Lemmon v. New York facts for kids
Quick facts for kids Lemmon v. New York |
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| Court | New York Court of Appeals |
| Decided | March 1860 |
| Citation(s) | 20 N.Y. 562 (1860) |
| Court membership | |
| Judge(s) sitting | Hiram Denio, William B. Wright, Clerke, George F. Comstock, Samuel Lee Selden |
| Case opinions | |
| Decision by | Denio |
| Concurrence | Wright |
| Dissent | Clerke, Comstock, Selden |
| Keywords | |
Lemmon v. New York, also known as Lemmon v. The People or the Lemmon Slave Case, was an important court case about freedom. It started in 1852 when a request was made to free eight enslaved people. The case went all the way to New York's highest court, the New York Court of Appeals. In 1860, just before the American Civil War, the court decided that the enslaved people should be set free.
This decision meant freedom for eight people, including six children. They had been brought to New York by their owners, Jonathan and Juliet Lemmon, who were moving from Virginia to Texas. New York had slowly ended slavery, freeing all enslaved people by 1827. A state law from 1841 clearly said that slave owners could not bring enslaved people into New York, even if they were just passing through. If they did, those enslaved people would become free.
Lawyer John Jay represented New York in the first case. Later, Chester A. Arthur, who would become a future U.S. President, helped represent the state when the former slave owners appealed the decision.
Contents
Why the Case Happened
New York's Stance on Slavery
New York City had strong business ties with the Southern states. Many businesses, like banking and shipping, relied on cotton and other goods produced by enslaved labor. Southern plantation owners and business people often visited New York.
However, New York had laws against slavery. In 1799, the state began a gradual process to end slavery. By July 4, 1827, all enslaved people in New York were officially free.
A key law passed in 1817 stated: "No person held as a slave shall be imported, introduced, or brought into this State on any pretence whatever ... . Every such person shall be free. ..."
Before this, an older law from 1799 allowed slave owners to visit New York with their enslaved people for up to nine months. But the 1817 law, and especially a later 1841 law, made it clear that bringing enslaved people into New York, even temporarily, would make them free.
People Fighting for Freedom
Many people in New York City worked to help enslaved people gain freedom. They were part of the Underground Railroad, a secret network that helped enslaved people escape.
John Jay (1817-1894) was a leading lawyer in New York. He often defended enslaved people in court, especially those who were trying to escape under the Fugitive Slave Act of 1850. This federal law made it harder for enslaved people to gain freedom, even in free states.
Louis Napoleon was a free African-American man who worked as a furniture polisher. He played a big role in helping enslaved people escape. He also helped connect enslaved people brought to New York with John Jay, leading to "freedom suits" in court. Louis Napoleon was the one who signed the request to start the Lemmon case.
What Happened in the Case
The Lemmons' Journey
In November 1852, Jonathan and Juliet Lemmon, who owned enslaved people in Virginia, decided to move to Texas. They traveled by steamship from Virginia to New York City. From New York, they planned to take another ship to Texas.
The Lemmons brought eight enslaved people with them. These included two families: Emiline (23) and her brother Edward (13), and Emiline's daughter Amanda (2). The other family was Nancy (20), her brother Lewis (16), and Nancy's sons Lewis (7) and Edward (7), and her daughter Ann (5). These individuals worked as house servants for the Lemmons.
While waiting for their next ship, the Lemmons stayed in one hotel. They placed the enslaved people in a boarding house on Carlisle Street.
Alerting the Activists
A Black porter at the boarding house noticed the enslaved people. He quickly told Louis Napoleon, the activist. Black citizens in New York often helped enslaved people brought to the city to gain their freedom, using the state's laws.
On November 6, 1852, Louis Napoleon asked Judge Elijah Paine Jr. of the Superior Court of New York City for a "writ of habeas corpus." This is a legal order that demands a person be brought before a court. It's often used to challenge if someone is being held illegally. In this case, it was used to argue that the enslaved people should be freed based on New York's 1841 law.
The Court Arguments
The Lemmons' lawyers argued that their clients were just passing through New York. They said that enslaved people were considered property in Southern states. They claimed that New York's law interfered with "interstate commerce" (trade between states). They referred to a U.S. Supreme Court case, Gibbons v. Ogden (1824), which said that only the federal government could regulate interstate commerce.
The state of New York, represented by lawyers like John Jay and Chester A. Arthur, argued differently. They said the U.S. Constitution gives limited powers to the federal government. Any powers not given to the federal government are reserved for the states. They pointed out that while the Fugitive Slave Act of 1850 required states to help return enslaved people who had escaped, it didn't say states had to allow slave owners to bring enslaved people into free states.
Court Decisions
Judge Paine's Ruling
On November 13, 1852, Judge Paine decided that the Lemmons didn't have to travel through New York to get to Texas. They chose to bring their enslaved people to New York, knowing it was a free state. Therefore, according to New York state law, the enslaved people were free.
Judge Paine's decision was based on an English court case from 1772, Somersett v. Stewart. In that case, an English court said that slavery could only exist where there were specific laws supporting it. Since England had no such laws, enslaved people who entered English territory became free.
After his decision, Judge Paine helped raise money to pay the Lemmons for the value of the enslaved people. This was done so the Lemmons wouldn't lose money, which might make their appeal weaker.
Appeals and Final Decision
The Lemmons appealed Judge Paine's decision to the New York Supreme Court. In December 1857, this court agreed with Judge Paine. The Lemmons then appealed again to the New York Court of Appeals, which is the highest court in New York.
In March 1860, the Court of Appeals upheld the decision by a vote of 5-3. They ruled that the enslaved people were indeed free.
The Lemmons then gave their legal rights to the State of Virginia, which planned to appeal the case to the Supreme Court of the United States. However, the American Civil War began soon after, and the case was never heard by the Supreme Court.
Impact of the Case
The Lemmon case was very important because it showed the growing tension between free and slave states. It highlighted the different laws and beliefs about slavery across the United States.
The New York Times newspaper reported on the decision. It criticized the judges who disagreed with the ruling. The newspaper said that judges, even in the South, were making decisions based on their feelings about slavery, rather than strictly following the law.
The Lemmon case was a major step in the fight against slavery. Historian Paul Finkelman said that Lemmon was the "culmination of a long and intense conflict over the place of slavery within the legal framework of the Union." He also noted that it was "part of the larger social and political movements that ultimately led to the Republican party, the Civil War, and Constitutional amendments ending slavery and making blacks full-fledged citizens."
The Southern states clearly saw the importance of Lemmon. When South Carolina decided to leave the Union, it mentioned the Lemmon case. It stated that New York's courts had "denied" even the right for a slave owner to pass through the state with enslaved people.
Years later, Chester A. Arthur, who became President, took credit for his role in the case. However, historians note that John Jay and William M. Evarts also played very important roles in winning the case.
