The law read: Any person who, with intent to injure or defraud his employer, enters into a contract in writing for the performance of any act of service, and thereby obtains money or other property from such employer, and with like intent, and without just cause, and without refunding such money, or paying for such property, refuses or fails to perform such act or service, must on conviction be punished....[2]Alonzo Bailey was an African American from Alabama who agreed to work for The Riverside Company for one year at $12 per month.
The Supreme Court began its majority analysis, written by Associate Justice Charles Evans Hughes, by dismissing any importance of fact that the plaintiff was a Black man.
The asserted difficulty of proving the intent to injure or defraud is thus made the occasion for dispensing with such proof, so far as the prima facie case is concerned.
[A]lthought the statute in terms is to punish fraud, still its natural and inevitable effect is to expose to conviction for crime those who simply fail or refuse to perform contracts for personal service in liquidation of a debt; and judging its purpose by its effect, that it seeks in this way to provide the means of compulsion through which performance of such service may be secured.
"[6] The Court again discussed the broad interpretation of the Thirteenth Amendment, "in this explicit and comprehensive enactment, Congress was not concerned with mere names or manner of description....
Analyzing the law by its effects rather than its pretense, the Court held that a contract may expose a debtor to the responsibility for his debt but not enforced labor.