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Slavery & Reconstruction

Dred Scott v. Sandford

Decided: 1857

In brief

Ruled that Black Americans could not be U.S. citizens and that Congress could not ban slavery in the territories; a catalyst toward the Civil War.

The Court's ruling in depth

Dred Scott, an enslaved man, sued for his freedom on the ground that he had lived with his enslaver in free territory. Chief Justice Taney's opinion is widely regarded as the worst in Supreme Court history. It held that people of African descent — whether free or enslaved — were not and could never be 'citizens' within the meaning of the Constitution, and therefore could not sue in federal court. It further held the Missouri Compromise unconstitutional because Congress lacked power to prohibit slavery in the territories, since doing so would deprive slaveholders of property without due process. Rather than settling the slavery question, Dred Scott inflamed sectional conflict and accelerated the march to civil war. Its holdings were repudiated by the Thirteenth Amendment (abolishing slavery) and the Fourteenth Amendment (which begins by defining citizenship precisely to overturn Taney's ruling). The case endures as the paradigmatic example of judicial catastrophe.

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