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Contracts Keyed to Barnett
Bailey v. State of Alabama
Facts
Bailey (Defendant) and Riverside Company (Riverside) entered into a contract in which Defendant agreed to work for $12/month for one year as a farm hand. As consideration for the agreement, Defendant was given $15 in cash. After one month of working, Defendant refused to continue working and refused to return the cash to Riverside. Afterwards, Defendant was charged with a crime. At trial, the court told the jury the following: “[T]he 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.” As such, Defendant requested a different jury instruction, which was refused by the court. Defendant was found guilty for damages of $15 and a fine of $30. In addition, if Defendant refused to pay or was unable to pay the fine, the court held that Defendant would be sentenced to 20 days of hard labor. Defendant appealed to the Alabama Supreme Court, which affirmed the conviction. The United States Supreme Court granted certiorari.
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