The Dred Scott v. Sandford case revolved around the issue of slavery. Dred Scott, who was born enslaved in Virginia around 1800, took legal action against his owner to seek freedom for himself and his family. He argued that he had lived in a territory where slavery was prohibited, which could potentially qualify him for emancipation. Peter Blow initially owned Scott and his family, but they were later purchased by John Emerson, a military doctor. They moved to St. Louis in 1830 and then traveled to Illinois and the Wisconsin territory – both territories that banned slavery according to the Missouri Compromise of 1820.
In 1842, Dred Scott and his wife Irene Sanford returned to St. Louis, Missouri with their two daughters. Unfortunately, John Emerson, Dred Scott’s spouse, passed away the following year. In 1846, the Scotts filed a lawsuit against Irene Emerson in an effort to secure their freedom based on their time spent in free territories. It is important to note that they did not initiate legal action while residing in those territories (Dred Scott’s Fight). The St. Louis courthouse initially ruled against Scott in 1847 but granted him a second trial opportunity. During the second trial in 1850, the jury decided that the Scotts should be given their freedom.
Emerson brought her case to the Missouri State Supreme Court in an effort to keep the Scotts with her. However, in 1852, the court overturned the decision. Subsequently, Dred Scott initiated legal proceedings against John Sanford, Emerson’s brother, in St. Louis Federal Court. Unfortunately for Scott, Sanford received a favorable ruling. Consequently, Scott decided to appeal to the U.S. Supreme Court (Dred Scott’s Fight). His argument was based on his claim of having been granted freedom while residing with his master in Illinois — a state where slavery was forbidden under the Missouri Compromise.
Emerson claimed that the Scotts unfairly took away her property, Dred Scott and his family, without proper legal proceedings or compensation. This action violated the Fifth Amendment in the case of Dred Scott v. Sandford. Chief Justice Taney, who incidentally had previously been a slave owner, delivered the majority opinion against Dred Scott with a 7-2 vote. Taney also stated that because Dred Scott was of African descent, he did not have citizen status and therefore could not sue in federal court. Additionally, Taney argued that since slaves were considered personal possessions at that time, Scott had never actually gained freedom (Dred Scott v. Sanford 63).
Two Justices, McLean and Curtis, had differing opinions on the decision. They argued that if the Court did not have jurisdiction to hear a case, it should dismiss it instead of giving a verdict. Additionally, they claimed that there was no Constitutional basis for denying black individuals citizenship. While the Constitution was being ratified, black men could vote in five out of thirteen states. As a result, they were considered citizens in their respective states as well as across the United States.
The Dred Scott decision is important because it is the first instance since Marbury v. Madison where The Supreme Court ruled that an act of Congress was unconstitutional.
The ruling of Congress was unable to prohibit slavery in federal territories, making the Missouri Compromise unconstitutional. This meant that individuals living in these territories had no say in whether their state would allow slavery or remain free. The Court’s decision undermined the concept of popular sovereignty and increased tensions between the North and South over slavery. As a result, this pushed the nation closer to civil war and hindered the efforts of the new Republican Party to prevent the expansion of slavery. It is worth noting that while not directly overturned by the Supreme Court, the Dred Scott Decision (Dred Scott v. Sanford 64) played a significant role in shaping these events.
The previous ruling was invalidated by two amendments to the Constitution. The Court recognized that part of it was rendered invalid by the 14th Amendment, enacted in 1868. This amendment stated that “All persons born or naturalized in the U.S., and subject to jurisdiction thereof, are citizens of the U.S. and of the state in which they reside.” Additionally, slavery was abolished through the 13th Amendment (US Constitution, Amendments 13 and 14). After the Court’s decision, Scott and his family were bought from their previous owner by Peter Blow, who granted them freedom. Furthermore, he helped them with their legal expenses. Unfortunately, Dred Scott passed away just nine months later (Dred Scott’s Fight).
