Freedom suit

An animation showing when United States territories and states forbade or allowed slavery, 1789–1861.

Freedom suits were lawsuits filed by enslaved people against slaveholders asserting their right to freedom.

The right to petition for freedom descended from English common law and allowed people to challenge their enslavement or indenture. Petitioners challenged slavery both directly and indirectly even if slaveholders generally viewed petitions as the exception that proved the rule and as a means to uphold rather than undermine slavery. Slave states, colonies and territories enacted slave laws that created a legal basis for “just subjection.” Their codes also provided for enslaved persons to sue on the basis of wrongful enslavement. While cases were tried during the colonial period, the majority of petitions for freedom were heard during the antebellum period in border or southern states. After the American Revolution, most northern states had abolished slavery, and the United States Congress prohibited it in some newly established territories.

In Saint Louis, Missouri nearly 300 petition cases were filed between 1807 and 1860 and in Washington, D.C. nearly 500 petition cases were filed in the same period. A large portion of cases, as much as one-third, either never went to trial or were settled out of court. In the early nineteenth century in St. Louis and in Washington, D.C., nearly half of the attorneys at the bar may have acted as counsel for slave petitions. Gradually, after the 1830s the number of petition cases declined and the number of attorneys grew. But from 1800 to 1830 most of the bar in these cities tried a petition case.[1]

Recognizing the growing number of manumissions and petition cases being filed in the decades prior to the Civil War, most southern states began to make petitioning more difficult. Maryland, for example, in 1796 required that county courts serve as the court of original jurisdiction, rather than the General Court of the Western Shore, an appellate court. The county courts clearly would be more favorable to the interests and views of local planters against whom these suits were often filed. In Virginia in 1798 the legislature banned those with antislavery sympathies from serving on juries in freedom suits. Maryland did so in 1796. Until the Civil War brought an end to slavery thousands of freedom suits were tried in state courts across the country, with some slaves petitioning as high as the Supreme Court.

History

Colonial petitions for freedom

The act of writing petitions asking the courts for freedom has been a practice within North America dating back to the late 1600s. Some of the first petitions for freedom were not directed at the courts, but to the various colonial joint stock companies such as the Dutch West India Company. During the early importation of enslaved laborers the West India Company had no strict laws governing their status and condition. Enslaved persons were allowed to marry and raise families as long as they continued to work for the company. In this regard, many early petitions were concerned with obtaining freedom for nuclear families, a trend that continues through antebellum petitions.

One of the earliest petitions on record dates back to 1644. A group of eleven petitioners, not including their children, entreated the Council of New Netherland for their freedom on the claim that it was impossible for them to support their growing families under slavery. The Dutch West India Company released these slaves on a plan of half-freedom; this allowed slaves their liberty in exchange for an annual tributary to the company.[2] During early America and the first two decades of the colonial period freedom was not yet strictly associated with race and the Dutch West India Company freed many slaves between 1644 and 1664 when they lost control of the colony to England. These early petitioners did not base their claim for freedom on bloodline but on the monetary realities of living in slavery and caring for a family. This line of argument quickly faded from the records and as the African race becomes entwined with the American construction of slavery. Over the next decades petitioners focused on proving their right to liberty through hereditary freedom claims.

Suits for freedom during and after the Revolution

During the years leading to the Revolutionary War there was a rise in freedom suits submitted in Northern states such as Connecticut, Massachusetts, and New Hampshire. Many of these cases referred to the highly significant case of Somerset v. Stuart in 1772. The ruling in the Somerset case held that slavery was inhumane and illegal on British soil. Lord Mansfield’s opinion in the case was widely read and commented on in the colonies. Slavery, Lord Mansfield ruled, had no basis in "natural law" and could only be maintained through "positive law." As such, slavery did not exist in England and no person on English soil could be held in bondage. Slaves in Virginia and Maryland knew of the Somerset decision and in the months and years following used it as a weapon against their enslavement.

Sir William Blackstone, the leading authority on English law and a professor at the University of Oxford, had already published his Commentaries on the Laws of England in which he laid down the most complete argument to date that slavery was incompatible with free societies. Although admitting that slavery might have a legal basis in the colonial plantation societies of the Atlantic World, Blackstone wrote, "pure and proper slavery does not, nay cannot, subsist in England; such I mean, whereby an absolute and unlimited power is given to the master over the life and fortune of the slave. And indeed it is repugnant to reason, and the principles of natural law, that such a state should subsist any where."[3]

On January 6, 1773, the first of five appeals written during the year, asking for a range of rights, was submitted by black petitioners to Governor Hutchinson and the General Court of Massachusetts.[4] Though signed by only one man, a slave named Felix, the document petitioned for the freedom and rights of all slaves in the Massachusetts colony. While the tone of the petition is cautious it speaks to the “unhappy State and Condition” in which enslaved persons are forced to live.[4] The petition later went on to be published as a pamphlet along with letters and other abolitionist documents. Felix’s petition represented the talk of freedom, liberty and the pursuit of happiness that was circulating around Massachusetts, and other American colonies, before the American Revolution. No record of a response from the Massachusetts General Court exists and, since slavery was never outlawed in the Massachusetts Constitution, it is believed that Felix never earned his freedom.

With the outbreak of war, thousands of blacks made their way to freedom during the Revolution. Enslaved persons during these years found their freedom through military service, petitions for freedom and by those revolutionist who fully embodied the ideal that “every man is created equal” and manumitted their slaves. At the end of the war over 5,000 enslaved Africans had fought with the Continental Army and joined the new America as free men, vastly increasing the number of free black people in the newly formed states.[5] The presence of free blacks altered the prevailing racial categories. Previously the color of one’s skin was associated with slavery, black indicating enslaved and white indicating free. After the Revolution when tens of thousands of African Americans gained their freedom, either by volunteering or manumission, racial enslavement appeared inconsistent. Free blacks appeared to subvert the logic of racially based enslavement.[6]

During the years after the revolution from 1780 to 1804.[5] Pennsylvania, Connecticut, New Hampshire, Rhode Island, New York, and New Jersey created emancipation plans that would outlaw slavery in the states by 1809. Southern states enacted manumission laws and allowed slaveholders to free their enslaved laborers under certain circumstances. Maryland’s 1796 law was typical: slaveholders could only manumit healthy enslaved people under the age of 45 who would not become a public charge. Over the nineteenth century southern lawmakers became increasingly concerned with writing stricter definitions of the boundaries of race as a means to solidify slavery and equate blackness with enslavement. At the same time African Americans attempted to resist these racialized definitions of freedom. Petitions were one of the most powerful strategies to redefine racial categories, claim freedom, and reconstitute families in the face of enslavement.

Arguments for freedom

Petitions for freedom were lawsuits filed by enslaved persons against slaveholders asserting their right to freedom. The right to petition for freedom descended from English common law and allowed people to challenge their enslavement or indenture. While cases were tried during the colonial period, the majority of petitions for freedom were heard during the antebellum period.[7] Petitioners used a variety of arguments to obtain their freedom.

Manumission

Petitioners for freedom often claimed that a promised manumission had not been fully executed. Beginning in the 1790s manumission liberated an unprecedented number of African Americans in Maryland and Virginia. Historians have explained the large number of manumissions in three ways: as a consequence of Revolutionary ideals, religious fervor, and depressed crop prices in the Upper South and demand for slave labor in Georgia and the cotton frontier. Historians have examined wills and deeds of manumission and found that a just a small percentage (under 5%) mention Revolutionary ideals as a motivation. Religious motivations were also relatively insignificant. Instead, manumission was a tool slaveholders used to maintain a variegated labor force. Manumission provided a means for slaveholders to retain and control labor. With as much as two-thirds of manumissions structured as “term slavery,” it is not surprising that many of these arrangements became contested and some of them in the courts.[8] For an example of a freedom suit with a dispute over “term slavery,” see Lizette Lee et al. v. Augustus Preuss and related cases in the Circuit Court of the District of Columbia.[9]

Illegal importation

There were numerous laws on the books of various states that could affect the freedom status of enslaved people. One of these was Maryland Act of Assembly 1796, Chapter 67. Under the law, any enslaved person brought into the state whose owner intended to sell him or her would be granted freedom. However, a proviso was attached to the law stating that any person who intended to settle in Maryland was lawfully able to import his slaves from out of state so long as his slaves remained in the state for three years. If they were removed from the state before the three years has elapsed, the slaves would be granted freedom. Along with creating legal opportunities for slaves to gain freedom, the 1796 Maryland Act of Assembly also secured petitioners the right “to have the benefit of a trial by jury.” With this right, enslaved persons were given the power to petition their owners in court based on their illegal transport in or out of the state.[10]

A similar law was present in Virginia. Under the Act of Assembly of Virginia Act of 1785, Chapter 77, enslaved persons who were born in another state and brought into Virginia after the date of the act would be freed after spending one year in the state. The act provided an exception to this rule, stating that if a slaveholder were to bring slaves into Virginia, he had to make an oath within sixty days of his arrival that he had not imported his slaves from out of the country, and had not brought them into Virginia with the intention of selling them.[11]

Many petitions for freedom were filed based upon violations of these acts of assembly governing the importation of enslaved people. For an example of a freedom suit with a dispute over “term slavery,” see Matilda Derrick v. George Mason & Alexander Moore in the Circuit Court of the District of Columbia.[12]

Familial descent from a free woman

In 1662, Virginia enacted a law of hereditary slavery that stated a child born to an enslaved mother inherited her status as a slave. Other Southern states followed Virginia’s lead and assumed the same maternal inheritance of slavery. Dozens of petitions for freedom were filled on the basis that the petitioner was descended from a free woman, and so, by law, was entitled to freedom.[13] For an example of a freedom suit based upon the free status of a mother, see John Davis v. Hezekiah Wood in the Circuit Court of the District of Columbia.[14]

Filing suit

Thousands of petition cases were tried in state courts across the country. In Saint Louis, nearly 300 petition cases were filed between 1807 and 1860. In Washington, D.C., nearly 500 petition cases were filed in the same period. Often jurors decided in favor of the enslaved. In fact, slaves gained freedom in 37 percent of the cases in Saint Louis. A large portion of cases, as much as one-third, either never went to trial or were settled out of court.[15]

To file petitions for freedom, enslaved plaintiffs demonstrated an impressive knowledge of their rights and an equally impressive sense of calculated risk. For the most part, persistence paid off and petitioners who filed multiple suits were more likely to eventually succeed. Petitioners retained preeminent attorneys, such as Francis Scott Key, Richard Ridgely, John Law, William Wirt, Gabriel Duvall, and John Johnson.[16] During the early nineteenth century in St. Louis and in Washington, D.C., nearly half of the attorneys at the bar may have acted as counsel for slave petitions. After the 1830s, the number of petition cases gradually declined and the number of attorneys grew. But from 1800 to 1830, most of the bar in these cities tried a petition case.[1]

Recognizing the growing number of manumissions and petition cases, most southern states began to make petitioning more difficult. For example, in 1796, Maryland required that county courts serve as the court of original jurisdiction for petition for freedom cases, rather than the General Court of the Western Shore, an appellate court. The county courts clearly would be more favorable to the interests and views of local planters against whom these suits were often filed. In Virginia in 1798, the legislature banned those with antislavery sympathies from serving on juries in freedom suits. Maryland did so in 1796.

Applicable laws

1662 Virginia Act of Assembly

Whereas some doubts have arisen whether children got by any Englishman upon a Negro woman should be slave or free, be it therefore enacted and declared by this present Grand Assembly, that all children born in this country shall be held bond or free only according to the condition of the mother; and that if any Christian shall commit fornication with a Negro man or woman, he or she so offending shall pay double the fines imposed by the former act.[17]
Paul Heinegg, in his Free African Americans in Virginia, North Carolina, South Carolina, Maryland and Delaware (1995–2005) has traced the majority of families of free people of color in the early federal period, to families formed in colonial Virginia from unions between white women and African or African-American men among the working class, where free, indentured servants and slaves lived and worked near each other. While illegitimate mixed-race children of white mothers were bound to lengthy terms as apprentices, they still had gained the important status of free birth and the women's descendants were free.[19]

1785 Virginia Act of Assembly

1795 Virginia Act of Assembly

1796 Maryland Act of Assembly

District of Columbia courts

Located to connect the northern and southern portions of the United States, Washington, D.C., provided a unique venue for freedom suits due to its blending of both Maryland and Virginia law. Because the District comprised portions of Maryland and Virginia, the laws of both states were in effect within those regions of Washington. The District was divided into two counties, the portion lying east of the Potomac River was known as the County of Washington; the other part called the County of Alexandria.[22]

Since its formation in 1790, slavery was legal and existed prominently in the capital. The District of Columbia was the center of the domestic slave trade during the eighteenth century due to its ports in the Potomac River.[23] However, the number of slaves declined over the next five decades from approximately 6,400 slaves in 1820 to 3,100 by 1860.[24] As the number of slaves decreased, the population of free blacks grew, and by 1860, free blacks out-numbered slaves by four to one.[25]

In a 1796 revision of Maryland’s general code, a non-importation law was ratified to stop visitors from coming into the state and selling their slaves for speculative purposes. This law hindered slaveholders moving into Washington and Georgetown from areas outside of Maryland by requiring them to remain residents for three years before selling their slaves.[26] A number of slaves in Washington, D.C., petitioned for and won their freedom based owner violations of this Maryland enactment. These petitions were heard by the Circuit Court for the District of Columbia, consisting of one chief justice and two associate justices. Many judges that would go on to the Supreme Court started in this lower court. Despite being a federal branch of the court system, the Circuit Court for the District of Columbia acted as both a lower and appellate court for nearby jurisdictions.

The papers of the Circuit Court for the District of Columbia are held by the National Archives, however the digital project O Say Can You See: Early Washington D.C., Law & Family[27] has collected and digitized several hundred freedom suits and thousands of case files dating between 1800 and 1862 for public use. Users of the archived materials are able to explore the cases, people, families, and selected stories discovered by researchers.

Saint Louis, Missouri courts

A large corpus of freedom suits are available to researchers today in St. Louis, Missouri, where 301 files dating from 1814–1860 are among St. Louis Circuit Court Records discovered in the 1990s.[15] These records show that within the state jurors often decided in favor of the enslaved. In fact, slaves gained freedom in 57 percent of the cases in Saint Louis.[28] As the "Gateway to the West" and a slave state, the St. Louis courts heard many freedom suits. St. Louis developed its own network of people who supported slaves seeking freedom. Prominent attorneys were among those appointed as counsel by the court to argue for slaves' seeking freedom. In 1824, the Missouri courts established the precedent known as "once free, always free", freeing slaves in Missouri based on their having been held by their masters illegally in free states or territories. This held for decades until 1852 and the Dred Scott v. Sandford decision, which ruled that Scott should have filed for freedom while in a free state.[15][29]

The first freedom suit in St. Louis was filed in 1805 by Marguerite Scypion, an African-Natchez woman.[28] Briefly, she filed based on maternal descent from her Natchez grandmother. As the Spanish had ended Indian slavery in 1769, Scypion held that her mother, Marie-Jean Scypion, should have been freed at the time based on her Natchez ancestry, and that Marguerite herself was illegally held as a slave from birth. Having had an earlier ruling in her favor overturned on appeal, in 1826 Marguerite Scypion renewed her suit for freedom, filing against her current master Jean Pierre Chouteau, who headed one of the most prominent fur trading families in the city. She gained freedom for herself and all her mother's descendants in 1836, in a decision upheld by the US Supreme Court.[28]

Critical individuals

Notable United States cases

After passage in 1824 of a Missouri state law related to the right of slaves to file freedoms suits, in 1825 Scypion and her two sisters filed new petitions for freedom against their masters, by then Pierre Chouteau and two Tayon daughters. For such suits, the law gave slaves the standing of a free poor person, "with limited rights and privileges."[36] The cases were combined under Marguerite Scypion's name. After their attorney successfully gained two changes of venue away from St. Louis for the trial, a unanimous jury in Jefferson County, Missouri in 1836 decided in favor of the descendants of Marie Jean Scypion and officially ended Indian slavery in Missouri.[15] The decision survived appeals to the State Supreme Court and the US Supreme Court in 1838.[37]

Freedom suits in Great Britain

References

  1. 1 2 Anne Silverwood Twitty, “Slavery and Freedom on in the American Confluence, from the Northwest Ordinance to Dred Scott,” Ph.D. dissertation, Princeton University, 2010
  2. ↑ Vivienne Kruger, “Born to Run: The Slave Family in Early New York, 1626-1827” (PhD diss., Columbia University, 2007)
  3. ↑ Howell Cobb, A Scriptural Examination of the Institution of Slavery in the United States: With its Objects and Purposes (Georgia, 1856).
  4. 1 2 "Historical Document- Felix’s Petition". Africans in America. Public Broadcasting Service. January 1, 1773.
  5. 1 2 Heather Andrea Williams, American Slavery: A Very Short Introduction, Oxford University Press, 2014
  6. ↑ Gillmer, Jason, Suing for Freedom: Interracial Sex, Slave Law, and Racial Identity in the Post-Revolutionary and Antebellum South (January 1, 2004). North Carolina Law Review, Vol. 82, No. 2, January 2004. Available at SSRN: http://ssrn.com/abstract=1799647
  7. ↑ http://www.sos.mo.gov/archives/education/aahi/beforedredscott/biblio.asp "Before Dred Scott: Freedom Suits in Antebellum Missouri", Missouri Digital History, Missouri State Archives, accessed 1 February 2011
  8. ↑ John Joseph Condon, “Manumission, Slavery, and Family in Post Revolutionary Rural Chesapeake: Ann Arundel County, Maryland,” Ph.D. dissertation, University of Minnesota, 2001; and Stephen T. Whitman, The Price of Freedom: Slavery and Manumission in Baltimore and Early National Maryland (Lexington: University Press of Kentucky, 1997)
  9. ↑ John Lee, Lizette Lee, & Janette Lee v. Augustus Preuss, O Say Can You See: Early Washington, D.C., Law & Family (accessed Oct. 5, 2015, http://earlywashingtondc.org/cases/oscys.caseid.0076).
  10. ↑ Maryland Act of Assembly 1796, Chapter 67. (accessed Oct. 5, 2015, http://msa.maryland.gov/megafile/msa/speccol/sc2900/sc2908/000001/000105/html/am105--249.html).
  11. ↑ Act of the General Assembly of Virginia 1785, Ch. 77 quoted in “An Act to reduce into one, the several Acts concerning Slaves, Free Negroes and Mulattoes,” A Collection of All Such Acts of the General Assembly of Virginia of a public & permanent nature, as are now in force: comprising the first volume of the revised code, 1812, p. 262. (accessed Oct. 5, 2015, https://books.google.com/books?id=Mz4wAQAAMAAJ).
  12. ↑ Matilda Derrick, Lucy Derrick, Louisa Derrick, & Matilda Derrick v. George Mason & Alexander Moore, O Say Can You See: Early Washington, D.C., Law & Family (accessed Oct. 5, 2015, http://earlywashingtondc.org/cases/oscys.caseid.0092).
  13. ↑ Reid, Patricia Ann (July 2006). Between Slavery and Freedom. The University of Iowa. p. 66.
  14. ↑ John Davis, Teresa Davis, & Mary Ann Davis v. Hezekiah Wood, O Say Can You See: Early Washington, D.C., Law & Family (accessed Oct. 5, 2015, http://earlywashingtondc.org/cases/oscys.caseid.0251).
  15. 1 2 3 4 5 "Freedom Suits Case Files, 1814–1860", St. Louis Circuit Court Records Project, a collaboration between the Missouri State Archives, the St. Louis Circuit Court Clerk's Office, the American Culture Studies Program, Washington University, and the Missouri Historical Society (St. Louis, MO), 2004, accessed 4 January 2011 and 5 November 2012
  16. ↑ "People". O Say Can You See: Early Washington, D.C. Law & Family. Center for Digital Research in the Humanities, University of Nebraska-Lincoln.
  17. ↑ "Digital History". www.digitalhistory.uh.edu. Retrieved 2015-10-23.
  18. 1 2 Taunya Lovell Banks, "Dangerous Woman: Elizabeth Key's Freedom Suit – Subjecthood and Racialized Identity in Seventeenth Century Colonial Virginia", 41 Akron Law Review 799 (2008), Digital Commons Law, University of Maryland Law School, accessed 21 Apr 2009
  19. ↑ Paul Heinegg, Free African Americans in Virginia, North Carolina, South Carolina, Maryland and Delaware (1995–2005)
  20. ↑ Purcell Guild, June (1936). Black Laws of Virginia: A Summary of the Legislative Acts of Virginia Concerning Negroes From Earliest Times to the Present. New York: Negro Universities Press. pp. 63–65.
  21. ↑ "Archives of Maryland, Volume 0105, Page 0249 - Proceedings and Acts of the General Assembly, 1796". msa.maryland.gov. Retrieved 2015-10-23.
  22. ↑ William Bensing Webb, John Wooldridge, (Dayton, Ohio- United Bretheren Publishing House, 1892) Centennial History of the City of Washington, D.C.
  23. ↑ Sweig, Donald (Oct 1985). "The Importation of African Slaves to the Potomac River, 1732-1772". The William and Mary Quarterly (Omohundro Institute of Early American History and Culture) 42 (4). JSTOR 1919032.
  24. ↑ Davis, Damani (Spring 2010). "Quok Walker, Mumbet, and the Abolition of Slavery in Massachusetts". Prologue Magazine (National Archives) 42 (1).
  25. ↑ Brown, Letitia W (1970). "Residence Patterns of Negroes in the District of Columbia, 1800-1860". Records of the Columbia Historical Society, Washington, D.C. (Historical Society of Washington, D.C.) 70 (47). JSTOR 40067705.
  26. ↑ Corrigan, Mary Beth (Fall 2001 – Winter 2002). "Imaginary Cruelties? A History of the Slave Trade in Washington, D.C.,". Washington History (Historical Society of Washington, D.C.) 13 (2): 4–27. JSTOR 40073372.
  27. ↑ "O Say Can You See: Early Washington D.C. Law & Family", This site reconstructs the social world of early Washington, D.C., especially its multigenerational family networks, by collecting, digitizing, making accessible, and analyzing legal records and case files between 1800 and 1862.
  28. 1 2 3 William E. Foley, "Slave Freedom Suits before Dred Scott: The Case of Marie Jean Scypion's Descendants", Missouri Historical Review, 79, no. 1 (October 1984), p. 1, at The State Historical Society of Missouri, accessed 18 February 2011
  29. 1 2 "Before Dred Scott: Freedom Suits in Antebellum Missouri", Missouri Digital History, Missouri State Archives, accessed 1 February 2011
  30. ↑ Greene, Lorenzo Johnstone. The Negro in Colonial New England, p. 126
  31. ↑ Zilversmit, Arthur (October 1968). "Quok Walker, Mumbet, and the Abolition of Slavery in Massachusetts". The William and Mary Quarterly. Third (Omohundro Institute of Early American History and Culture) 25 (44): 614–624. JSTOR 1916801.
  32. ↑ Robert M. Cover, Justice Accused: Antislavery and the Judicial Process, New Haven and London: Yale University Press, 1975, p. 51
  33. ↑ Hudgins v. Wright (1806), Race and Racism in American Law, Dayton Law School, University of Dayton
  34. ↑ Ariela J. Gross (2008), What Blood Won't Tell: A History of Race on Trial in America, pp. 23–24 ISBN 978-0-674-03130-2
  35. ↑ "Freedom Suits", African-American Life in St. Louis, 1804–1865, from the Records of the St. Louis Courts, Jefferson National Expansion Memorial, National Park Service, accessed 11 January 2011
  36. 1 2 3 4 5 6 7 Edlie L. Wong, Neither Fugitive nor Free: Atlantic Slavery, Freedom Suits, and the Legal Culture of Travel, New York University Press, 2009
  37. 1 2 "Timeline of Missouri's African American History", Missouri Digital Heritage, Missouri State Archives, accessed 18 February 2011
  38. ↑ "O Say Can You See: Early Washington, D.C., Law & Family". earlywashingtondc.org. Retrieved 2015-10-26.
  39. ↑ Paul Finkelman, John F. A. Sanford, Dred Scott, Dred Scott v. Sandford: A Brief History with Documents, New York: Palgrave Macmillan, 1997, p. 20, accessed 17 February 2011
  40. ↑ History: "African American History: Residents: Charlotte Dupuy", Decatur House, National Trust for Historic Preservation, accessed 1 January 2011
  41. ↑ "Aaron and Charlotte Dupuy", Isaac Scott Hathaway Museum of Lexington, Kentucky
  42. ↑ Paul Finkleman, An Imperfect Union: Slavery, Federalism, and Comity, The Lawbook Exchange, Ltd., 2000, p. 222, accessed 26 February 2011
  43. ↑ Friedman, Champion of Civil Rights: Judge John Minor Wisdom, Southern Biography Series: LSU Press, 2009, p 24. Retrieved December 4, 2012.
  44. 1 2 Commonwealth v. Aves (1836), JRank, retrieved 11-26-10
  45. ↑ Eric Gardner, " 'You have no business to whip me': the freedom suits of Polly Wash and Lucy Ann Delaney", African American Review, Spring 2007, accessed 4 January 2011

Further reading

External links

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