Bailey v. Alabama - 219 U.S. 219 (1911)
U.S. Supreme Court
Bailey v. Alabama, 219 U.S. 219 (1911)
Bailey v. Alabama
Argued October 20, 21, 1910
Decided January 3, 1911
219 U.S. 219
Prima facie evidence is sufficient to outweigh the presumption of innocence, and, if not met by opposing evidence, to support a verdict. Kelly v. Jackson, 6 Pet. 632.
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.
While the Thirteenth Amendment is self-executing, Congress has power to secure its complete enforcement by appropriate legislation and the Peonage Act of March 2, 1867, and §§ 1990 and 5526, Rev.Stat., are valid exercises of this authority. Clyatt v. United States, 197 U. S. 207.
A peon is one who is compelled to work for his creditor until his debt
is paid, and the fact that he contracted to perform the labor which is sought to be compelled does not withdraw the attempted enforcement from the condemnation of the peonage acts.
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 motive 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 4730 of the Code of Alabama as amended in 1907, insofar 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.
161 Ala. 78 reversed.
The facts, which involve the constitutionality of § 4730 of the Code of Alabama as construed by the courts of that state and the validity of a conviction thereunder, are stated in the opinion.