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“ From this expression, we must admit that liberty was given to all the people at the time of adoption of the Declaration of Independence; this must be so, because it is not within the breast of any man to assume for a moment, that the president would enforce a policy inconsistant with the accepted law; and the Declaration of Independence being the supreme law directing individual liberty to all men in 1776, it remained law, and was law all the years afterwards, even though the system of involuntary servitude continued its operation throughout the country ”

“ These plaintiffs ask this Court to employ its inherent power to the solution of the problem presented by the terms of the bill of complaint. This case presents the simple question of having the Court to declare a lien on certain money, which money is the only remaining fruit of labor performed by plaintiffs, for which labor, there was no compensation paid plaintiffs: It is not overlooked, that liens for specific labor, are usually based upon certain specific conditions and contractural specifications, and usually are addressed to courts of law. ”

“ The question may present itself, whether these persons, who at a time, when by virtue of the then prevailing system throughout the country were not regarded as capable of contracting or being heard. in any manner whatever in consideration of their rights as persons entitled to legal notice, either in the courts of the country then, or otherwise, even though they were compelled to produce this cotton under this system; can they now even though emancipated from all disabilities come into court and request relief for labor extorted from them under this system. ”

“ It must be admitted that the labor of these plaintiffs produced the cotton; that some persons were made prosperous and happy thereby; and at the same time did not pay these laborers any compensation for this happiness and prosperity they enjoyed: It must be admitted further that this labor was certain and specific in the deal of enjoyment and comfort to some persons; these facts are willingly admitted by every one. It must not be overlooked, however, that these people were never consigned to the fate of this system with their free will ”

“ The country contends that the law is unconstitutional; and these plaintiffs contend the same thing; and the law being void, then the money which has been accumulated as result of enforcement of this void law, is assailed by these plaintiffs because the cotton from which this money came was raised and produced and manufactured for market purposes by these plaintiffs, and they did this labor under duress and force, by an illegal system, and all the fruit which they see of this unpaid-for labor, is this money which is fruit of that labor ”

“ The plaintiffs approach the presentation of their case to this Honorable Court, with becoming conciousness of the importance of the relief sought by the terms of their bill; Courts of Equity are clothed with power and authority to relive wrongs, wherein the terms of the law fall short. ”

“ The contention on part of these plaintiffs is, that it is the purpose of all political communities, where civilized conduct obtains, that wherever one man obtains the service and labor of another, for lawful and beneficial purposes to be enjoyed by the party obtaining such benefits, being the fruits of the toil of the laboring party in absence of performance thereof as penalty for crime, the laboring party must be indemnified for such labor by way of compensation therefor from the party so benefitted ”

“ The very circumstances under which our national life was created serves as a lesson which examplifies the truth, that in America, there is no condition, however [p11] complex, that there is not a way to the house of justice. ”

“ A settlement of this question must certainly determine the right of these plaintiffs to recover in a court of [p12] equity. To arrive at the equity in this character of case, we must reason out some of the events which transpired and thus come to a conclusion satisfactory to a reasonable mind as to the fairness justice and equity of plaintiffs' contention. ”

“ Before the statute could apply in this case as suggested by the motion of the defendant, the bill must have shown to the defendant by its terms alone, that the laber sued for, was labor performed under some known legally permitted scheme of industry; that the plaintiffs [p16] were performing this labor under some agreement ”