Wombs of Liberation
In September 1810, Letty Ogleton and her five children—Henry, Michael, Lucy, Lucky, and Charles—filed a petition of freedom with the Prince George’s County Court of Maryland.1 According to the petition, the enslaved family was “entitled to their freedom having lineally descended from a free woman.”2 Letty understood that her familial line included a free woman, and she petitioned for her own freedom accordingly. She also understood that she could not leave her children enslaved. In fact, Letty was part of a complex familial circle that included kin scattered across Prince George’s County—family members who, like Letty, were equally concerned with freedom. From September to December 1810, fourteen enslaved Ogletons filed freedom petitions with the Prince George’s County Court.3 Much like the freedom suits of the Brown family examined recently by Loren Schweninger, the Ogletons offer a window into the crucial narratives of how freedom was constructed, pursued, and maintained by families of African descent in Maryland.4
Despite the fact that the Ogletons were enslaved by seven different owners and lived a distance from one another, they each advanced the same claim: they were descended from a free woman named Maria Ogleton. The Ogletons’ attorney, Enoch M. Lowe, testified in a freedom affidavit that the petitioners believed themselves to be “descended from Maria Ogleton, a free East Indian woman in the maternal line.”5 Late eighteenth-century petitions such as those advanced by the Ogletons thus reveal the way that freedom was rooted in reproduction and how the Black woman’s body constructed slavery and freedom.
Freedom petitions from the late 1700s reveal the complexities of race and gender in an age marked by revolution. According to the testimony of her descendants, Maria Ogleton did not “look Black.” Rather, with her glossy dark hair and red skin she closely resembled indigenous people; they argued that her origins were rooted, at least in part, among the eastern Caribbean Arawaks. This argument by her descendants—that Maria was not “Black” or “African”—was a strategic navigation of the racial landscape. The more notable freedom cases in Maryland reveal that manumission was more likely to be granted if one could prove one’s mother was a White, Indian, or woman of African descent born somewhere other than the United States.6 If proximity to Whiteness aided a freedom suit, then it is fair to assume that a distancing from “Blackness”—perhaps, more specifically, a distancing from what would later be considered “African Americanness”—aided those seeking freedom as well.7 As exemplified with the Ogleton suits, petitions delineated the intersectionalities of race, gender, reproduction, and motherhood manifested in Black women’s lives and that of their descendants. Blackness and womanhood were malleable concepts and open to interpretation; biology was not. Proximity to Whiteness aided in winning one’s freedom just as the proximity to the “monstrous” Black woman, as discussed by Jennifer L. Morgan, could limit one’s chances for manumission.8 Therefore, in the eyes of the court, Blackness remained synonymous with slavery, and notions of the Black woman’s body as evidence and as spectacle replayed themselves throughout courtrooms in the Early Republic; Maryland was no exception.
Slaveholders generally paid little attention to the biological connections among the people they owned unless it suited their interests, but the same could not be said of the enslaved. Testimony grounded in African American oral culture demonstrates that enslaved people not only scrupulously recounted the intricate interrelationships among their forebears but that they also used that knowledge as grounds for their emancipation.9 In this way, enslaved women in Maryland paralleled other African American women who petitioned for freedom in Revolutionary-era New England. Researchers Catherine Adams and Elizabeth Pleck, for example, demonstrate that legal consciousness was embedded in family ties and that the struggles of African American women in New England courtrooms was an extension of the families efforts to live together and secure freedom for those still in bondage.10 In the decades following the American Revolution, families such as the Ogletons hoped that by tracing their lineage to a free woman, they could avoid a life in bondage.
Unfortunately, the outcome of the Ogletons’ quest for freedom is unknown. The Ogleton family’s utilization of the legal system reveals much about the standing of enslaved people and the evolution of their designation as legal property to personhood, not only in the United States but also elsewhere in the African diaspora and exemplified by the situation in Cuba. Alejandro de la Fuente suggests that by making claims upon the legal system, enslaved people enter the archive as architects of their own liberation.11 Similarly, Laura Edwards argues that the actions of enslaved women, and more importantly their reactions to enslavement, shaped the law in South Carolina.12 Camillia Cowling’s research on Cuba suggests that enslaved women’s deployment of motherhood rights helped define freedom in Spanish slave societies.13 Enslaved women in Maryland, such as Letty Ogleton, entered the court record as litigants petitioning for their freedom or that of their children. Black women, more specifically their bodies, entered the legal archive as evidence, such as in the case of Maria Ogleton. Regardless of courts’ rulings, cases citing a mother’s free status opened questions regarding the woman’s complexion, hair, and physical features. Indeed, both in Maryland and elsewhere from the late eighteenth to the first half of the nineteenth century, Black women’s very bodies held the potential to determine one’s claim to freedom.
I argue that enslaved women were keenly aware that freedom, like slavery, was necessarily tied to their womb. Specifically, this chapter is concerned with the ways enslaved women and their descendants transformed their status from property / possession to legal actor by focusing on the relationship between maternity and freedom. Building on Janell Hobson’s recasting of Frantz Fanon’s argument that the body is indeed evidence, it is through the Black woman’s body, then, that freedom can be mapped both for what it includes as well as for what it excludes.14 Maternity shaped concepts of liberation for enslaved women just as their biological capacities shaped access to that freedom in Maryland. By examining the case of Letty Ogleton and her family, I show that enslaved people used their knowledge of local kinship ties and assessments of anti-Black sentiment to challenge the legal notion of Black people as property and to gain their freedom.
African women were brought into the port of Annapolis during the Atlantic slave trade and through Baltimore as part of the domestic slave trade. Both the slave trade and African Americans’ quest for freedom linked the mobility of the Black woman’s body to the larger Atlantic world. Maryland’s location (and in particular that of Baltimore and Annapolis) on the Atlantic meant that Black women’s physicality and the spaces they inhabited and traveled to held implications for freedom. Indeed, enslaved women’s very positionality shaped discussions of slavery and freedom during the Revolutionary era.
Enslaved Africans and African Americans in the newly formed United States borrowed the language of the American Revolution to advance their claims to freedom. In New England, Elizabeth Freeman, a midwife and domestic, became the first African American to petition for her freedom in what became the United States. At first called Bett by those who owned her, and later Mum Bett as she is more commonly known, Elizabeth took the name Freeman to signify her new status.15 Elizabeth Freeman was one of countless African Americans who shed a surname their owners gave them, if they had a last name at all. In the post-Revolutionary period, many free Blacks adopted the prefix free in names such as Freeman, Freedman, or Freedmen to signify their transition from enslaved to free.
Other Revolutionary-era Blacks used the courts to test the limits of their freedom. In 1781, New England resident Quok Walker sued Nathaniel Jennison for assault.16 Born to slavery in Massachusetts in the 1750s, Quok had been promised his freedom at age twenty-one by the Caldwell family. After the death of her husband, Isabell Caldwell remarried Nathaniel Jennison but she died when Quok was nineteen. Jennison refused to free Quok, who eventually ran away. When Jennison found him, he and a group of Whites beat him severely. Because Quok believed “freedom” to be his natural right, he did not feel the need to sue for it. Rather, he sued Jennison for assault.17 Douglas Egerton suggests that “Black Americans [such as Quok] immediately expected the Revolution to offer not merely new opportunities for freedom but also full participation in the new political order.”18 Thus, the courts provided a place to sue for freedom, maintain preexisting free status, and exercise one’s new rights once emancipated.19
The process of filing a petition for freedom was long and expensive. Bringing freedom suits in Maryland, as elsewhere in the recently formed United States, meant that the enslaved possessed enough social capital for someone to believe their case was worth advancing. Many plaintiffs benefited from their relationships with Quakers or other antislavery religions and organizations, which often filed and paid for suits on the petitioners’ behalf. Schweninger notes that fines and court costs could amount to hundreds and sometimes even thousands of dollars.20 Lawyers had to be hired in order to file the suits and the many motions that were necessary to ensure the appearance of the plaintiffs and defendants in court. The Ogletons’ lawyer, Enoch Lowe, followed up each Ogleton freedom petition with a summons to the respective owner. Moreover, Lowe filed a motion forbidding the various owners from selling any of the Ogletons or removing them from the state. The process was long, expensive, and potentially dangerous.
Enslaved Africans who brought freedom suits had to weigh the consequences of their actions. When Jean Baptiste, an émigré from Saint-Domingue (now Haiti), filed a freedom petition in Baltimore in 1818, he faced violent retaliation in his owner’s home.21 Schweninger notes that the “court assume[d] responsibility; the court usually made arrangements for the protection of the plaintiff[s] during the period of litigation. If they were returned to their owners, the court often required the owner to post a bond; if they feared retribution, the plaintiffs could be turned over to the sheriff for protection and hired out for payment of fees; very few ran away; [very few] were severely punished for bringing suit. Some slaves suing for freedom asked for injunctions prohibiting owners or others (slave traders) from taking them beyond the court’s jurisdiction.”22 Some of these cases were appealed and went on for years, which led to the enslaved people working as hirelings under court supervision.23 In some cases, the courts upheld the filed motions and ordered the owners not to sell the petitioner while the case was being heard. Other times, the courts went even further, adding that the owner could be punished if the enslaved person was harmed during the court proceedings. And in some cases the courts assumed legal responsibility for the enslaved person.24 Despite the fact that the court possessed the power to keep enslaved people safe, they did not fully trust the legal system to protect them. After all, it was the law of Partus Sequitur Ventrem (the status of the child follows that of the mother) that kept them enslaved.
Freedom petitions from Maryland provide evidence that the enslaved negotiated their claims to freedom through knowledge of their parentage. If the case made it to court, depositions could provide their lineage; defining this lineage was important to Whites and Blacks alike. Petitions highlighted the tensions involved when “property” sued for rights to their personhood. And petitions, particularly in the state of Maryland, represented the ebb and flow of egalitarianism as antislavery advocates championed the cases of the enslaved. In the decade after the American Revolution, the Maryland General Court of the Western Shore, for example, heard eleven petitions from enslaved people. This highest court in Maryland was the only place one could bring a freedom suit during the eighteenth century. Although the overall number of petitions is low in that period, the power of petitions is found not in the volume of cases heard by the General Court—the cases were heard at the rate of only one or two a year, typically included one or more petitioners in a single case, and were heard over successive sessions of the court. Rather, the power lies in the fact that the number of petitioners remained consistent even in the face of laws designed to keep them in bondage. Their efforts certainly fostered solidarity with others filing suits in other states.
In colonial times, the relationship that African Americans had with the law fluctuated. In 1664 the colony issued a directive that children born to a White woman and Black man (slave or free) would be reduced to the condition of a slave. A law passed in 1681 then repealed the previous ruling. However, that law restricted preexisting legal recourse because Black testimony was no longer allowed in court cases. The contradictory history of Africans and African Americans meant that, as the arbiter of justice, courts contributed to the oppression of Black men and women—but, at the same time, and perhaps more significantly, the courts also influenced the notion that freedom was biological.
The 1681 law left open a slim opportunity for enslaved people: they could sue for their freedom provided they were descended from a White woman. For that reason, the majority of the freedom suits in Maryland following the American Revolution did not invoke the revolutionary language such as equality and liberty that appeared in suits from other locales. Rather, petitioners cited their mothers’ free status as the supporting evidence in their suits, the only legal recourse available to them. In some cases the petition included a single plaintiff; in others, petitions were filed on behalf of several people. When Eleanor Toogood sued prominent Annapolis doctor Upton Scott, for example, she testified that she was descended from “a free white woman and well entitled to her freedom.”25 From October 1782 to May 1783, the court heard Toogood’s complex case, a story that was well known around the small state capital. Toogood presented evidence that she was the daughter of Ann Fisher, the granddaughter of a white indentured woman and a man of color man named Dick.26 The court found that Toogood’s claim to freedom was valid. Doctor Scott appealed the case to no avail; the court honored Toogood’s claim, and she remained free.
In 1782, a petition from Mary Butler, an enslaved washerwoman from St. Mary’s County, changed access to freedom for African Americans. Mary Butler could trace back her lineage one hundred years to an Irish immigrant named Eleanor Butler and “Negro Charles,” an enslaved man. Eleanor and Charles were married in 1681. This is probably not a coincidence, given that this is the very year that the earlier law condemning the offspring of such a marriage as theirs to slavery for life was repealed. This earlier law in turn had followed the precedent set by Virginia two years prior, in 1662, which ruled that the condition of the child followed that of the mother. With the repeal of the 1664 law, Eleanor and Charles could marry without punishment; Eleanor would remain “free,” and their children would not be doomed to lives of servitude. Nevertheless, Eleanor’s progeny and future descendants found themselves enslaved.27
Oral tradition was important to the descendants of Eleanor and Charles—Mary Butler was raised knowing their story, one passed down to her from older members of her family. Her parents, William and Mary, both declared descent from Eleanor and Charles. William was Eleanor’s grandson, and Mary was a great-granddaughter. There is debate as to how close the family lines were between the two parents. Martha Hodes suggests that Mary and William were cousins; Stephen Whitman suggests that they were husband and wife.28 According to court affidavits, both are true. That they are closely related is not surprising given the many ways that slavery blurred family lines.
In 1770, Mary’s parents unsuccessfully filed a petition for freedom. Despite this, their example stayed with her and ultimately influenced Mary to file her own petition sixteen years later. Mary Butler won her suit. Why did her suit work when it did not work for her parents, particularly when both suits were based on descent from the same woman? Stephen Whitman suggests that Butler won her case due to the lack of definitive evidence proving Eleanor married Charles. Thus, her descendants could not be enslaved under any laws.29 Martha Hodes, however, provides evidence of witnesses testifying that a wedding took place.30 Ultimately, Mary Butler’s successful outcome was based not on whether a wedding took place but rather on hearsay evidence that by the time of her case was permitted in courts.31
There is scholarly consensus that the admission of hearsay evidence changed the trajectory of freedom suits in Maryland.32 The transformative power of hearsay evidence resonates in the cultural realm as well. The orality of African and African American cultures proved valuable when narrating a family’s history with detailed testimonies documenting their family lines. And, as Schweninger proves, the majority of court testimonies demonstrate that it is women who were charged with preserving the family genealogy through oral tradition.33 Hearsay evidence, once inadmissible, presented a new opportunity for seeking freedom, and the Butler case in particular presented a new precedent for admitting evidence. Following the Butler ruling, freedom petitions based on descent from a free White woman were later presented by several enslaved families in Maryland: the Bostons, the Browns, the Queens, and the Shorters.34
The admission of hearsay evidence effectively allowed for a Black woman’s words, actions, and body to be entered as evidence in court cases. When brothers Charles and Patrick Mahoney sued for their freedom in 1791, they relied on the importance of their ancestor’s body and the places she traveled to advance their claims for freedom. The Mahoneys petitioned for their freedom from John Ashton, one of the highest-ranking Roman Catholic officials in Maryland and one of the founders of Georgetown University. The Mahoneys based their case on the fact that they descended from Ann Joice, a free woman. Joice was brought from Barbados to England sometime in the late 1670s, prior to arriving in Maryland. The Mahoneys’ lawyers argued that Joice was taken to England during her period of service and resided there for nearly three years. On the basis of having lived in England, they argued that neither she nor her descendants could be held as slaves. There was good precedent for this assumption: In 1772, Lord Mansfield of the English Court of the High Bench ruled in James Somerset v. Charles Stewart that slavery was “unsupported” in English common law. Further, Lord Mansfield determined that it was unlawful to forcibly bring a slave into England. Somerset contributed to the abolition of slavery in England and the emancipation of bond people throughout the British Empire as the nineteenth century progressed.35
While it has been widely understood that Somerset reverberated in the British Atlantic, its use by a Maryland plaintiff expands our understanding of its implications. As Eric Papenfuse notes, the Mahoneys’ case drew Maryland into a larger transatlantic debate about lineage, liberty, and the abolition of the slave trade.36 Certainly the use of Somerset signals that Maryland’s legal culture was in tandem with the Atlantic world. It also signaled that the Mahoneys themselves understood the implications of their ancestor traveling to England. Hoping to benefit from the Somerset precedent, the Mahoneys’ defense maintained that traveling to England effectively rendered Ann Joice “free.” It took seven years for the case to be decided, and when it was, the decision was not exactly the outcome that the Mahoneys had hoped. In 1798 the court granted Charles Mahoney his freedom, but reversed its ruling when John Ashton appealed the case.37 Frustrated to be so close to freedom and then to have it taken away, the Mahoneys felt they had little option but to run away. They were caught, however, and returned to Ashton.
Despite losing their case in court, in 1806 the Mahoneys received their freedom from Ashton. The following year, Ashton freed one of their siblings. By 1808, at least six of the seven Mahoney brothers were freed by John Ashton or by fellow Catholic Charles Carroll of Carrollton. What accounts for the manumission of the brothers? Ashton, like the Mahoneys, may have grown weary of the decadelong case; he knew full well the lengths enslaved people would go to achieve freedom. Also, the Mahoneys were not the only family held in bondage by Ashton who were suing him. In 1791, the same year the Mahoneys filed suit, Edward Queen also sued, citing assault and battery by his owner. Edward Queen and his family cited lineage from a free Black woman and argued that they were falsely enslaved. The court agreed and granted Queen his freedom. Following the ruling in 1795, twelve members of the Queen family left the Ashton property.38 What with the suits and the missing workers, the Queens and the Mahoneys took up a considerable amount of Ashton’s time. Ashton’s practice of owning slaves also began to attract criticism from other Jesuits. Whatever the reason, the Queens’ recalcitrant behavior paid off; eventually, Ashton officially freed ten of the twelve people who ran away.
The cases filed by the Mahoneys and the Queens exemplify how events not only in England but also in the larger Atlantic—Saint-Domingue—influenced the legal culture of Maryland.39 As French slave owners fled the island with their human chattel, they produced waves of retaliatory rulings on the part of American and West Indian courts. Eric Papenfuse argues that the rebellion in Saint-Domingue influenced the Maryland court’s decision to deny the Mahoneys their freedom.40 Indeed, events in Saint-Domingue triggered responses from Whites and Blacks throughout the Atlantic.41 For Whites, the uprising was the culmination of their worst fear: as succinctly stated by Leon Litwack, the so-called loyal slave picked up the gun and, in the case of Haiti, the machete.42 For Blacks in the United States, Haiti promised a world of new possibilities. Haiti connected slave-holders and the enslaved to a larger circle of rebellion in the Atlantic world. Rather than an isolated incident, the events in Haiti represented a new social order.
Haiti had a complicated relationship with property, power, and place. In 1792, Maryland lawmakers advocated for the relocation of White slaveholders fleeing Saint-Domingue. White refugees were welcome but free Black émigrés were not, and lawmakers even forbade slaveholders from Saint-Domingue from freeing their slaves while in Maryland, forcing them to wait three years before releasing anyone from bondage. Clearly, lawmakers had determined that Black rebellion was contagious and they would do what they could to discourage the manumission of Saint-Domingue Blacks.43
Freedom suits like those filed by the Mahoneys and the Queens allow us to assess the importance of place within the Atlantic world. But for other plaintiffs, the place that they occupied was as corporeal as it was geographical. In November 1797, Margaret Creek and her lawyer filed a freedom petition in the Baltimore County Court.44 According to the petition, Creek “had been entitled to her freedom from birth.” Creek claimed that she had been held illegally by William Wilkins and maintained that she was “the daughter of Rachel who was the daughter of an Indian woman named Moll or Mary.” According to the petition, Mary was “a free native of America who lived and died [as such].”45 Creek’s case took three years to travel through the courts, but ultimately, in March 1800, the court affirmed Creek’s freedom. Creek’s case bears resemblance to others of the era: she cited lineage from a free woman and was awarded her freedom. She filed the claim as the sole petitioner, so it is not clear whether she had an extensive kin network such as the Mahoneys and Queens. Nonetheless, Creek hired an attorney and utilized the courts and eventually laid claim to her freedom. Although little is known about her save the sparse details of the petition, Creek nonetheless entered the legal space as a woman sure of her heritage being both African and Native American. And if necessary, Creek would exploit one aspect of her heritage over the other if it meant living freely. In this way, Creek was similar to enslaved women in Cuba discussed by Camillia Cowling, who, by asserting their rights, reminded the court that they were not property but women.46 Cowling suggests that the nature of Black women making legal claims forced the court and, by extension, lawmakers to view the enslaved as people and, by further extension, to view Black women as women. There were gendered values assigned to freedom, but for Black women in particular, entering the legal record—the space of a courtroom—called into question the very same practices of law that placed them outside discussions of liberty, independence, and freedom in the first place.47 This was particularly important when considering the difference between Creek, who embodied the complexities of race, gender, and status, and Black women in Maryland, whose bodies entered the court record as evidence.
Consider the discussions about the appearance of Catherine Booth. Booth enters the court record via testimony presented in the freedom suit of her descendant, Richard Booth. In 1792, Booth petitioned the Maryland General Court claiming that he “was descended from a free woman and is unjustly deprived of his Liberty by David Weems.”48 Booth maintained that his great-grandmother, Catherine Booth, was freed by her owner, King Harrison.49 Richard Booth’s petition was initially denied and later appealed; the result of that appeal is unknown. But the records of the appeal provide a compelling window into the ways in which physical appearance and racial logic were appended to freedom claims.
Scattered throughout approximately seventy pages of court testimony are the outlines of a second trial—that of Catherine Booth. Deponents on both sides were asked a series of questions: Were they related to either David Weems or Richard Booth? Did they know the great-grandmother Catherine (Kate) Booth? Did they know her daughter Sally? Did they know Sally’s daughter Esther, the mother of Richard Booth? What did deponents know about Kate’s status as free or slave? What did Kate look like? How did her hair look? Witnesses gave conflicting accounts of Catherine’s status, of whether she was a slave or was free; accounts were also given about her heritage, the color of her skin, and the grade of her hair. This line of questioning was standard for petitions based on descent from a “free” woman who was also Black. As with the case of Ann Joice, if it could be determined that the woman did not “look Black,” then the chances for freedom were often greater. Certainly litigants identified as Black; however, they did not envision a life of slavery for themselves. They used whatever was in their limited arsenal to plot a course for liberation.
Black women’s bodies were used as evidence, and, ironically, it was precisely the distancing from Blackness that provided a loophole for the enslaved to win their cases. If it entered the courtroom as evidence, a Black woman’s body connected her descendants to the revolutionary Atlantic, where the questions of slavery and freedom were quite literally being mapped as one traveled between metropoles, colonies, and former colonies. If she had been free, or if she had traveled to someplace and her status had changed, or if it was determined that she had not possessed traits that were distinctly African, her descendants had a claim to freedom. It is both painful and ironic that African Americans renounced their racial identity (at least on paper) in their quest for freedom. The nature of these questions conveys that there was something fundamentally integral about the value of Black women in Revolutionary society. For her descendants, a Black woman’s positionality was marked by geography, physicality, and physiology; in addition, as discussed below, freedom was marked biologically.
Petitioners in the late eighteenth century counted on genealogy to bolster their freedom claims, but by the beginning of the nineteenth century, the courts responded by essentially refusing to hear genealogical claims to freedom even as they reinscribed the relationship between reproduction and racial slavery. During the early part of the nineteenth century, county courts throughout Maryland were authorized to hear freedom suits. This allowed enslaved men and women to present cases in local courts, thus avoiding the obstacles to obtaining access to the highest court in Maryland. The provincial courts continued to hear cases, but these were limited to appeals rather than entire suits; the power to hear petition suits was transferred to the lesser courts. In addition to the shift in the location of freedom suit hearings, a much more important transformation was also under way. In November 1809, the Maryland State Legislature introduced a law that they believed solved persistent petitions from bond people who cited their mothers’ free or manumitted status as justification for their own release from bondage. The “Act to Ascertain and Declare the Condition of Such Issue as May Hereafter Be Born of Negro or Mulatto Female Slaves” enabled planters to determine the status of any living or future child born to bondwomen to whom they had promised freedom. If declarations of the status of future children were not made at the time the manumission document was presented in court, “then the state and condition of such issue shall be that of a slave.”50
Presented one year after the U.S. Constitution outlawed participation in the international slave trade, the 1809 law reconciled two opposing yet interrelated facts. The first is that the existence and expansion of the southern slave system depended on the reproductive labor of bondwomen.51 Slave owners were keenly aware that enslaved women might conceive children after they were promised freedom but before they were released from bondage. The decision to free an enslaved woman involved measuring the potential value of her future labor against the loss of the physical and reproductive labor of both mother and child. Indeed, Stephen Whitman suggests that the majority of young girls who were promised freedom remained in slavery well past their childbearing years.52 The second is that the propensity of Maryland owners to manumit slaves had the potential to dismantle the slave state. By passing the 1809 law, legislators attempted to obstruct the ability of manumitted women to produce “free” people by closing avenues to freedom based on the mother’s status. In doing so, legislators, many of whom owned bond people, reaffirmed the power of slaveholders to assert do-minion over their property. Moreover, the 1809 law represented what lawmakers, slaveholders, and bond people already knew: that freedom, like enslavement, was tied to a bondwoman’s womb.
By the time the 1809 law was passed, planters had realized that the only legal way they could obtain new slaves was through the reproductive work of their enslaved female population; thus, the decision to manumit a bondwoman involved even more economic disincentives. The 1809 law’s emphasis on the slave status of the children of manumitted women effectively prolonged enslavement for another generation of African Americans and ensured that owners would continue to profit from enslaved labor.53 The law was similar to the precedent set in New Amsterdam (now New York) during the seventeenth century, whereby the enslaved were given “half-freedom”: In exchange for their freedom, enslaved men and women agreed that existing or future children would be enslaved and work for the Dutch West India Company. In this way in Maryland, the gradual emancipation of children often meant that enslaved children remained under the control of their mother’s master until they reached adulthood.54 In this system of postnati service, owners promised freedom to children but waited until a time when either they profited little from a child’s labor or the child had reached an age of self-sufficiency. A substantial proportion of antebellum Baltimore’s free Black population was born as slaves and gained their freedom as young or middle-aged adults.55 Perhaps provisions for postnati service stemmed from planters’ reluctance to lose the potential revenue from sales of children. If that were the case, then the goal of the 1809 law was not to expand freedom through the manumission of bondwomen; rather, as Whitman argues, it was to constrict freedom by allowing planters to determine the postnati status of slave children.56
Although the 1809 law restricted access to freedom for future generations, it did not diminish the efforts of African American women and their descendants to use legal and extralegal measures to access freedom. In the ten years before the law was passed, six African Americans filed freedom petitions in Maryland’s higher courts.57 From 1810 to 1820, ten did so. Schweninger’s research at the county court level reveals a similar trend.58 From 1799 to 1809, twelve freedom petitions were presented in Maryland county courts; between 1810 and 1820, seventeen petitions were filed.59
Petitioners had to prove that their status as enslaved, free, or gradually manumitted was delineated prior to their mother’s manumission. Such was the case of bondwoman Lurena and her daughter Ellen. In 1810, Lurena was promised freedom in the last will and testament of her owner, Rezin Hammond, when she reached the age of thirty.60 Additionally, it stated that any children born to her were to be freed at age twenty-nine. Hammond’s heirs failed to honor the wishes of the deceased and not only kept the mother and her child in bondage but sold them as well. In 1812, two years after the sale, Lurena petitioned for and gained her freedom on the grounds that she was thirty years old at the time of Rezin Hammond’s death. Ellen was awarded freedom because she was born after the date of her mother’s promised emancipation.61 Thus, Ellen was illegally enslaved from birth. This case illustrates the complicated legal process of manumission, which often stretched across generations and frequently folded maternity into freedom petitions.
The 1809 law held three significant consequences for understanding how the Black woman’s reproductive body was deployed within the law. First, because the law was framed entirely in terms of “women and their issue,” the families of manumitted women were not understood to include the fathers of the children. This framing altered the definitions of household and family for manumitted women. Second, the terms of the law often staggered the dates of manumission for women and their children. As a consequence, responsibility for the upbringing of children was often extended through the mother’s extended kinship networks. Third, this shift in legal responsibility laid the foundation for future dialogues about gender, race, and poverty. African American women responded to all three consequences by drawing from the same support systems that had aided them in slavery, namely their extended kin networks.62
While the 1809 law had particular importance for African American women and their families, it also provided a mechanism for the planters to keep the children of manumitted women as insurance, in case the economy called for enslaved labor in the future. On one hand, the law could provide an opportunity to escape the system of slavery. On the other hand, the 1809 law could prolong the enslavement of children. Yet interventions by enslaved women and their children challenged the intention of the 1809 law to guarantee the future of slavery through natural reproduction.
With successive generations of African Americans gaining freedom, it is not surprising that African American women went from being perceived as pieces of evidence used by their descendants to obtain freedom to litigants petitioning for the freedom of their children. In this regard, African American women in Maryland were not unique. Following her emancipation in 1827, Isabella Baumfree (later Isabella Van Wagenen, who eventually became known as Sojourner Truth) sued Solomon Gedney for selling her son Peter to an owner in Alabama. Baum-free won her suit, and Peter was recovered and returned to her.63
Working within the system meant that for better or worse, enslaved people were subject to the law. Nat Turner’s rebellion in Southampton, Virginia, while a victory in the eyes of the enslaved, resulted in tighter restrictions on the lives of manumitted women and their kin. Across the South, laws quickly developed that demanded African Americans relocate outside a state once they were freed, and Maryland was no exception. These laws proved particularly painful for manumitted women whose children were enslaved. In 1833, recently manumitted Sophia Tydings petitioned the judges of the Anne Arundel County Orphans’ Court to be allowed to stay in the state of Maryland so that she could be close to her husband, who was free, and her ten children, who were still enslaved.64 Tydings’s request was based on her role as a mother; her petition noted that she “still had an infant at her breast.”65 Tydings was permitted to stay in the state another twelve months. Although the court records do not indicate whether she obeyed the order to leave her children behind the following year, the temporary reprieve must have been excruciating. Facing reenslavement for failing to follow a court order on the one hand and the loss of her children on the other, Tydings’s fate was similar to Solomon Northup’s—but in the extreme. She faced possible reenslavement should she stay in the state after the expiration date on her freedom permit. Tydings served as an example that, as mothers, manumitted women reminded planters and lawmakers that their familial responsibilities did not end when their freedom began. The court’s tendency to grant requests such as these revealed the court’s innate notions about biology and the health and care of the slaveholder’s property. After all, it benefited the state for Tydings to remain in Maryland to nurse her child, thus providing essential nutrients to an individual destined to spend their life as someone’s human property.
Tydings’s vulnerability to the court indicates the larger systemic violence of enslavement—the absence of a private life even in freedom. When Robert Williams purchased his wife, Susannah, he did so with the intention of freeing her. A great deal of time passed without Susannah being manumitted. Robert Williams, it seemed, was “deprived of his understanding.” The court labeled Williams a “lunatic.”66 Susannah petitioned on behalf of herself and her children to be freed rather than sold to another owner, as Robert seemed ill equipped to provide for his enslaved property—whether or not they were his kin was beside the point. In 1806, the General Assembly of Maryland passed a law transferring Susannah and her children to the chancellor, who would then free them in six months’ time.67 At the end of six months, Susannah and her children were to be manumitted and finally experience the liberation promised years ago. For Susannah, freedom meant that she was not entitled to the private space normally allowed families, for her husband’s health necessitated that the court intervene several times during her journey from bondage.
For enslaved people bringing suits, the experience of freedom was just as important its legality. In 1832, a man known only as “Negro Joe” sued for his freedom. He claimed that he was entitled to his freedom based on the fact that his grandmother, Lavinia, and his mother, Dinah, lived “free and undisturbed in possession of their liberty and freedom.” According to court testimony, Lavinia and Dinah lived like free women following the 1797 death of their owner, William Machubin. One witness noted that Lavinia and Dinah “were going at large as free women living acting and passing [as free] in all respects,” indicating that, over the course of thirty-plus years, the women and their descendants lived as if they were free. According to Joe, the two women continued in the “free and undisturbed possession of their liberty and until the death of Machubin’s wife.” In 1824, court testimony offered that Elizabeth Machubin “never set up any claim to them.” For descendants of Lavinia and Dinah, the experience with freedom nearly came to an end in 1832: Elizabeth Machubin’s husband, John M. Burke, inherited her property. At that time, Burke also laid claim to Joe and several relatives. The Anne Arundel County Court agreed with Joe and awarded him his freedom in 1832. The following year, Burke initiated an appeal with the Court of Appeals for the Western Shore, which upheld the lower court’s ruling and “Negro Joe” remained free. He had traded the experience of freedom enjoyed by his female predecessors for a legal document stating what he already knew to be true—that he was not property.68
As the example of “Negro Joe,” indicates, freedom as an experience was not lost on free or enslaved Blacks. Writing about free Black women in South Carolina, Amrita Myers notes that glimpsing and experiencing freedom were precursors to being formally emancipated.69 What makes the case of this family different is that neither the women nor their descendants were legally emancipated. For “Negro Joe” and other descendants, the experience of freedom preceded their actual status as free Blacks, and many Whites and Blacks in the surrounding area considered them to be free people.
Freedom came with consequences. Whereas the descendants of Lavinia and Dinah were successful in maintaining their freedom, others obtained freedom as long as they enjoyed it outside the United States, epitomized by the case of Betsey and John, an enslaved couple in Frederick County, Maryland. John and Betsey were granted freedom by their owner’s will and testament in 1828. Additionally, “any issue of her body” was to be freed as well—provided that the family “leave the United States.”70 The decision to free the couple on the condition that they emigrate was undoubtedly directed in part by the fact that many of the Maryland elite were active in campaigns to resettle Blacks in Liberia.71 The example of this family underscores how even the promise of freedom had the potential to break up extended families; they would have had to leave familiar surroundings in order to enjoy their freedom. In this instance, where the family enjoyed their freedom was as crucial to lawmakers as how they enjoyed that freedom was to the enslaved.
Place mattered in the lives of Black women and their ability to live freely—whether it was where they could live freely, where they moved to enjoy it, or, in this case, how they used their power to prevent the moving of their children. In neighboring Washington, D.C., Sally Henry, a free woman of color, petitioned the court to prevent an owner from selling her daughter outside of the district. Henry based her request on the fact that her daughter was awaiting a decision from a higher District of Columbia court regarding emancipation.72 Henry’s request was granted and her daughter remained in the city. It is not known if the younger Henry was manumitted at some point later.
The transition of African American women from bodies to agents represents the growing presence and power of free Black women as mothers. Patricia Reid, in her work on Margaret Morgan, reminds us that the experience of freedom was not limited to how Black women and their families perceived it.73 Morgan was enslaved by John Ashmore. She was promised her freedom by Ashmore in Maryland, but the deed was never executed. Since the promise of freedom, she had traveled to Pennsylvania (a free state) and lived there. Ashmore’s heirs decided to reclaim Morgan and the children she bore since leaving Maryland. Having tried unsuccessfully to bring Morgan back to Maryland, Edward Prigg, a slave catcher, brought the case to court in Pennsylvania, the commonwealth where Morgan resided. Though slavery was not legal in Pennsylvania, it was ruled that states held no power in obstructing slave owners from recovering their property. As exhibited in Prigg v. Pennsylvania (1842), the attempts of Black women and their kin had national implications as well. These questions of personhood, place, positionality, and traversing slavery and freedom were not resolved in Prigg v. Pennsylvania. It would take a suit filed by Dred Scott to force the courts to decide whether African Americans were people or property. For African Americans, the answer was simple; for the nation, the question, the answer, and the responses to the question hastened the country to civil war.
Despite the relatively small number of petitions presented in the wake of the American Revolution, Black women’s presence in Maryland courts shifted dramatically from the late eighteenth century to the middle of the nineteenth century. During the revolutionary era, African Americans used their descent from a White woman or free Black woman as a justification for freedom until the mid-nineteenth century, when Black women could enter the court as litigants on behalf of their children. The small absolute number of petitions should not minimize their importance—these successful petitions gave hope and encouragement to others who were enslaved.
Access to freedom in Maryland reaffirmed the central role of women’s reproductive labor just as the ability to petition for freedom based on the mother’s status revealed the centrality of Black women’s bodies in the law. Even when petitioners cited descent from a White or Indian woman, an implicit statement was made regarding the law: Blackness equated to enslavement, and a distancing from Blackness equaled freedom in the eyes of the court. The descendants of White, Indian, and Black women demonstrated that manumission continued to be linked to women’s reproductive capacities. The nature of this right to petition changed over time; as it did, so too did Black women’s ability to use the law to their advantage. They transitioned from being dissected as evidence to plaintiffs citing their role as mothers in order to enhance their legal rights. Although the nature of how Black women used and were used in court changed from the late eighteenth to the mid-nineteenth centuries, the efforts of African Americans challenged the intent of slavery through natural reproduction by demonstrating that freedom was also inheritable.
The author thanks the University of Georgia Press for permission to reprint portions of this chapter from Jessica Millward, Finding Charity’s Folk: Enslaved and Free Black Women in Maryland (Athens: University of Georgia Press, 2015).
1. Letty Ogleton and her five children, Petition for Freedom, September 10, 1810, Black Papers, Prince George’s County Court, Maryland State Archives, Annapolis, Md. (hereafter MDSA). See also accession no. 008967-002-1034, Race, Slavery, and Free Blacks, ser. 2: Petitions to Southern County Courts, part B: Maryland (1775–1866), Delaware (1779–1857), District of Columbia (1803–1865), Slavery and the Law, Pro-quest History Vault, 2012 (hereafter PHV 2012).
2. Letty Ogleton and her five children, Petition for Freedom, September 10, 1810, MDSA.
3. Anthony [Ogleton], Petition for Freedom, September 10, 1810, MDSA; Amy Ogleton, Petition for Freedom, September 10, 1810, MDSA; Eliza Ogleton and her three children, Petition for Freedom, September 10, 1810, MDSA; Letty Ogleton and her five children, Petition for Freedom, September 10, 1810, MDSA; Amy and Daniel Ogleton, Petition for Freedom, September 10, 1810, MDSA; Milly Ogleton, Petition for Freedom, September 10, 1810, MDSA; Harry, Joan, Mary, Sukey and Nelly, Petition for Freedom, September 10, 1810, MDSA; Charles and Francis Ogleton, Petition for Freedom, September 10, 1810, MDSA.
4. Loren Schweninger, “Freedom Suits, African American Women, and the Genealogy of Slavery,” William and Mary Quarterly 71, no. 1 (January 2014): 33–62.
5. Rezin Ogleton, Freedom Affidavit, September 1810, Prince George’s County, 1810–1850, Maryland State Archives, Archives of Maryland Online, accessed May 6, 2014, http://aomol.msa.maryland.gov/000001/000763/html/am763-1.html.
6. See, for example, Eric Robert Papenfuse, “From Recompense to Revolution: Mahoney v. Ashton and the Transfiguration of Maryland Culture, 1791–1802,” Slavery and Abolition 15, no. 3 (1994): 38–62; and Martha Hodes, White Women, Black Men: Illicit Sex in the Nineteenth-Century South (New Haven, Conn.: Yale University Press, 1999).
7. Jessica Millward, “‘That All Her Increase Shall Be Free’: Enslaved Women’s Bodies and the Maryland 1809 Law of Manumission,” Women’s History Review 21, no. 3 (2012): 363–78. See also Cheryl Harris, “Whiteness as Property,” Harvard Law Review 106, no. 8 (1993): 1709–91.
8. Jennifer L. Morgan, “Gender and Family Life,” in The Routledge History of Slavery, ed. Gad Heuman and Trevor Burnard (New York: Routledge, 2011), 138–52, esp. 139.
9. Schweninger, “Freedom Suits,” 40.
10. Catherine Adams and Elizabeth H. Pleck, Love of Freedom: Black Women in Colonial and Revolutionary New England (New York: Oxford University Press, 2010), 132.
11. Alejandro de la Fuente, “Slave Law and Claims-Making in Cuba: The Tannenbaum Debate Revisited,” Law and History Review 22, no. 2 (2004): 339–69, esp. 346.
12. Laura F. Edwards, “Enslaved Women and the Law: Paradoxes of Subordination in the Post-Revolutionary Carolinas,” Slavery and Abolition 26, no. 2 (2005): 305–23, esp. 305–6.
13. Camillia Cowling, “Debating Womanhood, Defining Freedom: The Abolition of Slavery in 1880s Rio de Janeiro,” Gender and History 22, no. 2 (2010): 284–301.
14. Janell Hobson, Body as Evidence: Mediating Race, Globalizing Gender (Albany: State University of New York, 2012), 5.
15. Adams and Pleck, Love of Freedom.
16. Douglas Egerton, Death or Liberty: African Americans and Revolutionary America (New York: Oxford University Press, 2009), 95. See also James Oliver and Lois E. Horton, In Hope of Liberty: Culture, Community, and Protest among Northern Free Blacks, 1700–1860 (New York: Oxford University Press, 1997).
17. Egerton, Death or Liberty, 93–95.
18. Ibid., 95.
19. See Adams and Pleck, Love of Freedom, 127.
20. Schweninger, “Freedom Suits,” 55.
21. Martha S. Jones, “The Case of Jean Baptiste, un Créole de Saint-Domingue: Narrating Slavery, Freedom, and the Haitian Revolution in Baltimore City,” in The American South and the Atlantic World, ed. B. Ward, M. Bone, and W. A. Link (Gainesville: University Press of Florida, 2013), 119.
22. Loren Schweninger, e-mail exchange with author, April 2, 2014.
25. Eleanor Toogood v. Upton Scott, August term, 1782, Maryland General Court of the Western Shore, Appeals and Judgments, MDSA. See also accession no. 20978201, PHV 2012.
26. Eleanor Toogood v. Upton Scott.
27. Mary Butler v. Adam Craig, October 1783 Term, Maryland General Court of the Western Shore, Appeals and Judgments, Maryland State Archives (Annapolis, Md.). This case is also discussed in Martha Hodes, White Women, Black Men: Illicit Sex in the Nineteenth-Century South (New Haven, Conn.: Yale University Press, 1997), 19–38; and T. Stephen Whitman, Challenging Slavery in the Chesapeake: Black and White Resistance to Human Bondage, 1775–1865 (Baltimore: Maryland Historical Society, 2007), 62–65.
28. Hodes, White Women, Black Men, 19–38; see also Whitman, Challenging Slavery in the Chesapeake, 62–65.
29. Whitman, Challenging Slavery in the Chesapeake, 64.
30. Hodes, White Women, Black Men, 20.
31. As noted in the work of Loren Schweninger, by the mid-1780s, “hearsay” stories—that is, oral history from free and formerly enslaved Blacks—were allowed as evidence in Maryland courts. See Loren Schweninger, “Freedom Suits, African American Women, and the Genealogy of Slavery, William and Mary Quarterly 71, no. 1 (2014): 35–62, 41.
32. Ira Berlin, Slaves without Masters: The Free Negro in the Antebellum South (New York: Pantheon Books, 1977); Schweninger, “Freedom Suits”; and Whitman, Challenging Slavery in the Chesapeake, 95.
33. Schweninger, “Freedom Suits,” 39–40; see also Loren Schweninger, The Southern Debate over Slavery: Petitions to Southern County Courts, 1775–1867 (Urbana: University of Illinois Press, 2008), 2:165.
34. For details of these cases, see Schweninger, “Freedom Suits,” 35–62.
35. Dana Rabin, “‘In a Country of Liberty’? Slavery, Villeinage and the Making of Whiteness in the Somerset Case (1772),” History Workshop Journal 72 (Autumn 2011): 5–29.
36. Papenfuse, “Recompense to Revolution.”
37. Archives of Maryland Biography Series, Reverend John Ashton, http://msa.maryland.gov/megafile/msa/speccol/sc5400/sc5496/041700/041715/html/041715bio.html, accessed April 28, 2014.
39. Ada Ferrer, Freedom’s Mirror: Cuba and Haiti in the Age of Revolution (New York: Cambridge University Press, 2014); and Rebecca J. Scott, Degrees of Freedom: Louisiana and Cuba after Slavery (Cambridge, Mass.: Harvard University Press, 2005).
40. Papenfuse, “Recompense to Revolution,” 62.
41. James Sweet, Recreating Africa: Culture, Kinship, and Religion in the African-Portuguese World, 1441–1770 (Chapel Hill: University of North Carolina Press, 2003); James Sidbury, Becoming African in America: Race and Nation in the Early Black Atlantic (New York: Oxford University Press, 2007); Laurent DuBois, Avengers of the New World: The Story of the Haitian Revolution (Cambridge, Mass.: Belknap Press of Harvard University Press, 2004).
42. For discussion of slavery and resistance, see Leon Litwack, Been in the Storm So Long: The Aftermath of Slavery (New York: Vintage Press, 1979), esp. chap. 1, “The Faithful Slave,” 1–53; and David P. Geggus, ed., The Impact of the Haitian Revolution (Columbia: University of South Carolina Press, 2001).
43. Jones, “Case of Jean Baptiste,” 106.
44. Margaret Creek v. William Wilkins, Petition for Freedom, November 1797, General Court of the Western Shore, accession no. 20979704, PHV 2012.
46. Camillia Cowling, Conceiving Freedom: Women of Color, Gender, and the Abolition of Slavery in Havana and Rio de Janeiro (Chapel Hill: University of North Carolina Press, 2013).
47. Ibid., 378.
48. Richard Booth v. David Weems, General Court of the Western Shore, accession no. 20978908, PHV.
50. “1809 Law of Maryland,” in Index to the Laws of Maryland, ed. William Kilty (Annapolis, Md.: Jeremiah Hughes Printing, 1820), 192.
51. For the most recent literature on bondwomen and reproduction, see Daina Ramey Berry, “Swing the Sickle for the Harvest Is Ripe”: Gender and Slavery in Antebellum Georgia (Urbana: University of Illinois Press, 2007), 77–84; and Jennifer L. Morgan, Laboring Women: Gender and Reproduction in New World Slavery (Philadelphia: University of Pennsylvania Press, 2004). For discussion of slave law, see Joseph C. Dorsey, “Women without History: Slavery and the International Politics of Partus Sequitur Ventrem in the Spanish Caribbean,” Journal of Caribbean History 28, no. 2 (1994): 165–207. For classic studies, see Deborah Gray White, Ar’n’t I a Woman? Female Slaves in the Plantation South (New York: W. W. Norton, 1985); and Barbara Bush, Slave Women in Caribbean Society, 1650–1838 (Bloomington: Indiana University Press, 1990).
52. Whitman, The Price of Freedom, 23.
53. Ibid., 123.
54. Leslie M. Harris, In the Shadow of Slavery: African Americans in New York City, 1626–1863 (Chicago: University of Chicago Press, 2003), 23–25. See also Morgan, “Gender and Family Life,” 146; and Ruth Wallis Herndon, Unwelcome Americans: Living on the Margin in Early New England (Philadelphia: University of Pennsylvania Press, 2001).
55. Whitman, Price of Freedom, 27.
56. Ibid., 123.
57. See Helen T. Catterall, Judicial Cases Concerning American Slavery and the Negro (1926), Digital Library on American Slavery, http://library.uncg.edu/slavery_petitions, accessed June 27, 2017; Jennifer Hull Dorsey, “Documentary History of African-American Freedom: An Introduction to the Race, Slavery and Free Blacks Microfilm Collection,” Slavery and Abolition 30, no. 4 (2009): 545–63; and Schweninger, Southern Debate over Slavery.
58. Maryland General Court of the Western Shore, Appeals and Judgments, MDSA 1810–1820; Schweninger, Southern Debate over Slavery; and Schweninger Collection, MDSA.
59. Maryland General Court of the Western Shore, Appeals and Judgments, MDSA, 1780–1820; see also Schweninger, Southern Debate over Slavery.
60. Lurena and Ellen, Petition for Freedom, 1818, accession no. 20981604, PHV 2012.
62. African American networks included abroad marriages and were nuclear, matrifocal, matrilocal, fictive, and extended in scope. See Brenda E. Stevenson, “Black Family Structure in Colonial and Antebellum Virginia: Amending the Revisionist Perspective,” in The Decline in Marriage among African Americans, ed. M. Belinda Tucker and Claudia Mitchell-Kernan (New York: Russell Sage Foundation, 1995), 27–56; and Dylan Penningroth, The Claims of Kinfolk: African American Property and Community in the Nineteenth-Century South (Chapel Hill: University of North Carolina Press, 2003). For the relationship between African cultural survivals and Christianity, see Walter Rucker, The River Flows On: Black Resistance, Culture, and Identity Formation in Early America (Baton Rouge: Louisiana State University Press, 2005); and Sylvia Frey and Betty Wood, Come Shouting to Zion: African American Protestantism in the Americas (Chapel Hill: University of North Carolina Press, 1998).
63. Margaret Washington, Sojourner Truth’s America (Urbana: University of Illinois Press, 2009).
64. Schweninger, Southern Debate over Slavery, 165.
66. Susannah Williams, Petition, February 1806, Schweninger Collection, MDSA. See also accession no. 20980604, PHV 2012.
67. Susannah Williams, Deed of Manumission, 1805, Anne Arundel County Court, Manumission Record, 1797–1807, vol. 825, p. 259. See also Archives of Maryland Online, http://aomol.msa.maryland.gov/000001/000825/html/am825-259.html, accessed June 27, 2017.
68. Negro Joe, Petition for Freedom, 1832, accession no. 20983202, PHV 2012.
69. Amrita Chakrabarti Myers, Forging Freedom: Black Women and the Pursuit of Liberty in Antebellum Charleston (Chapel Hill: University of North Carolina Press, 2011).
70. Chester Coleman to John and Betsey, 1828, Frederick County Court Petitions, 1783–1847, MDSA.
71. Eric Burin, The Peculiar Solution: A History of the American Colonization Society (Gainesville: University Press of Florida, 2005); Claude Clegg, The Price of Liberty: African Americans and the Making of Liberia (Chapel Hill: University of North Carolina Press, 2004); R. J. M. Blackett, Beating against the Barriers: Biographical Essays in Nineteenth-Century Afro-American History (Baton Rouge: Louisiana State University Press, 1986); Michele Mitchell, Righteous Propagation: African Americans and the Politics of Racial Destiny after Reconstruction (Chapel Hill: University of North Carolina Press, 2004); and Penelope Campbell, Maryland in Africa: The Maryland State Colonization Society, 1831–1857 (Urbana: University of Illinois Press, 1971).
72. Sally Henry Petition, 1814, accession no. 20481403, PHV 2012.
73. Patricia A. Reid, “Margaret Morgan’s Story: A Threshold between Slavery and Freedom, 1820–1842,” Slavery and Abolition 33, no. 3 (2012): 359–80.