## Facts

- Joel Thomas Pierce operated the Lone Star Club, a roadside establishment in Bryan County, Georgia, with a bar, dance hall, rooms upstairs, and cabins behind the main building.
- Pierce employed girls and young women as bartenders, waitresses, hostesses, and dance partners.
- Trial evidence showed the women were required against their will to engage in prostitution and other immoral acts at the club.
- Pierce obtained release of two women from state prison by paying their fines and then required them to work at his establishment to repay him.
- Pierce claimed the women owed him debts (including fines, clothing, or advances) and used those asserted debts to compel them to keep working and to prevent them from leaving.
- Witnesses testified Pierce arranged dates with men, collected money, and directed the women to perform.
- Some women complained to local law enforcement and federal authorities that they were being held against their will; warrants were used to help secure their release.
- Pierce was indicted on eleven peonage counts tied to different women; the jury convicted on seven counts and acquitted on four.
- The district court imposed a $500 fine and consecutive eighteen-month prison terms on each count of conviction.

## Issues

1. Whether the evidence was sufficient to prove peonage—compulsory service enforced to satisfy alleged debts—on the counts of conviction.
2. Whether initial voluntary entry into an arrangement to work off a fine or advance prevents a later finding of peonage when continued work is compelled by coercion tied to debt.
3. Whether acquittals on some counts required reversal of convictions on other counts as inconsistent or legally undermining.

## Decision

- The Fifth Circuit affirmed the convictions and consecutive sentences on the counts for which the jury returned guilty verdicts.
- The court held the evidence permitted the jury to find that Pierce forced the women to work against their wills by asserting debts and using those debt claims to compel continued service.
- The court rejected the argument that initial consent to work negated peonage where the proof showed later coercion to keep working for debt.
- The court held the mixed verdicts did not invalidate the convictions; the jury could credit the evidence as to some women and not others.

## Legal Principles

- Peonage is compulsory service to satisfy a debt; it exists when a person is held to labor against their will under the asserted obligation of indebtedness.
- An arrangement that begins voluntarily can become peonage if the employer later uses debt claims and coercion to compel continued labor and restrict departure.
- Separate counts tied to different alleged victims may result in mixed verdicts without requiring reversal, so long as evidence supports each count of conviction.

## Conclusion

The court upheld peonage convictions where the defendant used asserted debts to coerce women into continued involuntary service, including prostitution, and held that initial agreement to work off obligations did not bar liability once coercion for debt was shown.


Pierce v. United States, 146 F.2d 84 (5th Cir. 1944)