Clyatt v. United States

197 U.S. 207 (1905)

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Clyatt v. United States

United States Supreme Court
197 U.S. 207 (1905)

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Facts

Samuel M. Clyatt (defendant) sought and received a magistrate’s warrant for larceny after his former workers, Will Gordon and Mose Ridley, left Georgia for a Florida work camp. Armed with the warrant, Clyatt traveled to Florida to seek out his former employees. When Clyatt found the men, he handcuffed them and put them on a train back to Georgia to return to their former employment. Evidence presented at trial indicated that Gordon and Ridley owed Clyatt money, but no evidence was introduced to show a peonage agreement between the men and Clyatt. Clyatt was indicted for knowingly returning Gordon and Ridley to a state of peonage, or debt slavery, by forcefully returning them to work off their debts to him. The prosecutor (plaintiff) claimed Clyatt’s actions in tracking down the men, handcuffing them, and transporting them back to Georgia to work off their debts violated the Anti-Peonage Act of 1867, §§ 1990 and 5526. A federal district court jury found Clyatt guilty under the Anti-Peonage Act. The court sentenced Clyatt to four years of hard labor. Clyatt appealed. The federal appellate court certified questions to the United States Supreme Court about the constitutionality of the Anti-Peonage Act and its applicability to the facts of the case.

Rule of Law

Issue

Holding and Reasoning (Brewer, J.)

Concurrence/Dissent (Harlan, J.)

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