Does the Thirteenth Amendment ban on involuntary servitude apply to employment undertaken to meet a parent's child support obligation?

[950 P.2d 68] The United States Supreme Court has consistently recognized that the Thirteenth Amendment does not prevent enforced labor as punishment for crime, and does not prevent state or federal governmental entities from compelling the performance of civic duties such as jury service (Hurtado v. United States (1973) 410 U.S. 578, 589, fn. 11, 93 S.Ct. 1157, 1164, n. 11, 35 L.Ed.2d 508), military service (Selective Draft Law Cases (1918) 245 U.S. 366, 390, 38 S.Ct. 159, 165, 62 L.Ed. 349), ⁹ and road work (Butler v. Perry (1916) 240 U.S. 328, 333, 36 S.Ct. 258, 259, 60 L.Ed. 672). A parent's obligation to support a minor child is a social obligation that is no less important than compulsory military service, road building, jury service and other constitutionally permissible enforced labor. Even if the necessity of accepting employment in order to meet this obligation were somehow analogous to those forms of compelled labor, we have no doubt that this form of labor would be recognized as an exception to the ban on involuntary servitude found in the Thirteenth Amendment. It is clear to us, however, that employment undertaken to meet a child support obligation is not analogous to government-controlled labor and does not otherwise create a condition of peonage or slavery. Unlike those recognized exceptions to the Thirteenth Amendment in which labor is compulsory, undertaking employment because an income is necessary to enable a parent to comply with a valid court order to support a child does not impose on the parent any government control over the type of employment, the employer for whom the parent's labor will be performed, or any other aspect of the parent's individual freedom that might be associated with peonage or slavery.