This is a case that I taught for the first time today (in Admiralty). The case involved a sailor who attempted to leave a merchant ship before the end of the voyage and, in effect, quit. The vessel, relying on a federal stature, had the sailor jailed and then forced him to return to work. He sought habeas corpus, claiming that this remedy violated the Thirteenth Amendment.
The Court, in an opinion by Justice Brown, rejected this claim on the ground that the vessel’s action was sustained by longstanding maritime custom and that the Thirteenth Amendment did not disturb that practice. Justice Harlan dissented, arguing that this was a form of involuntary servitude. Note that this was the same lineup as in Plessy v. Ferguson (Brown writing for the Court and Harlan dissenting alone) and also involving a Thirteenth Amendment claim.
Moreover, Robertson was the first Supreme Court that called the first ten amendments the Bill of Rights. I noted that in my 2018 book on the Bill of Rights, but until today I never thought about the parallel with Plessy.
