Bailey v. Alabama
E934443
Bailey v. Alabama is a 1911 U.S. Supreme Court decision that struck down a state law effectively criminalizing breach of labor contracts, holding that it violated the Thirteenth Amendment’s prohibition of involuntary servitude.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Bailey v. Alabama canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T11576362 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Bailey v. Alabama Context triple: [United States Supreme Court cases of the White Court, hasNotableCase, Bailey v. Alabama]
-
A.
Swain v. Alabama
Swain v. Alabama was a 1965 U.S. Supreme Court decision that set a high evidentiary bar for proving racial discrimination in jury selection, later overturned by Batson v. Kentucky.
-
B.
Powell v. Alabama
Powell v. Alabama is a landmark 1932 U.S. Supreme Court decision that held in capital cases the Due Process Clause requires defendants be given access to effective legal counsel, especially when they are young, illiterate, or otherwise disadvantaged.
-
C.
Hamilton v. Alabama
Hamilton v. Alabama is a 1961 U.S. Supreme Court decision that held an indigent defendant in a capital case has a constitutional right to counsel at arraignment, treating that stage as a critical point in the criminal process.
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D.
J.E.B. v. Alabama ex rel. T.B.
J.E.B. v. Alabama ex rel. T.B. is a 1994 U.S. Supreme Court case that held peremptory jury strikes based solely on gender violate the Equal Protection Clause.
-
E.
Stone v. Mississippi
Stone v. Mississippi is an 1880 U.S. Supreme Court case in which the Court held that a state cannot irrevocably surrender its police power, allowing Mississippi to prohibit a previously chartered lottery despite contractual claims.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Bailey v. Alabama Target entity description: Bailey v. Alabama is a 1911 U.S. Supreme Court decision that struck down a state law effectively criminalizing breach of labor contracts, holding that it violated the Thirteenth Amendment’s prohibition of involuntary servitude.
-
A.
Swain v. Alabama
Swain v. Alabama was a 1965 U.S. Supreme Court decision that set a high evidentiary bar for proving racial discrimination in jury selection, later overturned by Batson v. Kentucky.
-
B.
Powell v. Alabama
Powell v. Alabama is a landmark 1932 U.S. Supreme Court decision that held in capital cases the Due Process Clause requires defendants be given access to effective legal counsel, especially when they are young, illiterate, or otherwise disadvantaged.
-
C.
Hamilton v. Alabama
Hamilton v. Alabama is a 1961 U.S. Supreme Court decision that held an indigent defendant in a capital case has a constitutional right to counsel at arraignment, treating that stage as a critical point in the criminal process.
-
D.
J.E.B. v. Alabama ex rel. T.B.
J.E.B. v. Alabama ex rel. T.B. is a 1994 U.S. Supreme Court case that held peremptory jury strikes based solely on gender violate the Equal Protection Clause.
-
E.
Stone v. Mississippi
Stone v. Mississippi is an 1880 U.S. Supreme Court case in which the Court held that a state cannot irrevocably surrender its police power, allowing Mississippi to prohibit a previously chartered lottery despite contractual claims.
- F. None of above. chosen
Statements (40)
| Predicate | Object |
|---|---|
| instanceOf |
Thirteenth Amendment case
ⓘ
U.S. constitutional law case ⓘ United States Supreme Court case ⓘ |
| areaOfLaw |
civil rights law
ⓘ
criminal law ⓘ labor law ⓘ |
| citation | 219 U.S. 219 ⓘ |
| constitutionalProvisionInterpreted |
Anti-Peonage Act
NERFINISHED
ⓘ
Thirteenth Amendment to the United States Constitution NERFINISHED ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1911 ⓘ |
| effect | restricted states’ ability to use criminal law to coerce labor performance ⓘ |
| finding |
criminal penalties attached to labor contract breach could amount to involuntary servitude
ⓘ
presumption of fraudulent intent from mere nonperformance of labor contract was unconstitutional when used to compel labor ⓘ |
| fullCaseName | Bailey v. State of Alabama NERFINISHED ⓘ |
| historicalContext | post-Reconstruction regulation of Black labor in the American South ⓘ |
| holding |
Alabama statute criminalizing breach of certain labor contracts violated the Thirteenth Amendment
ⓘ
State may not use criminal law to enforce labor contracts in a way that compels involuntary servitude ⓘ |
| jurisdiction |
State of Alabama
NERFINISHED
ⓘ
United States of America ⓘ
surface form:
United States
|
| languageOfProceedings | English ⓘ |
| legalIssue |
constitutionality of criminal penalties for breach of labor contracts
ⓘ
involuntary servitude under the Thirteenth Amendment ⓘ peonage ⓘ |
| majorityOpinionBy | Charles Evans Hughes NERFINISHED ⓘ |
| party |
Alonzo Bailey
NERFINISHED
ⓘ
State of Alabama NERFINISHED ⓘ |
| precedentFor |
interpretation of involuntary servitude beyond chattel slavery
ⓘ
limits on criminal sanctions for breach of employment contracts ⓘ |
| recognizedAs | landmark Thirteenth Amendment decision ⓘ |
| relatedConcept |
debt peonage
ⓘ
forced labor ⓘ post–Civil War labor control statutes ⓘ |
| result | Alabama conviction reversed ⓘ |
| stateLawInvolved | Alabama statute making failure to perform labor contract prima facie evidence of intent to defraud ⓘ |
| subsequentCitationIn | later Thirteenth Amendment and peonage cases ⓘ |
| timePeriod | Progressive Era NERFINISHED ⓘ |
| typeOfRemedyLimited | criminal enforcement of private labor contracts GENERATED ⓘ |
| vote | 7–2 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Bailey v. Alabama Description of subject: Bailey v. Alabama is a 1911 U.S. Supreme Court decision that struck down a state law effectively criminalizing breach of labor contracts, holding that it violated the Thirteenth Amendment’s prohibition of involuntary servitude.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.