The 13th Amendment banned not just chattel slavery but also "involuntary servitude" -- any arrangement where someone is forced to work against their will through violence, threats, or legal coercion. In Bailey v. Alabama (1911), the Supreme Court struck down an Alabama law that let landowners force sharecroppers to work off debts or face criminal charges, ruling it was involuntary servitude dressed up as contract law. In United States v. Kozminski (1988), the Court defined the term as forced labor through "the use or threat of physical restraint or physical injury, or by the use or threat of the law or the legal process." One major exception exists: the amendment's text explicitly permits involuntary servitude "as a punishment for crime." Courts have consistently upheld mandatory prison labor under this exception, and today most incarcerated people in the United States are required to work in jobs ranging from food service to manufacturing, often for pennies per hour. Several states have moved to close that loophole -- voters in Alabama, Tennessee, Vermont, and Oregon have amended their state constitutions since 2022 to ban slavery and involuntary servitude without exception.