York or in Idaho.
Opportunities for coercion and oppression, in varying circumstances, exist in all parts of the Union, and the citizens of all the states are interested in the maintenance of the constitutional guaranties the consideration of which is here involved.The Writer’s Dig by Jess Zafarris Content Strategist Jess Zafarris covers everything about writing on this blog.
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