Study Notes on Scott v. Sandford (Dred Scott Decision)

Scott v. Sandford (Dred Scott Decision) Overview

  • Case Citation: 19 HOW. (60 U.S.) 393 (1857)

  • Vote: 7 Justices in favor (Campbell, Catron, Daniel, Grier, Nelson, Taney, Wayne), 2 against (Curtis, McLean)

  • Opinion of the Court: Delivered by Chief Justice Roger B. Taney

  • Concurring Opinions: Justices Campbell, Catron, Daniel, Grier, Nelson, Wayne

  • Dissenting Opinions: Justices Curtis, McLean

Facts of the Case

  • Background of Dred Scott:

    • Dred Scott was born into slavery around 1795 in Virginia.

    • His original owner was Peter Blow, a plantation owner.

    • Dred Scott’s ownership changed hands multiple times, but he remained linked to the Blow family.

  • Timeline of Scott's Ownership:

    • 1827: Blow moved to St. Louis with Scott and the Blow family slaves.

    • 1833: After Blow's death, Scott was sold to John Emerson, a U.S. Army surgeon.

    • 1834: Scott was taken to Illinois, a free state.

    • 1836: Scott was taken to the Upper Louisiana Territory, also free due to the Missouri Compromise of 1820.

    • While in the Wisconsin territory, Scott married Harriet Robinson (also a slave), and they had two daughters.

    • Post-Emerson's Death: Title was transferred to Emerson's widow E. Irene Sanford Emerson, who later moved to Massachusetts.

  • Legal Proceedings:

    • In 1846, Henry T. Blow, son of Scott's original owner, initiated a lawsuit for Scott's freedom, believing Scott to be free due to having lived in free territories.

    • Scott was initially hired out while the lawsuit was pending.

    • The trial court ruled in favor of Scott, but the Missouri Supreme Court reversed the decision.

    • Ownership of Scott was transferred to John Sanford (spelled 'Sandford' in court records) of New York, allowing the case to be pursued in federal court due to diversity jurisdiction.

  • Federal Court Proceedings:

    • Lower federal courts ruled against Scott but indicated he may have been a citizen.

    • Scott lived virtually free in St. Louis while awaiting Supreme Court decisions, as Congress repealed the Missouri Compromise in 1854, inciting tensions regarding slavery.

Supreme Court Proceedings

  • Initial Court Stance:

    • The Court hesitated for a year to decide, with suggestions to affirm the state court ruling.

    • Justice James Wayne insisted the Court should address the fundamental issues regarding slavery and citizenship.

    • The Court eventually announced a divided decision in 1857, involving nine separate opinions.

  • Chief Justice Taney's Opinion:

    • Stated that Dred Scott was still a slave and asserted that descendants of slaves could not claim citizenship.

    • Taney defined the question at hand:

    • "Can a negro whose ancestors were imported into this country and sold as slaves become a member of the political community formed by the Constitution?"

    • The Court maintained that the term “citizens” does not include descendants of African slaves, consequently denying them rights provided for citizens in the Constitution.

Legal Interpretation and Constitutional Insights

  • Definitions of Citizenship:

    • Taney argued that "the words 'people of the United States' and 'citizens' are synonymous" and referred to those exercising sovereignty and authority through representatives.

    • The Court concluded:

    • Descendants of Africans were viewed as a subordinate class and had no rights which a white man was bound to respect.

  • Limitations of State Citizenship vs. U.S. Citizenship:

    • Citizenship granted by states does not guarantee corresponding rights under the Constitution.

    • Each state retained the right to define citizenship within its limits, leading to disparate rights under different states.

  • Equality of Citizens:

    • The Constitution aimed to create a political family with general comprising citizens; thus, only those considered citizens by states at the time of adoption could be included.

    • The Court indicated that no new member could be introduced into this political community by any post-Constitution state law.

Historical Context and Societal Views

  • Racial Prejudices:

    • Analyzed the historical public opinion against Africans and their descendants who were regarded as unfit for inclusion in civic and societal life.

    • Taney emphasized how throughout colonial and state history, Africans were legally treated as inferior and without rights worthy of respect.

  • Impact of the Decision:

    • The ruling galvanized anti-slavery sentiments in the North, demonstrating the Supreme Court's alignment with pro-slavery attitudes, tarnishing Taney's reputation.

    • Southern states celebrated the ruling as a legal endorsement of slavery, emboldened by Taney’s principles on slavery and federalism.

  • Political Repercussions:

    • This decision became a flashpoint leading up to the American Civil War, illustrating deep national divisions over slavery.

Conclusion of the Court's Opinion

  • Taney concluded that Dred Scott was not a citizen of Missouri or the United States and that the Circuit Court could not have jurisdiction over the case.

  • Therefore, the judgment of the lower court was reversed, and the case was dismissed for lack of jurisdiction due to Scott's status as a non-citizen slave.

  • Judgment: The final ruling decreed that neither Scott nor his family were free by virtue of being taken to free states or territories; Scott's status as a slave was maintained according to Missouri law upon his return.