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The Case of Mary Clark, A Woman of Colour

Indiana Supreme Court
1 Blackf. 122 (1821) (1821)
ELI5:

Rule of Law:

Compelling a person to perform a contract for personal services against their will constitutes involuntary servitude, which is prohibited by the state constitution, regardless of whether the person initially entered the contract voluntarily.


Facts:

  • Mary Clark, a free woman of color, voluntarily executed an indenture on October 24, 1816, in Vincennes, Indiana.
  • The indenture bound her to serve G.W. Johnston as an indented servant and house maid for a term of 20 years.
  • At some point after the indenture was signed, Clark's service became involuntary.
  • Clark sought to be released from Johnston's service, indicating she no longer wished to be bound by the indenture.

Procedural Posture:

  • Mary Clark petitioned the Knox Circuit Court for a writ of habeas corpus to be released from the custody of G.W. Johnston.
  • Johnston responded, asserting the 20-year indenture as the legal basis for her detention.
  • The Knox Circuit Court (the trial court) found the cause of detention sufficient and remanded Clark to Johnston's custody.
  • Clark, as the appellant, appealed the trial court's decision to the Indiana Supreme Court.

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Issue:

Does holding an individual to a contract for personal service against their will constitute involuntary servitude prohibited by the Indiana Constitution, even if the individual voluntarily executed the indenture?


Opinions:

Majority - Holman, J.

Yes. Holding an individual to a contract for personal service against their will constitutes prohibited involuntary servitude. The court reasoned that while Clark initially entered the indenture voluntarily, her application to be discharged is clear evidence that the service is now involuntary. The Indiana Constitution forbids involuntary servitude, and the court cannot create a legal fiction that her service is voluntary when the facts show otherwise. The common law does not recognize the specific performance of personal service contracts because it would create a state of degradation and irritation similar to slavery. Distinguishing this case from apprenticeships, which involve minors without full legal will, the court found that Clark is an adult with the right to exercise her own volition. Therefore, because her service is factually involuntary, the constitution requires her discharge.



Analysis:

This case is a landmark decision in early American law establishing that personal liberty outweighs contractual obligations for labor. It interprets the constitutional prohibition on 'involuntary servitude' broadly to include service that becomes involuntary, even if it originated from a voluntary agreement. This ruling effectively outlawed indentured servitude in Indiana and set a strong precedent against the specific performance of personal service contracts. Future courts would rely on this principle to limit remedies for breach of employment contracts to monetary damages, rather than compelling a person to work against their will.

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