Clyatt v. United States
SPLIT Law upheld and peonage defined; conviction reversed on a proof gap. S1 ↗
01 / Verdict · where it standsUS · MASS INCARCERATION · CAMPAIGN
Campaign standing · the labor traps struck, the sentencing engine cleared
THE COURTS STRUCK THE LABOR TRAPS. THEN THEY CLEARED THE WAY FOR THE ENGINE.
Clyatt, Bailey and Reynolds struck debt bondage one mechanism at a time, without naming the system it served. In 1986 Congress built the 100-to-1 crack ratio into mandatory minimums with no hearings, and in 1991 Harmelin removed the main constitutional limit on mandatory sentences. In 2010 Congress cut the ratio to about 18 to 1, and in 2018 it reached the people already sentenced, on petition.
The 1986 and 2010 Acts have their own statute files. The 1994 Crime Bill and the exception clause don't have files yet. S6 ↗⚔ BATTLE LOOT · WHO TOOK EACH ENCOUNTER
CITIZEN3INSTITUTION2SPLIT1
A count of results, not a score. Each row names what was at stake.
ϟ THE CAMPAIGN IN 20 SECONDS
1THE FIGHTWhether the state can compel labor for debt, and how severely it can punish.
2THE OBSTACLEThe Thirteenth Amendment's punishment exception, and deference on sentencing.
3WHERE IT STANDSPeonage is a federal crime; mandatory sentences face almost no constitutional limit.
THE EXCEPTION, AND THE ENGINE.
♟ CITIZEN LOADOUT · ROUTES THAT REMAIN
⬟
THE CORE SHIELD
The Thirteenth Amendment's ban on slavery and involuntary servitude, and the Eighth Amendment's ban on cruel and unusual punishment.
♜ INSTITUTION LOADOUT · POWERS SUSTAINED
♜
THE SCORED ACTOR
Civic³ rates the institutions that used the power, not the people on the other end of it.
02 / Battle · powers and the battle logUS · MASS INCARCERATION · CAMPAIGN
Scale · legacyVCivilizational
CAMPAIGN POWER LEVEL · LEGACY PROFILE
86 /99
Band 82–90 · ±4 uncertainty. From the earlier version; not recalculated yet.
EARLIER PROFILE · NOT A CCS SCOREThe power level and radar come from the earlier version of this page. Battle power comes from each encounter's own case file. The campaign doesn't add them into a total of its own.
⚔ POWER BY ENCOUNTER
Battle power for each side, taken from each case's own file. A case that hasn't been reviewed yet shows UNMEASURED.
1905 · Clyatt v. United States
♟ Citizen battle power55
♜ Institution battle power48
Gravity 75 · current force 65 · effect +29.2 · from case:clyatt-v-united-states ↗
1911 · Bailey v. Alabama
♟ Citizen battle power67
♜ Institution battle power43
Gravity 76 · current force 70 · effect +52.8 · from case:bailey-v-alabama ↗
1914 · United States v. Reynolds
♟ Citizen battle power79
♜ Institution battle power38
Gravity 77 · current force 70 · effect +53.7 · from case:united-states-v-reynolds ↗
1986 · Anti-Drug Abuse Act of 1986
♟ Citizen battle power34
♜ Institution battle power74
Gravity 83 · current force 60 · effect −49.9 · from case:anti-drug-abuse-act-1986 ↗
1991 · Harmelin v. Michigan
♟ Citizen battle power41
♜ Institution battle power78
Gravity 80 · current force 80 · effect −63.6 · from case:harmelin-v-michigan ↗
2010 · Fair Sentencing Act + First Step §404
♟ Citizen battle power60
♜ Institution battle power64
Gravity 79 · current force 85 · effect +67.1 · from case:fair-sentencing-act-2010 ↗
♟ CITIZEN ROUTES
The Peonage ActACTIVE
Strict proof of the charge.No indirect compulsionACTIVE
Decided on colorblind grounds.Fear of prosecution is compulsionACTIVE
Convict leasing not before the Court.♜ INSTITUTIONAL MACHINERY
The punishment exceptionACTIVE
Requires a conviction.Mandatory sentencesACTIVE
Grossly disproportionate sentences may still fail.Proportionality narrowedCONDITIONAL
Nearly nothing clears the bar.BATTLE LOG · WHAT CHANGED, WHEN
Bailey v. Alabama
CITIZEN Struck 7–2 as peonage, on colorblind grounds. S2 ↗
United States v. Reynolds
CITIZEN Struck: compulsion by fear of imprisonment is peonage. S3 ↗
Anti-Drug Abuse Act of 1986
INSTITUTION Enacted with mandatory minimums; no hearings behind the ratio. S6 ↗
Harmelin v. Michigan
INSTITUTION Upheld 5–4: severe, mandatory penalties are not unusual. S4 ↗
Fair Sentencing Act + First Step §404
CITIZEN Cut to about 18 to 1 (2010); made retroactive on petition (2018). S7 ↗
FOUR RULINGS, ONE EXCEPTION. Different kinds of events. No campaign total is calculated from them.
03 / Evidence · the record behind every claimUS · MASS INCARCERATION · CAMPAIGN
THE RECORD IS OPEN TO INSPECTION.
Read the legal record, see how this page uses it, and challenge any specific claim.
S1 · Public.Resource.Org
S1 ↗Clyatt v. United States, 197 U.S. 207 (1905)
Peonage defined; conviction reversed.
S2 · Justia
S2 ↗Bailey v. Alabama, 219 U.S. 219 (1911)
The fraud-presumption trap struck.
S3 · Public.Resource.Org
S3 ↗United States v. Reynolds, 235 U.S. 133 (1914)
The criminal-surety trap struck.
S4 · Cornell LII
S4 ↗Harmelin v. Michigan, 501 U.S. 957 (1991)
Mandatory life without parole upheld.
S5 · Wikipedia
S5 ↗Harmelin v. Michigan
The 5–4 lineup; Michigan's 1998 parole change.
S6 · U.S. Sentencing Commission
S6 ↗Report to the Congress: Cocaine and Federal Sentencing Policy (May 2002)
The 100-to-1 ratio, passed with no hearings; 84.7% of federal crack offenders in FY2000 were Black.
S7 · Cornell LII
S7 ↗Terry v. United States, 593 U.S. ___ (2021), No. 20-5904
The 2010 thresholds (28g, 280g; about 18 to 1) and First Step Act §404 (2018).
No matching source.
ENCOUNTERS & POWERS · OPEN ANY ENTRY
What this selection covers · and what it does not
| Question | Forced labor for debt, and the constitutional limits on punishment. |
|---|---|
| Included | Four court cases and two statutes, each with its own file. |
| Not included | The 1994 Crime Bill and the Thirteenth Amendment's exception clause (future records); every peonage and sentencing case. |
COMMUNITY VAULT · PREPARE A FORMAL CHALLENGE
DISAGREE? MAKE THE OBJECTION PRECISE.
Your challenge saves on this device. Export it to send it in for review. Nothing is posted publicly.
04 / Lineage · where it came from, what it producedUS · MASS INCARCERATION · CAMPAIGN
AUTHORITY CHAIN · FROM LABOR TO SENTENCING
CLYATT → BAILEY → REYNOLDS → HARMELIN
Clyatt defined peonage; Bailey struck the fraud trap; Reynolds struck the surety trap; Harmelin cleared mandatory sentencing.
Clyatt v. United States
Law upheld and peonage defined; conviction reversed on a proof gap. S1 ↗
Bailey v. Alabama
Struck 7–2 as peonage, on colorblind grounds. S2 ↗
United States v. Reynolds
Struck: compulsion by fear of imprisonment is peonage. S3 ↗
Anti-Drug Abuse Act of 1986
Enacted with mandatory minimums; no hearings behind the ratio. S6 ↗
Harmelin v. Michigan
Upheld 5–4: severe, mandatory penalties are not unusual. S4 ↗
Fair Sentencing Act + First Step §404
Cut to about 18 to 1 (2010); made retroactive on petition (2018). S7 ↗
⚙ POWER INSPECTOR · WHAT EACH SIDE CAN USE
Expand any power to see its origin, holder, effect, conditions, reach and change.
♟ The Peonage ActACTIVE
- Origin
- Clyatt (1905)
- Who may use it
- Anyone held to labor for debt.
- Effect
- Federal prosecution of peonage anywhere.
- Conditions
- Strict proof of the charge.
- Reach
- National.
- Power change
- Upheld 1905.
♟ No indirect compulsionACTIVE
- Origin
- Bailey (1911)
- Who may use it
- Workers bound by debt.
- Effect
- A state may not do indirectly what it may not do directly.
- Conditions
- Decided on colorblind grounds.
- Reach
- National.
- Power change
- Never overruled.
♟ Fear of prosecution is compulsionACTIVE
- Origin
- Reynolds (1914)
- Who may use it
- People working off fines.
- Effect
- Labor compelled by threat of jail is forced.
- Conditions
- Convict leasing not before the Court.
- Reach
- National.
- Power change
- Never overruled.
♜ The punishment exceptionACTIVE
- Origin
- Thirteenth Amendment §1
- Who may use it
- Anyone convicted of a crime.
- Effect
- Involuntary servitude as punishment for crime remains allowed.
- Conditions
- Requires a conviction.
- Reach
- National.
- Power change
- Never repealed.
♜ Mandatory sentencesACTIVE
- Origin
- Harmelin (1991)
- Who may use it
- Legislatures setting penalties.
- Effect
- Severe, mandatory sentences without mitigation.
- Conditions
- Grossly disproportionate sentences may still fail.
- Reach
- National.
- Power change
- Controlling since 1991.
♜ Proportionality narrowedCONDITIONAL
- Origin
- Harmelin (1991), Kennedy concurrence
- Who may use it
- Courts reviewing sentences.
- Effect
- Only grossly disproportionate sentences barred.
- Conditions
- Nearly nothing clears the bar.
- Reach
- National.
- Power change
- The controlling rule.
LINKS TO OTHER CAMPAIGNS
Civil asset forfeiture is a thematic pairing: both concern what the state may extract after an accusation. The link is thematic.
05 / Battlefield · where it was foughtUS · MASS INCARCERATION · CAMPAIGN
MAP RULE: Pins show where each encounter started. Supreme Court decisions are pinned to Washington, D.C. A campaign doesn't change any county's score.
◈ THE BATTLEFIELD · WHERE IT WAS FOUGHT
The Civic Ops Map's own outline, with this campaign's encounters. Pin colors show who took each encounter.
Approximate origins · not a compliance heatmap
- 11905 · Clyatt v. United StatesLevy County, FloridaSPLIT
Law upheld and peonage defined; conviction reversed on a proof gap.
- 21911 · Bailey v. AlabamaMontgomery County, AlabamaCITIZEN
Struck 7–2 as peonage, on colorblind grounds.
- 31914 · United States v. ReynoldsAlabamaCITIZEN
Struck: compulsion by fear of imprisonment is peonage.
- 41986 · Anti-Drug Abuse Act of 1986Washington, DCINSTITUTION
Enacted with mandatory minimums; no hearings behind the ratio.
- 51991 · Harmelin v. MichiganMichiganINSTITUTION
Upheld 5–4: severe, mandatory penalties are not unusual.
- 62010 · Fair Sentencing Act + First Step §404Washington, DCCITIZEN
Cut to about 18 to 1 (2010); made retroactive on petition (2018).
LIVE FRONTS · WHERE TO LOOK NEXT
| Front | Power question | Record to inspect |
|---|---|---|
| Federal litigation | Is a sentencing challenge pending? | The petition, docket and ruling. |
| State legislation | Has your state changed mandatory minimums or fines and fees? | The statute, the vote and its effective date. |
| Local justice | Who sets bail and charges in your county? | The prosecutor's and judges' seats and their next election. |
| Public accountability | Does your county jail or prison use inmate labor? | The contract or policy and who approved it. |
FOLLOW THE RESPONSIBLE SEAT
Who holds the power → who used it → what allowed it → who oversees it → which elected seat answers for it. A local event goes on the map only with evidence of what happened, the authority used and the institution responsible.
06 / Battle Loot · what each side won and lostUS · MASS INCARCERATION · CAMPAIGN
⚔ BATTLE LOOT · WHAT CHANGED HANDS
Who won each encounter and what changed hands. “Taken by” names the side that came out ahead. It doesn't measure harm or who was right.
| Encounter | What was at stake | Taken by | What changed |
|---|---|---|---|
| 1905 · Clyatt v. United States | Whether Congress could punish peonage, and whether this conviction stood | SPLIT | Law upheld and peonage defined; conviction reversed on a proof gap. S1 ↗ |
| 1911 · Bailey v. Alabama | Whether Alabama could jail a worker for leaving after an advance | CITIZEN | Struck 7–2 as peonage, on colorblind grounds. S2 ↗ |
| 1914 · United States v. Reynolds | Whether fines paid by sureties could be worked off under threat of prosecution | CITIZEN | Struck: compulsion by fear of imprisonment is peonage. S3 ↗ |
| 1986 · Anti-Drug Abuse Act of 1986 | Whether crack should carry 100 times the penalty of powder by quantity | INSTITUTION | Enacted with mandatory minimums; no hearings behind the ratio. S6 ↗ |
| 1991 · Harmelin v. Michigan | Whether mandatory life without parole for drug possession is cruel and unusual | INSTITUTION | Upheld 5–4: severe, mandatory penalties are not unusual. S4 ↗ |
| 2010 · Fair Sentencing Act + First Step §404 | Whether to cut the ratio and reach people already sentenced | CITIZEN | Cut to about 18 to 1 (2010); made retroactive on petition (2018). S7 ↗ |
Citizen 3 · Institution 2 · Split 1 · a count of results, not a score
07 / Method & History · every number, every changeLEGACY PROFILE · NO CAMPAIGN FORMULA
READ EVERY NUMBER IN ITS OWN SCOPE.
The radar and power level are an editorial estimate from the earlier version. Encounter bars come only from reviewed case files. There's no formula for a campaign-wide score yet, so this page doesn't show one.
Campaign-wide power, gravity and current forceNo campaign method exists.UNMEASURED
EARLIER SCORES
| Field from the old file | Value | Treatment |
|---|---|---|
| Campaign power level | 86 /99 | Earlier estimate, not recalibrated; no bar. |
| Power band | 82–90 · ±4 | Original uncertainty range. |
| Scale | V · Civilizational | Historical classification, not a current score. |
THE NINE AXES (EARLIER VERSION)
| Axis | Legacy value | Scope |
|---|---|---|
| Reach | 99 | Original campaign input |
| Severity | 100 | Original campaign input |
| Precedent force | 94 | Original campaign input |
| Institutional resistance | 92 | Original campaign input |
| Profile divergence | 100 | Original campaign input |
| Asymmetry | 55 | Original campaign input |
| Evidentiary strength | 88 | Original campaign input |
| Contestation | 75 | Original campaign input |
| Fog density | 31 | Original campaign input |
HOW ENCOUNTER BARS ARE READ
Each encounter links to its case file. Battle power is calculated from that file once it's reviewed. The campaign page never enters those numbers itself.
RESULT COUNTS ARE NOT SCORES
“Taken by” covers one encounter. Counting wins doesn't measure harm or who is ahead today.
REVISION HISTORY
A RECORD THAT STAYS OPEN TO CHALLENGE.
Campaign chain INCARCERATION-001
Original campaign: eight nodes from the Exception Clause (1865) to the Fair Sentencing and First Step Acts, power level 86/99 and a nine-axis profile.
Rebuilt in the current card format
Seven standard tabs, power by encounter read from each case's own record, the battlefield and battle loot. The four court cases are encounters; the root clause and the three statutes are named in the verdict and wait for their own record types.
Claims corrected or withheld
'Black federal incarceration roughly quintupled', the $8.7–12.5B Crime Bill figure and 'a star died of a powder overdose' are not carried until the statutes get sourced records. Reynolds's 'operation-and-effect test' is not carried.
Two statutes join
The Anti-Drug Abuse Act of 1986 and the Fair Sentencing Act (2010) with First Step §404 (2018) are built as statute files and join as encounters.
REVIEW THIS EDITION
Challenge a specific fact, result or label. Evidence counts; agreeing or disagreeing doesn't.