Dred Scott v. Sandford

Dred Scott v. Sandford Summary

The central themes of this case were whether a “negro slave”, descendants of “negro slaves”, freed African-American slaves, or descendants of freed African-American slaves had the rights of U.S. citizens, including the right to file a lawsuit.

Key Players in Dred Scott v. Sandford

• 1Appellant: Dredd Scott, who filed a lawsuit for his freedom and who, along with his family, was assaulted by his master.
• 2Appellee: Sandford, successor in interest of the master of Scott and of his family members.

Dred Scott v. Sandford Brief

The central themes of this case were whether a “negro slave”, descendants of “negro slaves”, freed African-American slaves, or descendants of freed African-American slaves had the rights of U.S. citizens, including the right to file a lawsuit.

Dred Scott v. Sandford Facts

Sandford’s successor in interest attacked and “imprisoned” Scott and Scott’s wife and children, who were his slaves at the time and who could be subject to punishment by him under the law at the time. Scott sued Sandford for his freedom in Missouri, and the state case was concluded in favor of the defendant because Scott and his family were considered “property”. Dred Scott was a slave in Missouri and was transported by his master to Illinois and Louisiana. Scott married another slave of his master in Louisiana and was then transported with his wife and children by his master to Missouri.

The Dred Scott v. Sandford Decision

The Court held that individuals like Dred Scott were not citizens under the Constitution based on interpretations of a clause expressly permitting the import of slaves and the holding of them as property. The Court did not distinguish between property rights over slaves and more general property rights, asserting that the government cannot interfere with rights in any property of a private citizens. The Court emphasized that rights given to an individual in a particular state—such as those of a freed slave—“would be restricted to the state which gave them”.

In its analysis, the ruling addressed the issue of whether the lower court, the Circuit Court, had jurisdiction to hear the case and whether the judgment in favor of Scott was correct. The Court clarified that the central issue as to jurisdiction in this case was the citizenship of Dred Scott. The Court noted that its duty in interpreting the Constitution with respect to this issue of citizenship involved determining the intent of the signers at the time that the Constitution was signed. It noted that, at the time the Constitution was signed, African Americans were “subordinate” and “inferior” to whites and that the Declaration of Independence and other essential legal texts made no explicit grant of citizenship to African American slaves and their descendants (It asserted that African Americans were “not intended to be included” in the assertion that “all men are created equal”). “Laws long before established”, the court held, were evidence of this intent or lack thereof; and the only mention of African Americans in that time referred to them as pieces of “property”. It went on to say that, at the time the Constitution was signed, the “rights” or “privileges” granted to African Americans were limited to those which the government should “choose to grant them”. It went on to point to specific clauses in the Constitution and the Articles of Confederation which clearly defined African Americans as a “separate class or persons” and non-citizens. A clause of the Constitution, at that time, allowed the practice of slavery to persist until 1808, thereby defining African Americans as property and not citizens. Clauses in the Articles of Confederation afford the “privileges and immunities of…citizens” of the United States to “free inhabitants of each of the states” and, also, state that armies would be raised from each state based on a count of the population of “white inhabitants” of the states. The fact that an African descendant had never been “free” at the time of the drafting of the Articles and the fact that only “white inhabitants” were included in such a critical population count led the Court to conclude that African Americans were generally not considered “free” people or “inhabitants” of the United States such that they could be deemed citizens. Based on that, the Court determined that the intent of the signers, at the time, was not to include African Americans as part of “the people of the United States” who were entitled to certain rights and privileges.

The Court asserted that Congress was entitled to an exclusive right to establish a “rule of naturalization” and that, because of that, states did not have the right to “naturalize” non-citizens or afford them the “the rights and privileges secured to a citizen of a state under the federal government”. It went on to state that a single state’s inviting of a “new member into the political community created by the Constitution” would encroach upon the powers of naturalization afforded to the federal government. Moreover, a state’s attempt to make an African American a citizen of the state of Missouri, would not then make him a citizen of the United States. The Court noted that the purpose of defining citizens or the “people of the United States” in the Constitution was to allow people to enjoy the rights of citizens across state lines and that state-created, in-state citizenship did not exist.

Key Takeaways for Law Students

• 1At this point in history, the Supreme Court concluded that African-American freed slaves—and African Americans in general—were not citizens of the United States such that they could file lawsuits in federal court.
• 2The Court determined that the intent of the signers of the Constitution was to exclude African Americans from enjoying the “rights, privileges, and immunities” of citizenship and that the plain words of the Constitution, the contemporaneous attitudes towards African American slaves, and the legislative history at the time demonstrated such intent.