## Facts

- Samuel M. Clyatt, associated with a lumber operation, was accused of forcibly taking Will Gordon and Mose Ridley and compelling them to work to satisfy an alleged debt to Clyatt’s firm.
- A federal indictment charged two counts under Revised Statutes § 5526: (1) unlawfully and knowingly returning Gordon and Ridley to a condition of peonage; and (2) aiding and causing their return to peonage.
- The prosecution theory treated the men’s alleged debt as the basis for compelled labor and characterized the conduct as peonage.
- A jury convicted Clyatt, and he was sentenced under § 5526.
- The federal court of appeals affirmed the conviction.
- The Supreme Court reviewed the case and evaluated both the scope of the federal anti-peonage statutes and whether the evidence matched the indictment’s “returning” charge.

## Issues

1. Whether Congress, under the Thirteenth Amendment, may prohibit and criminally punish peonage by private individuals within the states.
2. What “peonage” means for purposes of the Thirteenth Amendment and federal statutes barring involuntary servitude.
3. Whether a conviction for “returning” a person to peonage can stand without proof that the person was previously in a condition of peonage.
4. Whether the Supreme Court could review evidentiary sufficiency despite record-format objections and the absence of a directed-verdict motion.

## Decision

- The Supreme Court unanimously reversed and remanded.
- The Court upheld Revised Statutes §§ 1990 and 5526 as valid enforcement legislation under the Thirteenth Amendment that operates directly on private persons, in states and territories, regardless of state authorization.
- The Court defined peonage as a status of compulsory service based on indebtedness, constituting involuntary servitude within the Thirteenth Amendment.
- The Court held the evidence was insufficient to support an indictment charging “returning” to peonage because there was no adequate proof that Gordon and Ridley had previously been in peonage.
- The Court treated the bill of exceptions as containing all the evidence and reached the sufficiency question despite procedural objections.

## Legal Principles

- Peonage is a status or condition of compulsory service based on indebtedness to a master; enforced labor to satisfy a debt is involuntary servitude forbidden by the Thirteenth Amendment.
- Congress’s Thirteenth Amendment enforcement power permits federal legislation prohibiting and punishing peonage committed by private individuals, not merely state-sponsored systems.
- A criminal charge for “returning” a person to peonage requires proof of a prior peonage condition; the term “return” presupposes a previous status.
- Appellate review may reach plain error and evidentiary sufficiency in a criminal case when the record reasonably shows the evidence presented, even without technical certification or a directed-verdict motion.

## Conclusion

The Court confirmed broad federal power to suppress peonage as involuntary servitude under the Thirteenth Amendment but reversed Clyatt’s conviction because the indictment’s “returning to peonage” theory required proof of prior peonage that the evidence did not establish.


Clyatt v. United States, 197 U.S. 207 (1905)