Feb 9, 2025 Story by: Editor
The Dred Scott v. Sandford case, decided by the U.S. Supreme Court on March 6, 1857, was a landmark ruling that deepened sectional divisions in the country and moved it closer to Civil War. In a 7–2 decision, the Court ruled that Dred Scott, a slave who had lived in free territories, was not entitled to his freedom. Furthermore, it determined that African Americans, whether free or enslaved, could never be U.S. citizens and that the Missouri Compromise of 1820, which restricted slavery in certain territories, was unconstitutional.
Legal scholars widely regard Scott v. Sandford as the Supreme Court’s worst decision, an instance where the judiciary wrongly attempted to resolve a political issue. Chief Justice Charles Evans Hughes later called it the Court’s great “self-inflicted wound.”
Background
Dred Scott was a slave owned by John Emerson, a Missouri resident serving in the U.S. military. Between 1833 and 1843, Emerson moved with Scott through Illinois (a free state) and the Wisconsin Territory (where slavery was prohibited). During this time, Scott married Harriet Robinson, who also became part of Emerson’s household. After Emerson’s death in 1843, Scott attempted to purchase his freedom from Emerson’s widow, but she refused.
In 1846, with assistance from anti-slavery lawyers, Dred and Harriet Scott separately sued for their freedom in Missouri state court, arguing that their time in free territories had emancipated them. Ultimately, only Dred’s case proceeded, and the decision would apply to Harriet as well. While initially successful in 1850, Scott’s freedom was overturned by the Missouri Supreme Court in 1852. When Emerson’s widow left Missouri, her brother, John F.A. Sanford of New York, took over her late husband’s estate. Since Sanford was not a Missouri resident, Scott’s lawyers filed a case against him in federal court, which ruled in Sanford’s favor. The case eventually reached the U.S. Supreme Court, which delivered its controversial ruling in March 1857, just two days after President James Buchanan’s inauguration.
The Supreme Court’s Decision
Chief Justice Roger B. Taney, in his majority opinion, made sweeping rulings that ignored legal precedent, distorted historical facts, and imposed a strict interpretation of the Constitution. He argued that African Americans, even if considered citizens in individual states, were not U.S. citizens and thus had no right to sue in federal court. He also stated that Congress had no authority to prohibit slavery in U.S. territories, thereby invalidating the Missouri Compromise. Taney’s ruling struck down key anti-slavery principles and denied African Americans the possibility of national citizenship.
Justice Benjamin R. Curtis strongly refuted Taney’s arguments, noting that African Americans had been recognized as citizens in several states at the nation’s founding. He wrote: “At the time of the ratification of the Articles of Confederation, all free native-born inhabitants of the States of New Hampshire, Massachusetts, New York, New Jersey, and North Carolina, though descended from African slaves, were not only citizens of those States, but such of them as had the other necessary qualifications possessed the franchise of electors, on equal terms with other citizens.”
Curtis contended that African Americans were part of the nation and should not be denied citizenship.
Reaction and Legacy
The ruling was celebrated in the South, with one Georgia newspaper declaring, “The Southern opinion upon the subject of Southern slavery is now the supreme law of the land.” However, the North strongly condemned Taney’s decision, with editor Horace Greeley publishing Curtis’s dissent as campaign material for the 1858 and 1860 elections.
Many Northern states rejected the ruling’s legitimacy. Courts in Ohio, New York, and Maine upheld the rights of free African Americans, while state legislatures passed laws ensuring that slavery could not exist within their borders. Instead of settling the slavery issue, Scott v. Sandford only intensified national divisions, bringing the U.S. closer to civil war.
Chief Justice Taney is now largely remembered for this pro-slavery ruling and his assertion that African Americans could never be citizens. When he died in 1864, he was widely vilified in the North, with Republican Senator Charles Sumner stating, “The name of Taney is to be hooted down the page of history.”
Though the Supreme Court denied Dred Scott his freedom, he was later emancipated when the Blow family, his original owners, repurchased and freed him in 1857. He died of tuberculosis in 1858. Harriet Scott lived until 1876, witnessing both the Civil War and the passage of the Thirteenth Amendment, which abolished slavery in the U.S. Source: Britannica
