The U.S. Supreme Court case Butler v. Perry, in 1915, revolved around the constitutionality of a Florida statute that required able-bodied men between the ages of 21 and 45 to work on public roads for up to six days each year or pay an alternative tax. The plaintiff, Butler, argued that this law violated the Thirteenth Amendment's prohibition against involuntary servitude. However, the Supreme Court disagreed with his argument and upheld the validity of such statutes as they were seen as a valid exercise of state police power necessary for public welfare and safety. The court held that compulsory labor under these circumstances did not equate to "involuntary servitude" prohibited by the Constitution because it was part of citizens' civic duty towards their community.

In the dissenting opinion for Butler v. Perry, Justice Holmes argued that the Florida statute requiring able-bodied men to work on public roads for a certain number of days each year or pay a commutation tax was unconstitutional. He believed it violated both the Thirteenth Amendment's prohibition against involuntary servitude and Fourteenth Amendment's Equal Protection Clause. Holmes contended that compulsory labor is akin to slavery unless used as punishment for crime or in cases of military draft during war times. Furthermore, he asserted that this law unfairly targeted poor individuals who could not afford to pay the tax and were therefore forced into labor, violating their right to equal protection under law.