In the Robertson v. Baldwin case of 1896, the U.S Supreme Court ruled that seamen under contract could be compelled to work even if they later chose not to, without this being a violation of the Thirteenth Amendment's prohibition on involuntary servitude. The court held that certain occupations and circumstances necessitated exceptions from strict adherence to constitutional rights for practical purposes. This was based on an understanding that sailors were often unruly and needed discipline; thus their contracts had elements resembling "involuntary servitude". However, it also emphasized such exception should not be used as a cover for abusive practices or inhumane treatment. Therefore, while upholding the constitutionality of laws allowing forcible return of deserting sailors by ship officers (Merchant Seamen Act 1790), it maintained these did not grant unlimited power over them but only what is necessary for maintaining order and discipline onboard.

In the dissenting opinion for Robertson v. Baldwin, Justice Brewer argued that seamen should not be treated as wards of the government and subjected to involuntary servitude under peonage laws. He contended that this was a violation of their Thirteenth Amendment rights which abolished slavery and involuntary servitude except as punishment for crime. Brewer believed that all citizens, regardless of profession, should enjoy equal protection under the law and have their constitutional rights respected by courts at all levels. He further asserted that it was inappropriate for courts to make exceptions based on outdated legal traditions or societal norms; instead they must uphold individual liberties in accordance with modern understandings of justice and equality.