Prigg v. Pennsylvania
Prigg v. Pennsylvania is a landmark Supreme Court case decided in 1842 that addressed the conflict between state and federal laws regarding the recapture of fugitive slaves. The case arose when Edward Prigg, an agent for a Maryland slave owner, unlawfully captured a runaway slave in Pennsylvania, conflicting with the state's personal liberty law designed to protect such individuals. The Supreme Court ultimately ruled in an 8-1 decision that the federal Fugitive Slave Law of 1793 was constitutional, thereby affirming the rights of slave owners to pursue and reclaim their escaped slaves across state lines. The Court also declared Pennsylvania's personal liberty law unconstitutional, emphasizing the supremacy of federal law in this area.
Additionally, the ruling indicated that while slave owners had the right to recapture their property, the national government could not compel state officials to assist in this enforcement. This decision led to increased tensions between northern and southern states, prompting some northern legislatures to pass laws prohibiting state involvement in the capture of fugitive slaves. The fallout from Prigg v. Pennsylvania contributed to the enactment of the more stringent Fugitive Slave Law of 1850, reflecting the deepening divisions over slavery in the United States.
Prigg v. Pennsylvania
Date: January, 1842
Citation: 16 Pet. (41 U.S.) 539
Issue: Supremacy of federal laws over the states
Significance: The Supreme Court held that slave owners had the constitutional right to take possession of their property, but state officials could not be required to assist in the process.
In 1837 Edward Prigg, an agent of a Maryland slave owner, took possession of a runaway female slave in Pennsylvania. Because of the state’s personal liberty law of 1826, he was not able to obtain legal authorization to remove the woman from the state, but he forcibly took her back to Maryland. After Pennsylvania indicted Prigg for kidnapping, the state of Maryland agreed to extradite him so that the Supreme Court might consider the legal issues of the case. Writing for an 8-1 majority, Justice Joseph Story made four rulings: First, the federal Fugitive Slave Law of 1793 was constitutional; second, the Pennsylvania personal liberty law was unconstitutional; third, the fugitive slave clause in the Constitution implied the right of slave owners to recapture runaway slaves; and fourth, the national government had no power to compel state officials to enforce federal law. Chief Justice Roger Brooke Taney, while joining with the rest of the opinion, disagreed with the fourth ruling.
Following the Prigg decision, some northern legislatures prohibited state officials from helping capture fugitive slaves or using state facilities for that purpose. Southern dissatisfaction with this situation contributed to the passage of the stringent Fugitive Slave Law of 1850.