In the 1904 case of Holden v. Stratton, the United States Supreme Court was tasked with determining whether a state law that required all able-bodied men to work on public roads for a certain number of days each year or pay a commutation tax was constitutional. The plaintiff, Mr. Holden, argued that this law violated his rights under the Thirteenth Amendment which prohibits involuntary servitude except as punishment for crime. However, the court ruled in favor of Mr. Stratton and upheld the constitutionality of such laws by stating they were within states' police powers to maintain their highways and bridges without resorting to general taxation or debt creation. The court also noted that these types of laws had been common practice since colonial times and did not constitute forced labor but rather civic duties expected from citizens.

In the dissenting opinion for Holden v. Stratton, Justice Harlan disagreed with the majority's decision to uphold a state law that required miners to be paid in cash instead of company scrip. He argued that this violated the Fourteenth Amendment by depriving mining companies of their property without due process of law and denying them equal protection under the laws. According to Justice Harlan, if a miner willingly agreed to accept payment in company scrip as part of his employment contract, then it was not within the state's power to interfere with such private contractual arrangements. He believed that upholding such legislation would open doors for states interfering excessively into private contracts between employers and employees which could potentially harm businesses and economic growth.