to service or labor under the system known as peonage", specifically banning "the voluntary or involuntary service or labor of any persons as peons, in liquidation of any debt or obligation, or otherwise." In 1939, the Department of Justice created the Civil Rights Section, which focused primarily on First Amendment and labor rights. The increasing scrutiny of totalitarianism in the lead-up to World War II brought increased attention to issues of slavery and involuntary servitude, abroad and at home. The U.S. sought to counter foreign propaganda and increase its credibility on the race issue by combatting the Southern peonage system. Under the leadership of Attorney General Francis Biddle, the Civil Rights Section invoked the constitutional amendments and legislation of the Reconstruction Era as the basis for its actions. In 1947, the DOJ successfully prosecuted Elizabeth Ingalls for keeping domestic servant Dora L. Jones in conditions of slavery. The court found that Jones "was a person wholly subject to the will of defendant; that she was one who had no freedom of action and whose person and services were wholly under the control of defendant and who was in a state of enforced compulsory service to the defendant." The Thirteenth Amendment enjoyed a swell of attention during this period, but from Brown v. Board of Education (1954) until Jones v. Alfred H. Mayer Co. (1968) it was again eclipsed by the Fourteenth Amendment. Penal labor exemption The Thirteenth Amendment exempts penal labor from its prohibition of forced labor. This allows prisoners who have been convicted of crimes (not those merely awaiting trial) to be required to perform labor or else face punishment while in custody. Few records of the committee's deliberations during the drafting of the Thirteenth Amendment survive, and the debate that followed both in Congress and in the state legislatures featured almost no discussion of this provision. It was apparently considered noncontroversial at the time, or at least legislators gave it little thought. The drafters based the amendment's phrasing on the Northwest Ordinance of 1787, which features an identical exception. Thomas Jefferson authored an early version of that ordinance's anti-slavery clause, including the exception of punishment for a crime, and also sought to prohibit slavery in general after 1800. Jefferson was an admirer of the works of Italian criminologist Cesare Beccaria. Beccaria's On Crimes and Punishments suggested that the death penalty should be abolished and replaced with a lifetime