United States v. Reynolds

235 U.S. 133 (1914)

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United States v. Reynolds

United States Supreme Court
235 U.S. 133 (1914)

EL

Facts

Alabama State Code § 6846 allowed a convict to sign a private labor agreement known as a surety contract. Surety contracts required a convict to perform labor for a private surety who paid the convict’s fines and court costs. If a convict failed to work, the surety could have the convict arrested and imprisoned. Ed Rivers was convicted of larceny under Alabama law. J. A. Reynolds (defendant) paid Rivers’s fine and court costs under a surety contract with Rivers. The surety contract required Rivers to work for Reynolds for almost 10 months to pay off his debt. After one month, Rivers refused to work. Reynolds had Rivers arrested for violating the labor contract. Rivers was convicted of violating the agreement and incurred a larger fine and court costs. To pay his second fine and court costs, Rivers entered into a surety contract with G. W. Broughton (defendant) to work for over 14 months. Had Rivers been sentenced to hard labor for his initial conviction, his sentence would have been approximately two months. Similarly, E. W. Fields was convicted of selling mortgaged property. Broughton paid Fields’s fine and costs as part of a surety contract that required Fields to labor for Broughton for almost 20 months. Fields quit, so Broughton had Fields rearrested. Had Fields been sentenced to hard labor for his initial conviction, he would have had to work a maximum of four months. The solicitor general (plaintiff) alleged the surety contracts constituted involuntary servitude. The federal district court dismissed the claims against Reynolds and Broughton, finding the contracts did not violate the Constitution’s prohibition of involuntary servitude. The solicitor general appealed.

Rule of Law

Issue

Holding and Reasoning (Day, J.)

Concurrence (Holmes, J.)

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