## Facts

- Black citizens worked as laborers at a lumber mill in White Hall, Arkansas under employment arrangements with the mill operator.
- A group of white defendants allegedly conspired to force the Black workers to stop working and abandon their employment by threats and intimidation, including acting in a group at the worksite.
- Federal prosecutors indicted the defendants for conspiring to oppress and intimidate the workers in the exercise of federally secured rights, characterizing the right to make and carry out labor contracts as protected by the Thirteenth Amendment and federal civil-rights and conspiracy statutes (Revised Statutes §§ 1977–1979, 5508, 5510).
- The district court rejected the defendants’ jurisdictional and constitutional objections, and a jury convicted them.
- The defendants sought Supreme Court review, arguing Congress lacked constitutional authority to criminalize this private, intrastate conspiracy.

## Issues

1. Whether the Thirteenth Amendment’s enforcement power permits Congress to criminalize a purely private conspiracy aimed at preventing Black citizens from making or carrying out labor contracts.
2. Whether federal civil-rights and conspiracy statutes could be applied to private, racially motivated interference with employment absent state involvement.

## Decision

- The Supreme Court reversed the convictions.
- The Court held that the Fourteenth and Fifteenth Amendments address state action and did not support federal jurisdiction because the indictment alleged no state involvement.
- The Court held that the Thirteenth Amendment, as construed, did not authorize federal punishment of private interference with labor contracts that did not amount to slavery or involuntary servitude.
- The Court concluded federal courts lacked jurisdiction over the charged conspiracy.

## Legal Principles

- The Fourteenth and Fifteenth Amendments operate on state action, not purely private conduct.
- The national government is one of enumerated powers; absent a constitutional grant, regulation of private violence and contract interference remains primarily a matter of state law.
- The Thirteenth Amendment’s enforcement power reaches slavery and involuntary servitude (understood as compelled service), and does not create general federal authority to punish all private, racially discriminatory interference with civil rights such as contracting.
- Federal civil-rights and conspiracy statutes cannot be applied to a private conspiracy to prevent Black citizens, because of race, from making or carrying out labor agreements when the conduct is not legally equivalent to slavery or involuntary servitude.

## Conclusion

The Court set aside federal convictions arising from a private conspiracy to drive Black workers from employment, ruling that—without state involvement and absent conduct amounting to slavery or involuntary servitude—Congress lacked Thirteenth Amendment authority to make the conspiracy a federal crime.


Hodges v. United States, 203 U.S. 1 (1906)