of enslavement for the worst criminals; Jefferson likely included the clause due to his agreement with Beccaria. Beccaria, while attempting to reduce "legal barbarism" of the 1700s, considered forced labor one of the few harsh punishments acceptable; for example, he advocated slave labor as a just punishment for robbery, so that the thief's labor could be used to pay recompense to their victims and to society. Penal "hard labor" has ancient origins, and was adopted early in American history (as in Europe) often as a substitute for capital or corporal punishment. Various commentators have accused states of abusing this provision to re-establish systems similar to slavery, or of otherwise exploiting such labor in a manner unfair to local labor. The Black Codes in the South criminalized "vagrancy", which was largely enforced against freed slaves. Later, convict lease programs in the South allowed local plantations to rent inexpensive prisoner labor. While many of these programs have been phased out (leasing of convicts was forbidden by President Franklin Roosevelt in 1941), prison labor continues in the U.S. under a variety of justifications. Prison labor programs vary widely; some are uncompensated prison maintenance tasks, some are for local government maintenance tasks, some are for local businesses, and others are closer to internships. Modern rationales for prison labor programs often include reduction of recidivism and re-acclimation to society; the idea is that such labor programs will make it easier for the prisoner upon release to find gainful employment rather than relapse to criminality. However, this topic is not well-studied, and much of the work offered is so menial as to be unlikely to improve employment prospects. As of 2017, most prison labor programs do compensate prisoners, but generally with very low wages. What wages they do earn are often heavily garnished, with as much as 80% of a prisoner's paycheck withheld in the harshest cases. In 2018, artist and entertainer Kanye West advocated for repealing the Thirteenth Amendment's exception for penal labor in a meeting with President Donald Trump, calling the exception a "trap door". In late 2020, Senator Jeff Merkley (D-OR) and Representative William Lacy Clay (D-MO) introduced a resolution to create a new amendment to close this loophole. Judicial interpretation In contrast to the other "Reconstruction Amendments", the Thirteenth Amendment was rarely cited in later case law. As historian Amy Dru Stanley summarizes, "beyond a handful of landmark rulings striking down debt