The Pollock v. Williams case in 1943 involved the issue of peonage, a system where debtors are bound in servitude to their creditors until their debts are paid off. The Supreme Court ruled that Florida's statute allowing laborers to be prosecuted for fraud if they accepted employment advances and then failed to carry out the work was unconstitutional as it violated the Thirteenth Amendment prohibiting slavery or involuntary servitude. The court held that such laws were an attempt by states to make non-payment of debt a criminal offense, which would effectively reintroduce peonage abolished after the Civil War. This decision reaffirmed Bailey v Alabama (1911) where similar practices had been struck down.

In the dissenting opinion for Pollock v. Williams, Justice Frank Murphy argued that the majority's decision was a misinterpretation of the Thirteenth Amendment and its implementing legislation. He contended that Florida’s law did not impose involuntary servitude but merely regulated employment contracts in a way similar to other states' laws on fraud or breach of contract. In his view, this case was about an individual who had willingly entered into an employment agreement and then failed to fulfill it, rather than being forced into labor against their will. Therefore, he believed that striking down such laws could potentially undermine many legitimate state regulations on contractual obligations between employers and employees.