The contract
Bailey signs a year's contract with the Riverside Company and receives $15.S1 ↗
01 / Verdict · where it standsUS · 1911 · CASE
Outcome · Bailey won, 7–2
WHAT THE STATE MAY NOT DO DIRECTLY IT MAY NOT DO INDIRECTLY.
Alonzo Bailey took a $15 advance on a year's farm contract, worked about five weeks and left. Under Alabama's §4730 leaving was evidence of fraud, and he was barred from testifying about his intent. He was fined $30 and, in default, held to hard labor for 136 days. The Court struck the statute as in conflict with the Thirteenth Amendment and the federal peonage law.
The Court said it dismissed from consideration that Bailey was Black.S1 ↗ϟ THE CASE IN 20 SECONDS
1WHOAlonzo Bailey, a farm laborer, against the State of Alabama.
2WHATWhether a state could jail a worker for leaving a job after taking an advance.
3WHY IT MATTERSThe Court struck the trap, but would not name the racial system it served.
THE FULL CASE FILE · the original write-up, checked
HOW A $15 DEBT BECAME A PRISON SENTENCE
Alonzo Bailey signed a year's farm contract with the Riverside Company in December 1907 and took a $15 advance. He worked through January and a few days into February and left. Under Alabama's §4730, quitting after an advance without repaying was evidence of intent to defraud, and a separate rule barred him from testifying about his uncommunicated motives, so the one person who could rebut the presumption could not speak to it. He was fined $30 and costs, and in default held to hard labor: 136 days.
The arithmetic was the point: a worker could be jailed and forced to labor for walking away from a debt he could not pay down. The Supreme Court, 7–2, struck the statute as in conflict with the Thirteenth Amendment and the federal law enforcing it. What the State may not do directly, Justice Hughes wrote, it may not do indirectly.S1 ↗
WHAT THE COURT WOULD NOT DO
The Court decided on colorblind grounds of contract and debt and said so: it dismissed from consideration the fact that Bailey was Black, in a case about a system that re-bound Black labor after slavery. Justice Holmes, with Justice Lurton, dissented, reading the statute as an ordinary fraud law.
Bailey won his case. Whether the system he stood against lost its war is the divergence this file measures.S1 ↗
BAILEY V. ALABAMA
♟ CITIZEN LOADOUT · ALONZO BAILEY
⬟
NO INDIRECT PEONAGE
Presumptions cannot achieve forbidden compulsion.
♜ INSTITUTION LOADOUT · STATE OF ALABAMA
♜
THE SCORED ACTOR
State of Alabama and the power it used. The people on the citizen side are named as the case names them and are not scored.
WHAT THIS RULING DID NOT DO — The Court said it dismissed from consideration that Bailey was Black. It ruled on the Thirteenth Amendment and did not reach the Fourteenth. Holmes and Lurton dissented.
AFTERMATH LEDGER
WHY THIS SITS WHERE IT DOES
A 7–2 ruling that struck the fraud-presumption trap and set the rule against doing indirectly what cannot be done directly.
THE THROUGH-LINE
Clyatt defined peonage; Bailey struck the fraud trap; Reynolds struck the surety trap.
76/100
CONSTITUTIONAL GRAVITY
All-time consequence · high. Pointed toward the citizen.
02 / Battle · powers and the battle logUS · 1911 · CASE
ScaleIVInstitutional
POWER LEVEL · CASE
66 /99
Power level from the earlier version of this page. Band 63–69 · ±3 uncertainty.
citizen-protective · settledBattle Power rates each side's position in this lawsuit from five inputs. It doesn't judge the people involved.
◈ CITIZEN SIDE · ALONZO BAILEY
NO INDIRECT PEONAGE
Won, 7–2
P = 67/99 battle power
SCORE DASHBOARD · THE NUMBERS AS BARS
SUPREME COURT (HUGHES, J.)
The statute is void. A presumption cannot achieve what a direct command could not. The Court decided on colorblind grounds.S1 ↗
HOLMES, J., DISSENTING (WITH LURTON, J.)
Holmes read it as a fraud law.S1 ↗
BATTLE LOG · THE DECISIVE MOVES
THE RULING AND ITS CONSEQUENCES ARE RECORDED SEPARATELY. The lawsuit is scored on its own record. What happened afterward is listed separately, with sources.
03 / Evidence · the record behind every claimUS · 1911 · CASE
THE RECORD IS OPEN TO INSPECTION.
The opinions and records behind every line on this page.
S1 · Justia · U.S. Reports
S1 ↗Bailey v. Alabama, 219 U.S. 219 (1911)
Hughes, J., for the Court; Holmes, J., dissenting with Lurton. Decided 3 January 1911. The contract, the $15 advance, §4730, the evidence rule, the $30 fine and 136 days.
S2 · Public.Resource.Org · U.S. Reports text
S2 ↗United States v. Reynolds, 235 U.S. 133 (1914)
Three years later, the surety trap struck.
No matching source. Try a holding name or case title.
HOLDINGS INDEX · WHAT THE COURT SAID
Each entry opens the court's own words, a plain reading and the limit of the rule.
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 · 1911 · CASE
CASE · SELECT A PATH
WHERE THIS CASE SITS.
A state may not compel labor for debt through a criminal presumption that leaving a job is fraud.
1911 · BAILEY V. ALABAMA
A state may not compel labor for debt through a criminal presumption that leaving a job is fraud.
…is in conflict with the Thirteenth Amendment, and the legislation authorized by that Amendment, and is therefore invalid.S1 · Justia · U.S. Reports ↗
Clyatt v. United States
The definition of peonage.
S1 · Justia · U.S. Reports ↗United States v. Reynolds
Struck the criminal-surety trap three years later.
S2 · Public.Resource.Org · U.S. Reports text ↗LIMIT OF THE CONNECTION
Holmes and Lurton dissented.
▥ GOVERNMENT-ADVANTAGING DOCTRINE
Colorblind framingClaims about the racial purpose of a law
◈ CITIZEN DOCTRINE
No indirect peonageLabor-debt statutes
WHAT THIS FEEDS ON THE MAP
Links to places on the map where a record shows this rule was applied. It links; it doesn't color the map.
05 / Battlefield · where it was foughtUS · 1911 · CASE
MAP RULE: A court case doesn't change any county's score on its own. Only sourced, reviewed local events move a county's Constitutional Compliance Score.
DECISION · INSTITUTIONAL LOCATION
DECIDED · 1911-01-03SUPREME COURT OF THE UNITED STATES
State of Alabama and the power it used. The people on the citizen side are named as the case names them and are not scored.
HOW IT CONNECTS · DIAGRAM, NOT A MAP
ORIGINMONTGOMERY COUNTY, ALABAMA
⇢Montgomery County, Alabama
REACHNATIONAL
national — labor-fraud and debt statutes
WHERE THIS EVENT BELONGS
The dispute began in Montgomery County, Alabama.
The scored institution: State of Alabama.
WHAT CONNECTS TO YOUR U.S. MAP
Links to related places on the map.
On its own, it doesn't change any county's score.
MAP RECORD
| case_ref | case:bailey-v-alabama |
|---|---|
| Event type | adjudicated_case |
| Location | Montgomery County, Alabama |
| Scale | IV · Institutional · national |
| Direction | +1 · citizen-protective |
| Gravity · Current force | 76 · 70 |
| Method | civic3-gravity-1.0 |
06 / Battle Loot · what each side won and lostUS · 1911 · CASE
⚔ BATTLE LOOT · WHAT CHANGED HANDS
Who won each encounter, from the sources on this page.
| Encounter | What was at stake | Taken by | What changed |
|---|---|---|---|
| 1911-01-03 · Supreme Court of the United States · 219 U.S. 219 (1911) | Did Alabama's labor-contract fraud law, with its presumption and evidence rule, enforce peonage? | CITIZEN | Bailey won, 7–2. S1 ↗ |
Citizen 1 · a count of results, not a score
07 / Method & History · every number, every changeUS · 1911 · CASE
EVERY NUMBER IS OPEN.
Gravity, current force and effect use the Civic³ method on the Equation page. Every input below shows its reason and source. Challenge any of them.
75.5
GRAVITY · RAW WEIGHTED TOTAL
The six components below, weighted and summed.
G = .25 Authority + .20 Reach + .20 Durability + .15 Progeny + .10 Cross-domain + .10 Implementation| Input | Score | Weight | Contribution | Reason |
|---|---|---|---|---|
| Authority | 90 | 25% | 22.50 | The Supreme Court, 7–2.S1 ↗ |
| Reach | 75 | 20% | 15.00 | Labor-fraud statutes in every state.S1 ↗ |
| Durability | 85 | 20% | 17.00 | Never overruled.S1 ↗ |
| Progeny | 70 | 15% | 10.50 | The anti-evasion principle used against later peonage laws.S1 ↗ |
| Cross-domain | 60 | 10% | 6.00 | Labor, criminal evidence and debt.S1 ↗ |
| Implementation | 45 | 10% | 4.50 | Struck one statute; others were not before the Court.S1 ↗ |
| Total | 100% | 75.50 | Displayed as 76 |
CONSTITUTIONAL EFFECT
+52.8
E = Direction × Gravity × Confidence × Current Force
Toward the Thirteenth Amendment; settled.
E = +1 × 76 × 1.0 × 70/100READ THE SIGN CAREFULLY — A negative effect means the ruling's weight today favors institutions over citizens. It says nothing about the people in the case.
CURRENT FORCE · WHAT IS STILL LIVE
Good law on peonage statutes.
anti-evasion principle · controllingWhat the state may not do directly…S1 ↗
THE FULL SCORE STACK
| Field | This file | Meaning |
|---|---|---|
| Power level /99 | 66 · band 63–69 | From the earlier version (an editorial estimate). |
| Legal / Promise / Divergence | 88 / 54 / 34 | Remedy delivered versus constitutional promise. |
| Battle Power (citizen / institution) | 67 / 43 | Litigation strength of each side, from the five inputs above. |
| Gravity | 76 | All-time constitutional consequence. |
| Current force | 70 | How much of that weight still governs today. |
| Constitutional Effect | +52.8 | Signed present consequence. |
Nine-axis profile · every input
Reach · 87Legacy value, carried from the earlier file.S1 ↗
Severity · 87Legacy value, carried from the earlier file.S1 ↗
Precedent · 74Legacy value, carried from the earlier file.S1 ↗
Resistance · 76Legacy value, carried from the earlier file.S1 ↗
Divergence (axis) · 50Radar input only. Not the Legal/Promise divergence above.
Asymmetry · 50Legacy value, carried from the earlier file.S1 ↗
Evidence · 82Legacy value, carried from the earlier file.S1 ↗
Contestation · 35Legacy value, carried from the earlier file.S1 ↗
Fog · 34Legacy value, carried from the earlier file.S1 ↗
AXIS PROVENANCE — The nine axes come from the earlier version and only drive the radar.
FROM THE EARLIER VERSION
Values from the earlier version.
| Field | Legacy file | This edition |
|---|---|---|
| Power level | 66 · band 63–69 | 66 (carried) |
| Legal / Truth / Divergence | 88 / 54 / 34 | Shown as the Legal and Promise games. |
REVISION HISTORY
A RECORD THAT STAYS OPEN TO CHALLENGE.
Rebuilt from the opinion
The legacy page was rebuilt on the case-record chassis from the opinion.
[QUALIFIED] Prose restored from the legacy page, checked
The old page's write-up is carried into the card's full case file. Qualified: 'Alabama simply rewrote its statutes; the practice persisted for decades' and the Booker T. Washington funding are left as open research (not in the opinion read).
OPEN RESEARCH ITEMS
What Alabama did after the ruling (the old page said it rewrote its statutes).
The Booker T. Washington funding of the appeal (the old page said so; not checked).
REVIEW THIS EDITION
Every number, quote and edge on this page can be challenged with a source.