In United States v. Reynolds, the Supreme Court finds unconstitutional an Alabama law that allows people to pay off the fines of someone convicted of a misdemeanor, thus freeing the convict from jail, on the condition that the convict works to pay off the debt. Finding that the law allows for “involuntary servitude,” the Court notes that the work required to pay the debt can be harsher than if the convict had been sentenced to imprisonment at hard labor in the first place.