## Facts

- Louis Pouliot, an able-bodied husband and father of six minor children in Holyoke, Massachusetts, had no employment or income apart from municipal welfare relief.
- The city welfare department conditioned continued relief on his making himself available for public-relief work through the public works department.
- The work arrangement did not guarantee a fixed wage or a definite rate of compensation beyond the relief furnished.
- Pouliot refused the work, stating he wanted employment with a definite wage, and claimed the condition would amount to involuntary servitude under the Thirteenth Amendment.
- The Commonwealth charged him under a Massachusetts criminal nonsupport statute with unreasonably neglecting to provide support for his wife and children.

## Issues

1. Whether convicting an able-bodied husband and father of criminal nonsupport, based on refusal to accept municipally arranged relief work lacking a definite wage, violates the Thirteenth Amendment prohibition on involuntary servitude.

## Decision

- The Supreme Judicial Court sustained the finding of guilt and rejected the Thirteenth Amendment challenge.
- The court held that enforcing a husband’s and father’s preexisting legal duty to support his dependents, including through reasonable work opportunities tied to relief, is not involuntary servitude.
- The reported legal question was resolved for the Commonwealth, leaving the nonsupport conviction in place.

## Legal Principles

- A husband and father has a longstanding legal duty to support his wife and minor children; criminal nonsupport statutes may enforce that duty.
- The Thirteenth Amendment targets slavery and practices akin to slavery; enforcement of familial support obligations through criminal law is not within that prohibition.
- Conditioning public relief on availability for reasonable work does not relieve an able-bodied recipient of the obligation to support dependents and does not create unconstitutional compulsion.
- A preference for different employment terms (including a definite wage) does not excuse unreasonable neglect of family support when reasonable work is available to meet that obligation.

## Conclusion

The court upheld a criminal nonsupport conviction where an able-bodied father refused municipal relief work offered as a condition of assistance, holding that compelling compliance with family-support duties does not constitute involuntary servitude under the Thirteenth Amendment.


Commonwealth v. Pouliot, 292 Mass. 229, 198 N.E. 256 (Mass. 1935)