North Dakota Constitution

U.S. Const. amend. XIII (“Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.”)

1. W. Fargo Pub. School Dist. v. W. Fargo Ed. Ass'n, 259 N.W.2d 612 (N.D. 1977) (suggesting specific performance for personal service may be unenforceable as a result of constitutional prohibition against involuntary servitude)
2. Clark v. N.D. Workmen's Comp. Bureau, 262 N.W. 249 (N.D. 1935) (“It could not subject the debtor to involuntary servitude. Any penalty which the county might have attempted to impose upon him if he had failed or refused to work for the county, would have been beyond its power to enforce.”)
3. In re Kol, 88 N.W. 273 (N.D. 1901)