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Rachel v. Walker (1834) was an important "freedom suit" in St. Louis, Missouri. An African-American woman named Rachel, who was enslaved, asked the court for her freedom. She also wanted freedom for her son, James Henry.

Rachel argued that she and her son had been held illegally as slaves. This happened when her previous owner, an Army officer, took them to Michigan Territory. At that time, Michigan was a free territory where slavery was not allowed.

Her case went all the way to the Supreme Court of Missouri. In 1836, Rachel won! The court decided that an Army officer lost his right to own a slave if he took that person to a place where slavery was against the law. This ruling was later mentioned in the famous Dred Scott v. Sandford case in 1856.

Rachel's case was one of 301 freedom suits found in St. Louis court records from the 1800s. This is the largest collection of such cases available for people to study. The Missouri History Museum has an online database where you can search for these freedom suits.

Seeking Freedom in Court

Even though enslaved people were not considered citizens, a Missouri state law from 1824 allowed them to sue for their freedom. They could file a case as "poor people."

If the court thought a case had good reasons, it would give the enslaved person a lawyer. The law also said that the slave owner had to let the enslaved person talk with their lawyer. The owner could not take the enslaved person out of the court's area until the case was finished.

Rachel's Fight for Freedom

In Rachel's case, the court assigned Josiah Spalding to be her lawyer. Rachel had been held by an army lieutenant named Thomas Stockton. This happened at Fort Snelling (which is now in Minnesota) and Fort Crawford (now in Wisconsin). Both of these forts were in the Michigan Territory, which was a free territory at the time.

Rachel's son, James Henry, was born in 1834 at Fort Crawford. Lieutenant Stockton later returned to St. Louis with Rachel and James Henry. There, he sold them. Their new owner then sold them to William Walker, who was a slave trader. Walker planned to take them "downriver" on the Mississippi River, probably to New Orleans, to sell them again.

Rachel sued for her freedom because she had been held illegally as a slave for a long time in free territories. The first court ruled against Rachel. But her lawyer, Josiah Spalding, appealed the case to the Missouri Supreme Court.

In 1836, the Missouri Supreme Court ruled in Rachel's favor. This decision helped show that the court would support the laws of nearby free states. It meant that a slaveholder lost their rights to a slave if they took that person into free territory.

Winning Freedom for Her Son

By the time the case reached the State Supreme Court, it was only about Rachel's freedom. After she won, Rachel had to file a separate lawsuit to free her son, James Henry. She was successful in that case too.

The court continued to follow a rule from an earlier case called Winny v. Whitesides (1824). In that case, the state supreme court said that a slave became free after being held illegally in a free state. This led to the idea of "once free, always free."

Specifically, the court ruled that "if an officer of the United States Army takes a slave to a territory where slavery is prohibited, he forfeits his property." This meant the officer lost ownership of the enslaved person. The Winny case set an important rule in Missouri for freeing enslaved people who had lived in free territory.

Rachel's Petition to the Court

On November 4, 1834, Rachel filed her petition asking for freedom. She told the court that about five years earlier, she was owned by Stockton. He took her to Michigan Territory, specifically to Prairie du Chien, for about two years. During that time, she was forced to work for him and his family. Her son, James Henry, was born there and was also held as a slave.

Rachel explained that Stockton later brought her and her child to St. Louis and sold them. They were then sold again to William Walker, who was a slave dealer. Walker was planning to take them down the Mississippi River, likely to New Orleans, to sell them. Rachel asked the court to let her and her child sue for freedom as "poor persons." She also asked that Walker be stopped from taking them out of the court's area until the case was decided.

The Court's Decision

Justice Mathias McGirk of the Missouri Supreme Court explained the decision. He said that Stockton had "willfully procured a slave and held her, unlawfully, in free territories." This act was against the law and meant Stockton should lose ownership of the slave.

With this ruling, the court supported the laws of the neighboring free territories and states. It also closed a loophole that Army officers had tried to use to keep their slaves. Stockton had argued that he had no choice in his Army assignments, so he should not lose his slave property because of them.

Rachel's victory in this case gave her the legal basis to successfully sue for her son James Henry's freedom. Since he was born to a woman who was illegally held as a slave in a free state (and then freed for that reason), he was also free. This followed the principle of partus sequitur ventrem, which meant the child's social status came from his mother.

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