Francis Biddle

“ In the matter of control by one over the person of another, the circumstances
under which each person is placed must be determined, i.e., the subservience of the
will of one to the other. Open force, threats or intimidation need not be used to cause
a person to go involuntarily from one place to another to work and to remain at such
work; nor does evidence of kind treatment show an absence of involuntary servitude.
In the United States one cannot sell himself as a peon or slave -- the law is fixed and
established to protect the weak-minded, the poor, the miserable. ”

“ If two or more persons conspire or combine to do any of the
acts outlined above, they are guilty of a conspiracy to deprive
the person, if he is a citizen of the United States, of the free
exercise or enjoyment of the right and privilege secured to him
by the Constitution of the United States to be free from involun-
tary servitude, and are indictable accordingly. ”

“ It is requested that the spelling out of peonage under Section 444 be
deferred in favor of building the cases around the issue of involuntary servitude and
slavery under Sections 443, 51 [,] and 52, disregarding entirely the element of debt. If,
however, it is found that a claimed debt is the basis of the intimidation to compel one
to the service of another, a separate count under Section 444 should be included in the indictment. ”