United States v. Reynolds - 235 U.S. 133 (1914)
U.S. Supreme Court
United States v. Reynolds, 235 U.S. 133 (1914)
United States v. Reynolds
Nos. 478, 479
Argued October 23, 1914
Decided November 30, 1914
235 U.S. 133
Congress passed §§ 1990 and 526, Rev.Stat., and § 269, Criminal Code, abolishing and prohibiting peonage under the authority conferred by § 2 of the Thirteenth Amendment to enforce § 1 of that amendment, thereby undertaking to strike down all laws, regulations and usages in the states and territories which attempted to maintain and enforce, directly or indirectly, the voluntary or involuntary service or labor of any persons as peons in the liquidation of any debt or obligation.
Peonage is a condition of compulsory service based upon the indebtedness of the peon to the master. The basal fact is indebtedness. Clyatt v. United States, 197 U. S. 207.
Where a person charged with crime has, after confession, been sentenced to pay a fine and costs and then been released on the payment of a fine by a surety with whom he has made an agreement to work continuously for a specified period for the specified amount so paid for the fine and costs, as provided by the laws of Alabama, and he is liable to separate punishment if he fails to carry out the contract, the relation established between that person and the surety is that of peonage, and falls within the prohibition of the Thirteenth Amendment and the laws enacted to enforce it.
Constant fear of punishment under the criminal law renders work compulsory. Bailey v. Alabama, 219 U. S. 219.
While this Court follows the decisions of the state court in determining the constitutionality of state statutes under the state constitution, and ordinarily follows the construction given to such statutes by the state court, where such a decision really determines the legal effect of a state statute in a case involving the Constitution and laws of the United States, this Court determines for itself whether that statute does or does not violate the Constitution of the United States and the laws passed in pursuance thereof.
The validity of a system of state law will be adjudged by its operation and effect upon rights secured by the federal Constitution and offenses punished by federal statute.
213 F. 345, 352 reversed.
The facts, which involve the construction of certain penal statutes of Alabama and their constitutionality under the Thirteenth Amendment to the Constitution, and also of the Peonage Laws of the United States, are stated in the opinion.