The 13th Amendment to the Constitution provides that "[n]either slavery nor involuntary servitude, except as punishment for a crime whereof the party shall have been duly convicted, shall exist within the United States or any place subject to their jurisdiction."  U.S. Const. amend. XIII, § 1.

The United States Supreme Court has observed that requiring convicted prisoners to work without pay does not violate the 13th Amendment's prohibition against involuntary servitude. United States v. Kozminski, 487 U.S. 931, 943-944, 108 S.Ct. 2751, 2760, 101 L.Ed.2d 788 (1988) (“Our precedents reveal that not all situations in which labor is compelled by physical coercion or force of law violate the Thirteenth Amendment.  By its terms the Amendment excludes involuntary servitude imposed as legal punishment for a crime.”). “When a person is duly tried, convicted, and sentenced in accordance with the law, no issue of personage or involuntary servitude arises.” Draper v. Rhay, 315 F.2d 193, 197 (9th Cir.1963).