A fine becomes a contract
Rivers, fined $15 and $43.75 costs for petit larceny, contracts to work 9 months 24 days for Reynolds at $6 a month.S1 ↗
01 / Verdict · where it standsUS · 1914 · CASE
Outcome · surety system struck
COMPULSION BY THE CONSTANT FEAR OF IMPRISONMENT.
Ed Rivers, convicted of petit larceny, owed a $15 fine and $43.75 in costs. J. A. Reynolds paid as his surety and Rivers contracted to work for him for nine months and 24 days at $6 a month. When Rivers stopped, he was convicted again, and a new surety bound him for fourteen months and fifteen days. The Court held the system violates the Thirteenth Amendment.
Struck the surety system; did not reach convict leasing.S1 ↗ϟ THE CASE IN 20 SECONDS
1WHOThe United States, prosecuting two Alabama sureties under the federal peonage law.
2WHATWhether a state could let private sureties buy a convict's fine in exchange for his labor, enforced by more prosecutions.
3WHY IT MATTERSThe Court struck the surety trap; this file asks what it left standing.
THE FULL CASE FILE · the original write-up, checked
HOW A FINE BECAME A DEEPENING CAGE
Ed Rivers was convicted of petit larceny in Alabama and owed a $15 fine and $43.75 in costs. Under the Alabama Code, J. A. Reynolds became his surety and paid, and Rivers signed a contract to work on Reynolds's farm for nine months and 24 days at $6 a month. In June he stopped. On Reynolds's complaint he was convicted again, fined one cent and $87.05 in costs, and a new surety, G. W. Broughton, bound him for fourteen months and fifteen days. A second worker, E. W. Fields, was bound to Broughton for nearly twenty months. Each escape attempt deepened the trap.
The United States prosecuted the sureties under the federal peonage law; the district court threw the charges out. The Supreme Court reversed. Justice Day held the system in violation of the Thirteenth Amendment: compulsion of service by the constant fear of imprisonment under the criminal laws renders the work compulsory. Justice Holmes, who had dissented in Bailey, concurred.S1 ↗
WIN THE TRAP, NOT THE WAR
Three years after Bailey struck the fraud-presumption trap, Reynolds struck the surety trap. The legal win is real. But the Court struck a mechanism; the wider system of labor extracted after conviction was not before it. That gap is the divergence this file records.S1 ↗
UNITED STATES V. REYNOLDS
♟ CITIZEN LOADOUT · THE UNITED STATES, FOR ED RIVERS AND E. W. FIELDS
⬟
FEAR OF PROSECUTION MAKES LABOR FORCED
Criminal enforcement of a labor debt is compulsion.
♜ INSTITUTION LOADOUT · ALABAMA'S CRIMINAL-SURETY SYSTEM
♜
THE SCORED ACTOR
Alabama's criminal-surety system 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 — Struck the surety system; did not reach convict leasing. McReynolds, J., took no part. Holmes concurred.
AFTERMATH LEDGER
WHY THIS SITS WHERE IT DOES
A ruling without dissent that struck the criminal-surety system and named fear of prosecution as compulsion.
THE THROUGH-LINE
Clyatt defined peonage; Bailey struck the fraud trap; Reynolds struck the surety trap.
77/100
CONSTITUTIONAL GRAVITY
All-time consequence · high. Pointed toward the citizen.
02 / Battle · powers and the battle logUS · 1914 · 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 · THE UNITED STATES, FOR ED RIVERS AND E. W. FIELDS
FEAR OF PROSECUTION MAKES LABOR FORCED
Won
P = 79/99 battle power
♜ INSTITUTION SIDE · ALABAMA'S CRIMINAL-SURETY SYSTEM
CONVICT LEASING UNTOUCHED
Struck
P = 38/99 battle power
SCORE DASHBOARD · THE NUMBERS AS BARS
SUPREME COURT (DAY, J.)
The surety system is peonage. The threat of prosecution makes the labor forced.S1 ↗
HOLMES, J., CONCURRING
Holmes, who dissented in Bailey, concurred here.S1 ↗
BATTLE LOG · THE DECISIVE MOVES
Breach, re-arrest
He stops working; convicted again on Reynolds's complaint, fined 1 cent and $87.05 costs.S1 ↗
A longer contract
Broughton becomes surety; Rivers is bound for 14 months 15 days.S1 ↗
Charges thrown out
The court holds no federal offense charged and the conduct justified by the Alabama Code.S1 ↗
Reversed
Day for the Court; Holmes concurs; McReynolds takes no part.S1 ↗
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 · 1914 · 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 ↗United States v. Reynolds, 235 U.S. 133 (1914)
Day, J., for the Court; Holmes concurring; McReynolds took no part. Argued 23 Oct, decided 30 Nov 1914. Rivers, Reynolds, Broughton, Fields.
S2 · Justia · U.S. Reports
S2 ↗Bailey v. Alabama, 219 U.S. 219 (1911)
The fraud-presumption trap.
S3 · Public.Resource.Org · U.S. Reports text
S3 ↗Clyatt v. United States, 197 U.S. 207 (1905)
The definition of peonage.
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 · 1914 · CASE
CASE · SELECT A PATH
WHERE THIS CASE SITS.
Labor compelled by the constant fear of imprisonment, to pay off a fine a private surety advanced, is peonage.
1914 · UNITED STATES V. REYNOLDS
Labor compelled by the constant fear of imprisonment, to pay off a fine a private surety advanced, is peonage.
…this system is in violation of rights intended to be secured by the 13th Amendment…S1 · Public.Resource.Org · U.S. Reports text ↗
Bailey v. Alabama
The fraud-presumption trap, struck three years earlier.
S2 · Justia · U.S. Reports ↗Clyatt v. United States
The definition of peonage.
S3 · Public.Resource.Org · U.S. Reports text ↗LIMIT OF THE CONNECTION
Holmes concurred.
▥ GOVERNMENT-ADVANTAGING DOCTRINE
Convict leasing untouchedLabor as punishment after conviction
◈ CITIZEN DOCTRINE
Fear of prosecution makes labor forcedFines-and-costs labor schemes
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 · 1914 · 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 · 1914-11-30SUPREME COURT OF THE UNITED STATES
Alabama's criminal-surety system 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
ORIGINALABAMA
⇢Monroe County, Alabama
REACHNATIONAL
national — fines, costs and labor
WHERE THIS EVENT BELONGS
The dispute began in Alabama.
The scored institution: Alabama's criminal-surety system.
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:united-states-v-reynolds |
|---|---|
| Event type | adjudicated_case |
| Location | Alabama |
| Scale | IV · Institutional · national |
| Direction | +1 · citizen-protective |
| Gravity · Current force | 77 · 70 |
| Method | civic3-gravity-1.0 |
06 / Battle Loot · what each side won and lostUS · 1914 · 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 |
|---|---|---|---|
| 1914-11-30 · Supreme Court of the United States · 235 U.S. 133 (1914) | Is Alabama's criminal-surety system peonage forbidden by the Thirteenth Amendment and the federal law? | CITIZEN | surety system struck. S1 ↗ |
Citizen 1 · a count of results, not a score
07 / Method & History · every number, every changeUS · 1914 · 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.
76.8
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 | 90 | 25% | 22.50 | The Supreme Court, without dissent.S1 ↗ |
| Reach | 75 | 20% | 15.00 | Criminal-surety laws in every state.S1 ↗ |
| Durability | 85 | 20% | 17.00 | Never overruled.S1 ↗ |
| Progeny | 65 | 15% | 9.75 | Completes the peonage pair with Bailey.S1 ↗ |
| Cross-domain | 70 | 10% | 7.00 | Fines, court costs and labor.S1 ↗ |
| Implementation | 55 | 10% | 5.50 | The surety prosecutions could proceed; convict leasing was not before the Court.S1 ↗ |
| Total | 100% | 76.75 | Displayed as 77 |
CONSTITUTIONAL EFFECT
+53.7
E = Direction × Gravity × Confidence × Current Force
Toward the Thirteenth Amendment; settled.
E = +1 × 77 × 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 against compelled labor for fines and costs.
surety peonage · controllingStruck.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 | 85 / 49 / 36 | Remedy delivered versus constitutional promise. |
| Battle Power (citizen / institution) | 79 / 38 | Litigation strength of each side, from the five inputs above. |
| Gravity | 77 | All-time constitutional consequence. |
| Current force | 70 | How much of that weight still governs today. |
| Constitutional Effect | +53.7 | 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 · 76Legacy value, carried from the earlier file.S1 ↗
Resistance · 70Legacy 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 · 84Legacy value, carried from the earlier file.S1 ↗
Contestation · 35Legacy value, carried from the earlier file.S1 ↗
Fog · 33Legacy 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 | 85 / 49 / 36 | 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.
[CORRECTED] [QUALIFIED] Prose restored from the legacy page, checked
The old page's write-up is carried into the card's full case file. Corrected: the quote is 'constant fear of imprisonment under the criminal laws' (the old page said 'punishment'); the fine and costs figures and contract terms are now the opinion's. Qualified: 'unanimous' (McReynolds took no part) and 'convict leasing continued into the 1940s' (open research). The 'operation-and-effect test' attributed by the campaign is not carried.
OPEN RESEARCH ITEMS
The county of Rivers's conviction (Monroe County placed approximately).
How long convict leasing continued in Alabama, from a primary source (the old page said into the 1940s).
REVIEW THIS EDITION
Every number, quote and edge on this page can be challenged with a source.