United States v. The Amistad

Summary

United States v. The Amistad is the Supreme Court case that freed the African captives who had seized the Spanish schooner Amistad. In 1839 Portuguese slave traders kidnapped a large group of people, most of them Mende, from the region of present-day Sierra Leone and carried them illegally to Havana, in violation of Spanish laws and treaties against the African slave trade. There José Ruiz and Pedro Montez bought fifty-three of them, with forged papers calling them Cuban-born slaves, and shipped them on the Amistad along the coast of Cuba. At sea the captives, led by a man called Sengbe Pieh or Cinqué, rose against the crew, killed the captain and the cook, and ordered Ruiz and Montez to steer for Africa. The Spaniards steered by night toward North America instead, and in August 1839 the ship was seized off Long Island by the U.S. brig Washington and brought into Connecticut. A complicated lawsuit followed. The naval officers claimed salvage; Ruiz and Montez claimed the Africans as their property; and the Spanish government, supported by the administration of President Martin Van Buren, demanded that the ship and its cargo, including the Africans, be returned under a 1795 treaty with Spain. Abolitionists organized the captives' defence. The federal district and circuit courts in Connecticut ruled that the Africans had been kidnapped and were free, and ordered them delivered to the President to be returned to Africa. The government appealed. The case was argued before the Supreme Court in February and March 1841. Roger S. Baldwin and the former President John Quincy Adams, then a congressman, argued for the Africans. On 9 March Justice Joseph Story delivered the opinion of the Court. He held that the treaty applied only to property, and that the Africans were not property: they had been kidnapped and illegally imported, and their papers were fraudulent. When the rights of Spanish claimants and of the Africans conflicted, the question had to be decided upon the eternal principles of justice and international law, and the Africans could not be treated as pirates or robbers for asserting their freedom. The Court therefore declared them free and reversed the order to deliver them to the President. Justice Baldwin dissented without opinion. The salvage award on the ship and cargo was upheld. The thirty-five surviving Africans sailed for Sierra Leone in late 1841, with funds raised by supporters and accompanied by missionaries, and arrived in January 1842. The case became a landmark for abolitionists and for the rule of law over political pressure.

Plot or Argument

• The voyage and the revolt

  The reporter recounts the kidnapping, the sale at Havana, the revolt aboard the Amistad and its capture off Long Island.

• The claims

  The United States, on behalf of Spain, Ruiz and Montez, and the naval officers each assert claims to the ship, cargo and Africans.

• Arguments of counsel

  The Attorney General argues for restoration under the treaty; Baldwin argues the Africans were free men kidnapped.

• Story's opinion: the treaty

  The treaty with Spain covers only property, and the Africans were never lawfully slaves.

• Story's opinion: justice

  The conflict must be decided by justice and international law; the Africans may not be treated as criminals for resisting.

• Decree

  The lower courts are affirmed except for the order to send the Africans to the President; they are declared free.

Lessons

• Freedom as a natural right

  The Court treated the Africans as free men who had been wronged, not as goods to be returned. Human beings cannot become property by fraud and force.

  • Why did Story hold that the treaty did not apply?
  • What does the case teach about the difference between persons and property?

• Law over politics

  The President's administration wanted the Africans returned, but the courts followed the law and the evidence. Independent courts protect the powerless.

  • What did the Van Buren administration want?
  • Why is it important that courts can rule against a government?

• Christian advocacy

  Abolitionists, many of them devout Christians, raised money, found lawyers, taught the captives and later helped them return home. Faith acted through patient work.

  • How did supporters help the Africans?
  • What can ordinary people do when others suffer injustice?

Context

Britain had abolished the slave trade in 1807, and Spain had agreed by treaty with Britain to end it, but the illegal trade to Cuba continued. In the United States, slavery was legal in the South and the subject of intense debate.

Composition

The case moved through the federal courts in Connecticut in 1839–1840 and was argued before the Supreme Court from 22 February to 9 March 1841, when Story delivered the opinion.

Reception

Abolitionists celebrated the decision, and Adams's argument was published separately. The case did not challenge slavery within the United States, but it affirmed that kidnapped Africans had a right to freedom.

Comparisons

• Dred Scott v. Sandford

  Sixteen years later, the Court in Dred Scott denied that Black Americans could be citizens.

• Narrative of the Life and What to the Slave Is the Fourth of July?

  Douglass's Narrative gives an American slave's account of the system the Amistad captives escaped.

• Somerset v. Stewart (Somerset's Case)

  Somerset's Case in England (1772) also turned on whether a court would let a person be held as property.

Quotes

For Students

A reading companion for classical Christian high school students. See the student guide.

Reading Guide

Watch for

• The facts of the kidnapping and the revolt.
• The competing claims.
• How Story treats the treaty with Spain.
• The final decree and what it ordered.

Key terms and names

Admiralty law

The law of ships and the sea.

Salvage

A reward to those who save a ship or cargo at sea.

Libel (admiralty)

A written claim filed in an admiralty court.

Treaty of 1795

Pinckney's Treaty between the United States and Spain.

Seminar Questions

1. Comprehension How did the Africans come to be on the Amistad?
2. Comprehension Who claimed the Africans, and on what grounds?
3. Interpretation Why did Story conclude that the treaty with Spain did not apply?
4. Interpretation Why does Story appeal to the eternal principles of justice?
5. Interpretation When a government seeks an unjust result, what should judges do?
6. Interpretation Why do you think Justice Baldwin dissented?
7. Big Question What makes a person free?

Faith Connections

• Exodus 21:16 (Scripture)

  "He that stealeth a man, and selleth him... shall surely be put to death": the biblical condemnation of man-stealing.

• Isaiah 61:1 (Scripture)

  "To proclaim liberty to the captives": the mission Christ applied to himself in Luke 4.

• John Quincy Adams, Argument in the Case of the Amistad (1841) (Great Conversation)

  Adams appealed to the Declaration of Independence before the Court.

Logic and Rhetoric

Central argument: Kidnapped Africans fraudulently held as slaves are not property under the treaty and must be declared free under the principles of justice and international law.

Rhetorical device: appeal to first principles. Story moves from treaty language to "the eternal principles of justice".

Debate: Resolved: that the Amistad decision was a victory for the rule of law.

Memory Work

must be decided upon the eternal principles of justice and international law.

Writing Prompts

Essay: Explain the Supreme Court's reasoning in the Amistad case and why it mattered.

Comparison with Dred Scott v. Sandford: Compare the Court's treatment of the Africans in Amistad with its treatment of Dred Scott.

Creative Prompts

• Essay

  Explain how Story distinguished between property and persons in the Amistad case.

• Fiction

  Tell the story of the Amistad from the point of view of one of the African captives.

• Classroom

  Make a timeline of the Amistad case from the kidnapping in 1839 to the arrival in Africa in 1842.

Further Reading

• Mutiny on the Amistad, Howard Jones