Taken back to Georgia
In Levy County, Florida, Clyatt and another man seize Gordon and Ridley on Georgia larceny warrants and take them back to work off a debt.S1 ↗
01 / Verdict · where it standsUS · 1905 · CASE
Outcome · law upheld; conviction reversed
THE BASAL FACT IS INDEBTEDNESS.
Samuel Clyatt took two men from Florida back to Georgia on larceny warrants the Court found were likely a pretext, to work off a debt. He was convicted under the federal peonage law and sentenced to four years at hard labor. The Court upheld the law and defined peonage, then reversed: no evidence showed the men had been in peonage before, as a charge of 'returning' them required.
The conviction was reversed and a new trial ordered.S1 ↗ϟ THE CASE IN 20 SECONDS
1WHOSamuel M. Clyatt, against the United States prosecuting on behalf of Will Gordon and Mose Ridley.
2WHATWhether Congress could punish peonage everywhere, and whether this conviction stood.
3WHY IT MATTERSIt set the definition of peonage the later cases used, and gave the two men no remedy.
THE FULL CASE FILE · the original write-up, checked
A PRINCIPLE WON, A CASE LOST
Samuel Clyatt said two men, Will Gordon and Mose Ridley, owed him money. In February 1901, in Levy County, Florida, he and another man seized them on Georgia larceny warrants, which the Court found were likely a pretext, and took them back to Georgia to work off the debt. He was indicted under the federal peonage law for returning them to peonage, convicted, and sentenced to four years at hard labor.
The Supreme Court did something that looks like a victory and works like a defeat. Justice Brewer defined peonage as a status or condition of compulsory service based on the peon's debt to the master: the basal fact is indebtedness. The Thirteenth Amendment denounces that status however it is created, so Congress can punish it anywhere, by anyone. Then the Court reversed the conviction. The charge was returning the men to peonage, and there was not a scintilla of testimony that they had been held in peonage before.S1 ↗
THE PROOF GAP
The debt was on the record. The forcible return was on the record. The one missing element was a prior condition of peonage, which a charge of 'returning' required. That single word decided the case: a new trial was ordered, the two men received no remedy, and the grand principle floated free of any consequence. Justice Harlan would have let the jury's verdict stand.
The legal score is high because the doctrine is real and durable. The truth score is low because the people at the center of it received nothing.S1 ↗
CLYATT V. UNITED STATES
♟ CITIZEN LOADOUT · THE UNITED STATES, FOR WILL GORDON AND MOSE RIDLEY
⬟
PEONAGE IS A CRIME EVERYWHERE
The federal law reaches individuals in every state.
♜ INSTITUTION LOADOUT · DEBT PEONAGE ENFORCED THROUGH STATE WARRANTS
♜
THE SCORED ACTOR
Debt peonage enforced through state warrants 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 conviction was reversed and a new trial ordered. The Court did not doubt the men were taken by force to work off a debt. Harlan, J., would have let the jury's verdict stand.
AFTERMATH LEDGER
WHY THIS SITS WHERE IT DOES
The definition of peonage, upheld as federal law against anyone, in a case whose own conviction failed.
THE THROUGH-LINE
Clyatt defined peonage; Bailey struck the fraud trap; Reynolds struck the surety trap.
75/100
CONSTITUTIONAL GRAVITY
All-time consequence · high. Pointed toward the citizen.
02 / Battle · powers and the battle logUS · 1905 · CASE
ScaleIVInstitutional
POWER LEVEL · CASE
65 /99
Power level from the earlier version of this page. Band 61–69 · ±4 uncertainty.
citizen-protective · leaningBattle Power rates each side's position in this lawsuit from five inputs. It doesn't judge the people involved.
◈ CITIZEN SIDE · THE UNITED STATES, FOR WILL GORDON AND MOSE RIDLEY
PEONAGE IS A CRIME EVERYWHERE
Won the principle; lost the conviction
P = 55/99 battle power
♜ INSTITUTION SIDE · DEBT PEONAGE ENFORCED THROUGH STATE WARRANTS
STRICT PROOF OF THE CHARGE
Conviction reversed
P = 48/99 battle power
SCORE DASHBOARD · THE NUMBERS AS BARS
SUPREME COURT (BREWER, J.)
Debt plus compelled labor is peonage. Debt, not the label, makes it peonage. The law reaches individuals, not only states. The charge of 'returning' them failed.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 · 1905 · CASE
THE RECORD IS OPEN TO INSPECTION.
The opinions and records behind every line on this page.
S1 · Public.Resource.Org · U.S. Reports text
S1 ↗Clyatt v. United States, 197 U.S. 207 (1905)
Brewer, J., for the Court; McKenna concurring in the judgment; Harlan dissenting in part. Decided 13 March 1905. Gordon and Ridley; Levy County, Florida, 11 Feb 1901; four years at hard labor.
S2 · Justia · U.S. Reports
S2 ↗Bailey v. Alabama, 219 U.S. 219 (1911)
Six years later, the fraud-presumption 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 · 1905 · CASE
CASE · SELECT A PATH
WHERE THIS CASE SITS.
Peonage is compulsory service based on debt; Congress may punish it everywhere, against anyone.
1905 · CLYATT V. UNITED STATES
Peonage is compulsory service based on debt; Congress may punish it everywhere, against anyone.
It may be defined as a status or condition of compulsory service, based upon the indebtedness of the peon to the master.S1 · Public.Resource.Org · U.S. Reports text ↗
Bailey v. Alabama
Applied the ban on peonage to a state fraud statute.
S2 · Justia · U.S. Reports ↗LIMIT OF THE CONNECTION
Harlan, J., would have let the jury's verdict stand.
▥ GOVERNMENT-ADVANTAGING DOCTRINE
Strict proof of the chargePeonage prosecutions
◈ CITIZEN DOCTRINE
Peonage is a crime everywhereDebt bondage
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 · 1905 · 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 · 1905-03-13SUPREME COURT OF THE UNITED STATES
Debt peonage enforced through state warrants 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
ORIGINLEVY COUNTY, FLORIDA
⇢Florida to Georgia
REACHNATIONAL
national — every peonage prosecution
WHERE THIS EVENT BELONGS
The dispute began in Levy County, Florida.
The scored institution: Debt peonage enforced through state warrants.
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:clyatt-v-united-states |
|---|---|
| Event type | adjudicated_case |
| Location | Levy County, Florida |
| Scale | IV · Institutional · national |
| Direction | +1 · citizen-protective |
| Gravity · Current force | 75 · 65 |
| Method | civic3-gravity-1.0 |
06 / Battle Loot · what each side won and lostUS · 1905 · 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 |
|---|---|---|---|
| 1905-03-13 · Supreme Court of the United States · 197 U.S. 207 (1905) | May Congress punish peonage by individuals in every state under the Thirteenth Amendment? | SPLIT | law upheld; conviction reversed. S1 ↗ |
Split 1 · a count of results, not a score
07 / Method & History · every number, every changeUS · 1905 · 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.
74.8
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 | 85 | 25% | 21.25 | The Supreme Court.S1 ↗ |
| Reach | 80 | 20% | 16.00 | Every state; every individual.S1 ↗ |
| Durability | 85 | 20% | 17.00 | The definition still stands.S1 ↗ |
| Progeny | 80 | 15% | 12.00 | The definition of peonage the later cases in this chain apply.S1 ↗ |
| Cross-domain | 60 | 10% | 6.00 | Labor, debt and criminal process.S1 ↗ |
| Implementation | 25 | 10% | 2.50 | No conviction resulted.S1 ↗ |
| Total | 100% | 74.75 | Displayed as 75 |
CONSTITUTIONAL EFFECT
+29.2
E = Direction × Gravity × Confidence × Current Force
Toward the Thirteenth Amendment's promise in principle; leaning, because the conviction failed.
E = +1 × 75 × 0.6 × 65/100READ 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
The definition and the Act's validity stand.
definition of peonage · controllingStill the definition.S1 ↗
THE FULL SCORE STACK
| Field | This file | Meaning |
|---|---|---|
| Power level /99 | 65 · band 61–69 | From the earlier version (an editorial estimate). |
| Legal / Promise / Divergence | 80 / 38 / 42 | Remedy delivered versus constitutional promise. |
| Battle Power (citizen / institution) | 55 / 48 | Litigation strength of each side, from the five inputs above. |
| Gravity | 75 | All-time constitutional consequence. |
| Current force | 65 | How much of that weight still governs today. |
| Constitutional Effect | +29.2 | 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 · 82Legacy value, carried from the earlier file.S1 ↗
Resistance · 62Legacy 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 · 60Legacy value, carried from the earlier file.S1 ↗
Contestation · 35Legacy value, carried from the earlier file.S1 ↗
Fog · 45Legacy 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 | 65 · band 61–69 | 65 (carried) |
| Legal / Truth / Divergence | 80 / 38 / 42 | 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: 'the first person ever convicted under the Act' and 'the Fifth Circuit certified questions' are not carried (not in the opinion text read). Added the opinion's own words: the warrants were likely a pretext; 'not a scintilla of testimony'.
OPEN RESEARCH ITEMS
Whether Clyatt was the first person convicted under the Act (the old page said so).
The outcome of the new trial.
REVIEW THIS EDITION
Every number, quote and edge on this page can be challenged with a source.