Hodges v. United States
| Hodges v. United States | |
|---|---|
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| Argued April 23–2, 1906 Decided May 28, 1906 |
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| Full case name | Reuben Hodges v. United States |
| Citations | 203 U.S. 1 (more) |
| Prior history | Conviction in United States District Court for the Eastern District of Arkansas; demurrer overruled by Jacob Trieber |
| Holding | |
| Thirteenth Amendment does not authorize Congress to protect labor rights from racially motivated attack | |
| Court membership | |
| Case opinions | |
| Majority | Brewer, joined by Fuller, Brown, White, Peckham, McKenna, Holmes |
| Dissent | Harlan, joined by Day |
| Laws applied | |
| 18 U.S.C. § 241, 42 U.S.C. § 1981 | |
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Overruled by
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| Jones v. Alfred H. Mayer Co., 392 U.S. 409 (1968) | |
Hodges v. United States 203 U.S. 1 (1906) was a decision by the United States Supreme Court limiting the power of Congress to make laws under the Thirteenth Amendment. Three White men had been convicted in the Eastern Arkansas District Court for conspiring against Black sawmill workers. The statute used to convict the men prohibits conspiracy to deprive American citizens of their Constitutional liberties, including the right to make contracts. The Supreme Court overturned the conviction, holding that Congress did not have the right to intervene against racially motivated interference with labor contracts.
On 8 May 1903, Arkansas Attorney General William G. Whipple wrote to U.S. Attorney General Philander C. Knox to announce (and request funding for) investigation of a “white-capping” case. Whipple wrote that an “inferior class of white men feeling themselves unable to compete with colored tenants combined to drive them out of the country.” Knox approved the investigation, responding that the Department of Justice was “alive to the aggressive attitude of such organized bands as those to which you refer, and determined to meet such emergencies with proper and decisive action”.
By October 1903, a grand jury had indicted two groups of White men accused of white-capping. The first case, filed as United States v. Morris, involved a group of 11 men accused of targeting sharecroppers. The second, United States v. Maples, accused 15 men of intimidating Black workers at a lumber mill in Whitehall, Arkansas. The case against them was made primarily under two statutes of the U.S. Code.
§1977 gives “all persons” in the U.S. the same right to make contracts “as is enjoyed by white citizens” :
All persons within the jurisdiction of the United States shall have the same right in every state and territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exactions of every kind, and to no other.
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