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Bailey (defendant) entered into a written contract with the Riverside Company (Riverside) in which he agreed to work as a farm hand for $12 per month for a term of one year. Bailey was given $15 in cash as consideration. However, Bailey stopped working after approximately one month and refused to return the $15 to Riverside. Bailey was subsequently charged with a crime. At his criminal trial, the court charged the jury that “the refusal of any person who enters into such contract to perform such act or service, or refund such money, or pay for such property, without just cause, shall be prima facie evidence of the intent to injure his employer, or to defraud him.” Bailey’s request for a different jury instruction was refused and he was found guilty, assessed damages of $15, and a fine of $30. The court further held that if Bailey refused or was unable to pay the fine he would be sentenced to 20 days of hard labor. Bailey appealed and the Alabama Supreme Court affirmed the conviction. The U.S. Supreme Court granted certiorari to review.
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