Dred Scott v. Sandford

Background:

Prior to the American Civil War, states and territories in the United States were divided into two categories. Free states were states where slavery was prohibited, whereas slave states were states where slavery was legal. Born into slavery around 1799, Dred Scott was purchased in 1830 by Dr. John Emerson. Between 1833 and 1843, Emerson took Scott with him to various military posts, including Fort Armstrong in Illinois and Fort Snelling in the Wisconsin Territory. Both Illinois and Wisconsin were free states. While living at Fort Snelling, Scott married Harriet Robinson, another enslaved woman whose ownership was subsequently transferred to Emerson. This marriage took place on free soil, and the couple later had two daughters. After Dr. Emerson died in 1843, his widow took Scott and his family back to St. Louis, Missouri, which was a slave state.

The Case:

 In 1846, Scott and his wife sued the widow of their former enslaver, Irene Emerson. John F. A. Sandford, her brother, was the nominal defendant (often misspelled as Sanford in court records). Dred Scott’s claim was based on the fact that his former enslaver had taken him to live in various free states for years before moving back to a slave state. This presented the legal question of whether an enslaved person living in a free state automatically became free. What appeared to at first be a straightforward lawsuit between two private parties, led to an 11-year legal struggle becoming one of the most notorious decisions ever issued by the United States Supreme Court. Scott lost his original case, which worked its way through the Missouri state courts. He eventually filed a new federal suit which ultimately reached the Supreme Court. 

Debates From Each Side:

Scott believed that due to the fact he had lived in places where slavery was prohibited, he legally should be free. He backed this with the idea that previous legal precedents often supported the idea, residence in a free territory granted freedom. Due to the Missouri Compromise of 1820, slavery was banned in both the state of Illinois and the Wisconsin territory, which Scott had lived in. His argument was based on existing legal principles, not just moral opposition to slavery. On the contrary, Sandford claimed, enslaved people remained property, regardless of where they lived. He backed this by presenting the idea that African Americans were not intended to be citizens under the Constitution when it was written. Sandford also stated the claim, Congress did not have the right to deprive slaveholders of property while in federal territories.

Verdict:

The Supreme Court determined, in a 7-2 vote, Dred Scott, or any other slave, was not automatically granted freedom by entering a free state. Chief Justice Roger B. Taney wrote the majority opinion for this case. African Americans were declared to not be eligible for U.S. citizenship under the Supreme Court’s interpretation. Because of this, they found that Scott could not legally sue in a federal court, since he was not a citizen. Simultaneously, the Court declared the Missouri Compromise to be unconstitutional, ruling Congress had no authority to prohibit slavery in federal territories. The Court determined that it violated the Fifth Amendment, as enslaved people were considered property, and any law depriving a person of property without due process was unconstitutional.

Legacy:

The decision in Dred Scott v. Sandford greatly intensified regional conflict between the North and South. This tension eventually led to the American Civil War. This case also strengthened the emerging Republican party’s opposition to the expansion of slavery. In 1865, the Thirteenth Amendment was ratified, abolishing slavery throughout the United States. This eliminated the legal foundation of the Court's ruling which treated enslaved people as property. Later, in 1868, the Fourteenth Amendment was ratified stating that all persons born or naturalized in the United States are citizens, contradicting the Court's previous claim that African Americans could not be U.S. citizens. The Supreme Court never formally overturned Dred Scott v. Sandford, however the Constitution itself changed. Because Amendments in the U.S. Constitution have higher authority than Supreme Court rulings, this case fundamentally became unconstitutional and unenforceable. This case is not only an important part of American history to be remembered, but also stands as a cautionary example from the past of how Supreme Court decisions can deepen national divisions rather than resolve conflicts.