Scott v. Sandford
Brief on Scott v. Sandford. Submitted for PSCI 1111 on August 26, 2019.
The two parties to the Dred Scott case of 1857 were Dred Scott, the plaintiff, and John F. A. Sanford, the defendant. Dred Scott was born a slave and originally belonged to Peter Blow, a plantation owner. He was later sold to the U.S. Army surgeon John Emerson, whose death transferred Scott’s title to his widow, E. Irene Sanford Emerson. Henry T. Blow, son of Peter Blow and supporter of Scott’s quest to freedom, made possible a transfer of title to Scott from Irene Chaffee (formerly Irene Sanford Emerson) to her brother John Sanford of New York, thus allowing Scott to “take his case to federal court under diversity of citizenship jurisdiction” (Epstein and Walker 2020, 339). After the federal circuit court ruled in favor of Sanford, Scott appealed to the Supreme Court.
As Chief Justice Roger B. Taney summarized in his majority opinion, the legal issue before the Court was whether citizenship granted by the States to people descended from Africans held in slavery obtains the rights and privileges held by those whose citizenship is granted by the Constitution of the United States. Seven out of the nine justices concurred in the ruling that people of African descent “are not included, and were not intended to be included, under the word ‘citizens’ in the Constitution” (Epstein and Walker 2020, 340), therefore rendering them, Scott included, unable to sue in federal courts. In this sense, the Supreme Court decides that the Circuit Court lacked jurisdiction in Scott’s case and mandated this suit be dismissed.
Apart from concluding that Scott was not legally a United States citizen, the Court also ruled on two other issues. For the second time in history, the Court exercised judicial review by deeming the Missouri Compromise of 1820 unconstitutional on the grounds that the Fifth Amendment prevents citizens from being deprived of private property, in this case, slaves, without due process of law. In addition, the Court determined that the slaves’ freedom and status depend on “the law of the state to which they voluntarily returned, regardless of where they had been” (Epstein and Walker 2020, 344).
The Scott v. Sandford decision proved to be disastrous for the nation. The Northerners and Southerners seemingly resolved the controversy around slavery in 1820 through the Missouri Compromise. However, with the passing of the Kansas-Nebraska Act in 1854 and the Court striking down the Missouri Compromise, northerners and abolitionists were convinced that the Court was overwhelmingly pro-South and that the government was controlled by Southern slave owners. While most southern Democrats lauded the Taney court’s decision, some northern Democrats supported individual states’ ability to regulate slavery, thereby factionalizing the Democratic party. On the surface, the moral controversy of slavery appears to be the singular cause of the American Civil War. There is, however, another underpinning struggle for supremacy between federal and state governments constantly inflaming the already volatile country. The cause, process, and aftermath of the Dred Scott case illustrate a dangerously divided court—each one of the nine justices wrote an opinion—of a dangerously divided nation in an increasingly uncertain antebellum era.
Notes
Due to a clerical error, Sanford’s name was misspelled in court records; the case has thus been known as Scott v. Sandford.