Today in Supreme Court History: January 3

United States v. Gaskin, 320 U.S. 527 (decided January 3, 1944): “Peonage” (abducting someone in debt to you and forcing him to work for you until the debt is paid off) is a Thirteenth Amendment violation and was outlawed in 1867. Here, where the defendant had “arrested” one James Johnson and transported him to another place within Florida, the Court construes what it concedes is confusing language in the peonage statute, and holds that one can be guilty even if the “arrested” person doesn’t perform any actual work (one guesses that Johnson escaped after being transported).

Bailey v. Alabama, 219 U.S. 219 (decided January 3, 1911): Another case related to the abolition of peonage. Here, the Court invalidates on Thirteenth Amendment grounds an Alabama statute that creates a presumption of fraud (a criminal offense) regardless of the mental state of the accused or any mitigating factors if someone makes off with an advance payment for work and neither returns it nor does the work.

Coray v. Southern Pacific Co., 335 U.S. 520 (decided January 3, 1949): man pumping one-man flatcar was not contributorily negligent for failing to see where he was going before hitting train where train itself stopped unexpectedly due to Federal Safety Appliance Act violation (defect in brake line which caused brakes to lock) (this argument would not fly in a rear-end auto case)