Clyatt v. United States

Citations

• 197 U.S. 207
• 25 S. Ct. 429
• 49 L. Ed. 726
• 1905 U.S. LEXIS 1211

Syllabus

<p>Peonage is a status or condition of compulsory service based upon the indebtedness of the peon to the master. The service is enforced unless the debt be paid, and however created, it is involuntary, servitude within the prohibition of the Thirteenth Amendment to the Federal Constitution.</p> <p>While the ordinary relations of individuals to individuals are subject to the control of the States and not to that of the General Government, the Thirteenth Amendment grants to Congress power to enforce the prohibition against involuntary servitude, including peonage, and to punish persons holding another in peonage; and §§ 1990, 5526, Rev. Stat. are valid legislation under such power and operate directly on every person violating their provisions whether in State or Territory and whether there be or not any municipal ordinance or state law sanctioning such holding.</p> <p>Conviction cannot be had under an indictment charging defendants with returning certain persons to a condition of peonage unless there is proof that the persons so returned had actually been in such condition prior to the alleged act of returning them thereto.</p> <p>Where the bill of exceptions, after referring to the empanelling of the jury, contains recitals that the plaintiff produced witnesses, followed in each case by the testimony of the witness at the close of all of which there were farther recitals that the parties rested, these statements are sufficient, even in the absence of a technical affirmative recital to that effect, to show that the bill of exceptions contains all the testimony, and defendant is not to be deprived of a full consideration of the question of his guilt by such omission; and even in the absence of a motion to instruct the jury to find for the defendant this court may examine the question where it is plain that error has been committed.</p> <p>No matter how severe may be the condemnation due to the conduct of a party charged with crime, it is the duty of the court to see t