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Encyclopedia > Prigg v. Pennsylvania

Prigg v. Pennsylvania, 41 U.S. 539 (1842), was a United States Supreme Court case in which the court held that Federal law is superior to State law, and overturned the conviction of Edward Prigg as a result. The Supreme Court of the United States (SCOTUS) is the highest judicial body in the United States and leads the judicial branch of the United States federal government. ...

Contents

Federal Law

In June 1788, the Constitution of the United States came into force, having been ratified by nine states (see History of the United States Constitution). Article IV, Section 2, of the Constitution contained two statements about the legality of fleeing justice, creditors, owners, or other agencies, across state borders: 1788 was a leap year starting on Tuesday (see link for calendar). ... Page I of the Constitution of the United States of America Page II of the United States Constitution Page III of the United States Constitution Page IV of the United States Constitution The Syng inkstand, with which the Constitution was signed The Constitution of the United States is the supreme... To meet Wikipedias quality standards, this article or section may require cleanup. ...

  • A person charged in any state with treason, felony or other crime, who shall flee from justice, and be found in another state, shall, on demand of the executive authority of the state from which he fled, be delivered up, to be removed to the state having jurisdiction of the crime.
  • No person held to service or labor in one state, under the laws thereof, escaping into another, shall, in consequence of any law or regulation therein, be discharged from such service or labor; but shall be delivered up, on claim of the party to whom such service or labor may be due.

Although the second clause above was superseded by the 13th Amendment, that amendment came into force only 77 years later, on December 6th 1865. Amendment XIII Amendment XIII (the Thirteenth Amendment) of the United States Constitution officially abolished, and continues to prohibit, slavery, and, with limited exceptions, prohibits involuntary servitude. ... 1865 (MDCCCLXV) is a common year starting on Sunday. ...


On February 12th 1793, the U.S. Congress passed the Fugitive Slave Law of 1793. 1793 was a common year starting on Tuesday (see link for calendar). ... Congress in Joint Session. ... The 1793 Fugitive Slave Law was written in response to a conflict between Pennsylvania and Virginia. ...


State law in Pennsylvania

On March 29th 1788, the State of Pennsylvania passed an amendment to one of its laws (An act for the gradual abolition of slavery, originally enacted March 1st 1780); this amendment stated that, No negro or mulatto slave ...shall be removed out of this state, with the design and intention that the place of abode or residence of such slave or servant shall be thereby altered or changed. 1788 was a leap year starting on Tuesday (see link for calendar). ... This article is about the U.S. State. ... 1780 was a leap year starting on Saturday (see link for calendar). ...


On March 25th 1826, the State of Pennsylvania passed a further law, which stated in part: The oldest surviving photograph, Nicéphore Niépce, circa 1826 1826 (MDCCCXXVI) was a common year starting on Sunday (see link for calendar) of the Gregorian calendar (or a common year starting on Tuesday of the 12-day-slower Julian calendar). ...

If any person or persons shall, from and after the passing of this act, by force and violence, take and carry away, or cause to be taken or carried away, and shall, by fraud or false pretense, seduce, or cause to be seduced, or shall attempt so to take, carry away or seduce, any negro or mulatto, from any part or parts of this commonwealth, to any other place or places whatsoever, out of this commonwealth, with a design and intention of selling and disposing of, or of causing to be sold, or of keeping and detaining, or of causing to be kept and detained, such negro or mulatto, as a slave or servant for life, or for any term whatsoever, every such person or persons, his or their aiders or abettors, shall on conviction thereof, in any court of this commonwealth having competent jurisdiction, be deemed guilty of a felony.

Case background

During the year of 1832, a black woman called Margaret Morgan escaped to Pennsylvania from Maryland, where she had been a slave to a woman named Margaret Ashmore. 1832 was a leap year starting on Sunday (see link for calendar). ... Official language(s) None (English, de facto) Capital Annapolis Largest city Baltimore Area  Ranked 42nd  - Total 12,417 sq mi (32,160 km²)  - Width 90 miles (145 km)  - Length 249 miles (400 km)  - % water 21  - Latitude 37°53N to 39°43N  - Longitude 75°4W to 79°33...


On April 1st 1837, Edward Prigg led an assault and abduction on Morgan in York County, Pennsylvania. They took Morgan to Maryland, intending to sell her as a slave. The four men involved in the abduction were arraigned under the 1826 act. Prigg pleaded not guilty, and argued that he had been duly appointed by Margaret Ashmore to arrest and return Morgan to her owner in Maryland. However, in a ruling on May 22nd 1839, the Court of Quarter Sessions of York County convicted him. Queen Victoria, Queen of the United Kingdom (1837 - 1901) 1837 (MDCCCXXXVII) was a common year starting on Sunday (see link for calendar). ... York County is a county located in the U.S. state of Pennsylvania. ... Official language(s) None (English, de facto) Capital Annapolis Largest city Baltimore Area  Ranked 42nd  - Total 12,417 sq mi (32,160 km²)  - Width 90 miles (145 km)  - Length 249 miles (400 km)  - % water 21  - Latitude 37°53N to 39°43N  - Longitude 75°4W to 79°33... In criminal law, an acquittal is the legal result of a verdict of not guilty, or some similar end of the proceeding that terminates it with prejudice without a verdict of guilty being entered against the accused. ... 1839 (MDCCCXXXIX) was a common year starting on Tuesday (see link for calendar). ...


Prigg appealed to the U.S. Supreme Court on the grounds that the Pennsylvania law arrogated the State powers over and above those allowed by the U.S. Constitution.


The Supreme Court's view

Prigg and his lawyer argued that the 1788 and 1826 Pennsylvania laws were unconstitutional:

  • Firstly, because of the injunction in Article IV of the U.S. Constitution that No person held to service or labor in one state, under the laws thereof, escaping into another, shall, in consequence of any law or regulation therein, be discharged from such service or labor; but shall be delivered up, on claim of the party to whom such service or labor may be due..
  • Secondly, because, the exercise of Federal legislation, such as that undertaken by Congress in passing the act of the February 12th 1793, supersedes any State law.

As a consequence, they argued, the 1788 Pennsylvania law, in all its provisions applicable to this case, should be voided.


Writing for the Court, Justice Story reversed the conviction and held the Pennsylvania law unconstitutional as a denial of both the right of slaveholders to recover their slaves under Article IV and the Federal Fugitive Slave Law of 1793, which trumped the state law per the Supremacy Clause. Six justices wrote separate opinions. American jurist Joseph Story Joseph Story (September 18, 1779 - September 10, 1845), American jurist, was born at Marblehead, Massachusetts. ... The 1793 Fugitive Slave Law was written in response to a conflict between Pennsylvania and Virginia. ... Article VI, Paragraph 2 of the United States Constitution is known as the Supremacy Clause: The Supremacy Clause establishes the Constitution, Federal Statutes, and U.S. treaties as the supreme law of the land. ...


However, while Story ruled the Pennsylvania laws unconstitutional, his opinion left the door open for further such actions by the state in his writing:

As to the authority so conferred upon state magistrates [to deal with runaway slaves], while a difference of opinion has existed, and may exist still on the point, in different states, whether state magistrates are bound to act under it; none is entertained by this Court that state magistrates may, if they choose, exercise that authority, unless prohibited by state legislation - Justice Story (emphasis added)

This last phrase - "unless prohibited by state legislation" - became the impetus for a number of personal liberties laws enacted by Pennsylvania and the other Northern states. These laws did as the Court had suggested - they prohibited state officials from interfering with runaway slaves in any capacity. Runaways could not be caught or incarcerated, cases could not be heard, and no assistance could be offered to those wishing to recapture slaves. The Fugitive Slave Act still stood, but only federal agents could enforce it.


Such an emphatic refusal to uphold the Fugitive Slave Act was viewed as a brazen violation of the federal compact by the Southern states. One letter to South Carolina Senator John C. Calhoun stated that the new personal liberties laws "rendered slave property utterly insecure" and was a "flagrant violation of the spirit of the U.S. Constitution."[1] John Caldwell Calhoun (March 18, 1782 – March 31, 1850) was a prominent United States Southern politician and political philosopher from South Carolina during the first half of the 19th century. ...


It was these laws that led to The Compromise of 1850 - California could enter the Union as a free state, but the Northern states would have to enforce the Fugitive Slave Act within their own borders. Official language(s) English Capital Sacramento Largest city Los Angeles Area  Ranked 3rd  - Total 158,302 sq mi (410,000 km²)  - Width 250 miles (400 km)  - Length 770 miles (1,240 km)  - % water 4. ...



 

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