Legal Definitions - Dred Scott v. Sandford (1857)

The case of Dred Scott v. Sandford (1857) was a landmark decision by the U.S. Supreme Court that profoundly impacted American history and significantly escalated tensions leading to the Civil War. The Court's ruling had two primary, far-reaching consequences:

• First, it declared that African Americans, whether enslaved or free, were not citizens of the United States. As a result, they could not sue in federal courts or claim the rights and privileges of U.S. citizenship.
• Second, the Court ruled that the federal government did not have the authority to prohibit slavery in any U.S. territory. This effectively invalidated the Missouri Compromise and other federal laws designed to limit the expansion of slavery, asserting that slave owners had a constitutional right to take their "property" (enslaved people) into any territory.

This decision was widely condemned by abolitionists and is largely regarded as one of the worst rulings in Supreme Court history. Its legal principles were ultimately overturned by the Fourteenth Amendment to the U.S. Constitution, ratified after the Civil War, which established that all persons born or naturalized in the United States are citizens.

Here are some examples illustrating the implications of the Dred Scott decision:

Example 1: Denied Access to Federal Courts

Imagine a free African American carpenter living in Ohio in 1858. He had a business agreement with a lumber supplier from Kentucky, but the supplier failed to deliver the promised materials, causing the carpenter significant financial losses. The carpenter believes he has a strong case and wants to sue the supplier in a federal court, hoping for a fair resolution that might be difficult to achieve in a state court in Kentucky. Under the Dred Scott ruling, this carpenter, despite being a free man and a resident of a free state, would be denied the ability to file a lawsuit in federal court. The Court's decision explicitly stated that African Americans were not U.S. citizens and therefore lacked the legal standing to bring cases before federal tribunals, regardless of their individual circumstances or the merits of their claim.

Example 2: Expansion of Slavery into "Free" Territories

Consider a wealthy plantation owner from Georgia in 1859 who decides to move his entire operation, including dozens of enslaved individuals, to the newly opened Dakota Territory. Prior to Dred Scott, federal law might have prohibited slavery in this territory, or at least allowed for a popular vote to decide its status. However, after the ruling, the plantation owner would be legally protected in bringing his enslaved workforce. The Dred Scott decision declared that Congress (the federal government) could not prevent slave owners from taking their enslaved people into any U.S. territory. This meant that even in territories previously designated as "free" by federal legislation, the institution of slavery could legally exist and expand, effectively nullifying any federal attempts to contain its spread.

Example 3: Inability to Claim Freedom Based on Residence in a Free Area

Suppose an enslaved family was taken by their owner from Maryland to the Oregon Territory in 1860, where they lived and worked for several years before the owner decided to return to Maryland. Upon their return, the family attempts to sue for their freedom, arguing that their prolonged residence in a territory where slavery was not permitted should have automatically made them free. Based on the Dred Scott ruling, their claim would be rejected. The Court held that even if an enslaved person resided in a territory where slavery was outlawed, that residence did not confer freedom because the federal government lacked the power to prohibit slavery in territories. Furthermore, as African Americans, they would not have been considered U.S. citizens and thus could not sue in federal court to begin with, reinforcing their status as property rather than individuals with legal rights to assert their freedom.