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April 28, 2005
The legal roots of abolition
Most African Americans are aware of the 13th Amendment
to the U.S. Constitution which ended slavery everywhere in the
country. However, few are aware of the Somerset case which energized
the anti-slavery movement in England and the United States.
Prior to the Declaration of Independence, the 13 original states
were colonies of Great Britain. They were, therefore, governed
by British law except for local matters which were considered
to be municipal law. Even after July 4, 1776 the English common
law was relied upon in the emerging American jurisprudence.
Slaves in England had tried to gain their freedom with mixed results
prior to the decision in the Somerset case on June 22, 1772. Some
judges had ruled that Africans who had been baptized as Christians
could not be enslaved. Others had simply asserted that breathing
British air was inconsistent with the status of slavery. These
cases were ultimately overruled by higher authority.
There was a line of cases which much like the southern United
States of that day held blacks were property. Runaway slaves were
required to be returned much like a stolen horse or cow.
It was so offensive to equate human beings with animals that clever
lawyers would sue for the recovery of errant slaves under the
commercial law. They asserted that a contractual obligation existed
for the runaway to perform services for the master, and the runaway
was in breach of the agreement.
The concept of enslaving Englishmen was in disfavor because of
the quasi-slavery that was permitted under the feudal system.
So called villeins were essentially the property of the barons.
However, by the 18th century no case asserting such a right over
a civilian had succeeded.
Most of the cases to free slaves arose when a plantation owner
or merchant from the West Indies or America traveled to London
with a servant. The question became whether the black’s
status as a slave survived after he set foot on English soil.
If the court ruled that he became instantly free even for a moment
then he was free forever.
Charles Steuart, a high-ranking colonial official from Virginia,
came to London with his trusted man servant, James Somerset. After
Somerset fled and refused to return, Steuart had him kidnapped
and taken to a ship headed for Jamaica to be sold as a slave.
Anti-slavery activists in London obtained a writ of habeas corpus
to free Somerset. In a famous trial before the highly regarded
judge, the Earl of Mansfield, the issue of the status of slavery
in England was finally resolved. Mansfield ruled that slavery
“… is so odious that nothing can be suffered to support
it but positive law.”
By that Mansfield meant there must be an affirmative and specific
statute to enforce slavery. Custom or common law are insufficient.
Before passage of the Fugitive Slave Act, states with no statute
authorizing slavery would rely on the Somerset case to free slaves
who were traveling there with their masters.
There is a long history of efforts to use the rule of law to end
slavery and achieve equality. According to Steven Wise in his
book “Though the Heavens May Fall,” Steuart vs. Somerset
is “the landmark trial that led to the end of human slavery.”
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