アメリカ合衆国憲法修正第13条
Finally, the Court states, "what the state may not do directly, it may not do indirectly." Thus, the creation of a statutory presumption to facilitate convictions for failure to pay a debt that could not be otherwise prosecuted was found to be invalid. Further, the peonage laws of Alabama were found to be contrary to the Thirteenth Amendment to the United States Constitution and therefore unconstitutional.