Prigg v. Pennsylvania facts for kids
Quick facts for kids Prigg v. Pennsylvania |
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| Decided March 1, 1842 | |
| Full case name | Edward Prigg v. Commonwealth of Pennsylvania |
| Citations | 41 U.S. 539 (more)
16 Pet. 539; 10 L. Ed. 1060; 1842 U.S. LEXIS 387
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| Prior history | In error to the Supreme Court of Pennsylvania. |
| Holding | |
| Federal law is superior to state law, but states are not required to use their resources to enforce federal law. | |
| Court membership | |
| Case opinions | |
| Majority | Story |
| Concurrence | Taney, Thompson, Wayne, Daniel |
| Dissent | McLean |
Prigg v. Pennsylvania was an important case decided by the Supreme Court of the United States in 1842. The Court had to decide if a Pennsylvania state law, which stopped Black people from being taken out of the state into slavery, went against a federal law called the Fugitive Slave Act of 1793.
The Court decided that the federal law was more powerful than the state law. Because of this, the conviction of slave catcher Edward Prigg was overturned.
This case happened when John Tyler was president. The decision made it harder to enforce the Fugitive Slave Act of 1793. It allowed states to say their officials didn't have to help return escaped slaves.
However, the Court also said that the federal government was in charge of returning escaped slaves. This set the stage for stronger laws later on. For example, the Fugitive Slave Act of 1850 (part of the Compromise of 1850) made free states help catch and return escaped slaves. It also increased punishments for not following the law.
The Prigg decision also meant that Black people had fewer legal protections than white people. This was because the Court didn't address the problem of free Black people being kidnapped and sold into slavery.
Contents
Understanding Federal Law and Slavery
In March 1789, the Constitution of the United States became the law of the land. It included rules about people who fled from one state to another.
Article IV, Section 2, had two important parts:
- One part said that if someone accused of a crime escaped to another state, they should be sent back.
- Another part, known as the Fugitive Slave Clause, said that a person "held to service or labor" (meaning an enslaved person) who escaped to another state could not be set free by that state's laws. Instead, they had to be returned to their owner. This part of the Constitution was later replaced by the Thirteenth Amendment, which ended slavery in 1865.
On February 12, 1793, the Congress passed the Fugitive Slave Law of 1793. This law was created to help enforce the part of the Constitution about returning escaped slaves.
Pennsylvania's State Laws
Pennsylvania had its own laws about slavery. On March 29, 1788, Pennsylvania changed an older law called "An Act for the Gradual Abolition of Slavery." The change said that no enslaved Black or mixed-race person could be taken out of Pennsylvania with the plan to change where they lived.
Later, on March 25, 1826, Pennsylvania passed another law. This law made it a serious crime (a felony) to use force, violence, or trickery to take any Black or mixed-race person out of Pennsylvania. This was especially true if the goal was to sell them or keep them as a slave for life or any period of time.
The Story Behind the Case
In 1832, a Black woman named Margaret Morgan moved to Pennsylvania from Maryland. She had been born into slavery in Maryland. Her owner, John Ashmore, had allowed her to live almost freely, but he never officially freed her.
After Ashmore died, his family decided they wanted Margaret Morgan back as their property. They hired a slave catcher named Edward Prigg to find her.
On April 1, 1837, Prigg and others captured Margaret Morgan in York County, Pennsylvania. They took her to Maryland, planning to sell her. Her children, including one who was born free in Pennsylvania, were also captured and sold.
The four men involved in the capture were charged under Pennsylvania's 1826 law. Prigg said he was innocent. He argued that he was allowed to arrest and return Margaret Morgan because Ashmore's family had hired him.
On May 22, 1839, a court in York County found Prigg guilty of breaking the state law.
Prigg then appealed his case to the US Supreme Court. He argued that Pennsylvania's law could not be stronger than federal law or the US Constitution. He said that the Fugitive Slave Act and Article IV of the Constitution were in conflict with Pennsylvania's 1788 law. This case became known as Prigg v. Pennsylvania.
Prigg and his lawyer argued that the Pennsylvania laws from 1788 and 1826 were unconstitutional.
- First, they pointed to Article IV of the US Constitution, which said escaped slaves must be returned.
- Second, they argued that federal laws, like the Fugitive Slave Act of 1793, were more powerful than any state law.
They believed that the Pennsylvania law should be canceled because it went against federal law. The main question was whether Pennsylvania's law violated the Constitution's rule about returning escaped slaves and the 1793 federal law that put it into action.
The Supreme Court's Decision
Justice Joseph Story wrote the main opinion for the Supreme Court. The Court decided to overturn Prigg's conviction. They ruled that the Pennsylvania law was unconstitutional. This was because it went against both the right of slaveholders to get their slaves back under Article IV and the Federal Fugitive Slave Law of 1793. The federal law was stronger than the state law, thanks to the Supremacy Clause of the Constitution.
Even though Justice Story said Pennsylvania's laws were unconstitutional, his decision also said something important. He suggested that states could choose to forbid their own officials from helping to return escaped slaves.
He wrote that state officials could help if they wanted to, unless their state laws told them not to. However, state laws could not stop a slave owner from going to another state and recapturing an escaped slave on their own, as long as they didn't cause a fight.
Many people at the time believed that Southern states would not have agreed to the U.S. Constitution if the Fugitive Slave Clause had not been included. Five of the seven Supreme Court justices, including Story, mentioned this idea. However, some historians, like Don E. Fehrenbacher, have since said there isn't much proof for this idea.
What Happened After the Decision
Justice Story's words, "unless prohibited by state legislation," led to new laws in Pennsylvania and other Northern states. These were called personal liberty laws. These laws stopped state officials from helping with escaped slaves in any way.
This meant that escaped slaves could not be caught or held by state actions. Their cases could not be heard in state courts. State officials could not help people who wanted to recapture slaves. The federal Fugitive Slave Act was still in place, but only federal agents could enforce it. This idea is known as the "anti-commandeering doctrine."
Southern states saw this refusal to help enforce the Fugitive Slave Act as a serious problem. They felt it broke the agreement between the states. One person wrote to South Carolina Senator John C. Calhoun, complaining that the new personal liberty laws made "slave property utterly insecure."
The growing tension over slavery led to the Compromise of 1850. This agreement dealt with several issues, including new territories gained from the Mexican–American War. The South allowed California to join the Union as a free state. In return, Northern states had to agree to a stronger Fugitive Slave Act. This new act required law enforcement in free states to help catch and return escaped slaves within their borders.
The South had to rely on the federal government for a solution. The Supreme Court had already shown it would support such a solution. However, many people in the North were against it. Some people hoped the Court could help calm the growing arguments about slavery.
But the Liberty Party, a political group, spoke out against the Prigg v. Pennsylvania decision in 1843. They said the ruling took away important protections for free Black people, like habeas corpus, which protects against unlawful imprisonment. They felt it removed their "whole legal security of personal freedom."
