Tag Archives: abolition

Habeas Corpus, the Fugitive Slave Law, and Executive Authority

Last month, President Donald Trump issued an executive order prohibiting the entry of refugees or visa holders from seven Middle Eastern nations. It went into effect while some foreign nationals were in transit, thus they arrived in a different America than the one they had expected. Among these were two Iraqis, detained at Kennedy Airport on January 27, 2017. Their lawyers filed writs of habeas corpus the following morning, hoping to have their clients released.[1] They were not alone. According to the director of the International Refugee Assistance Project, Becca Heller, “we’ve gotten reports of people being detained all over the country…. They’re literally pouring in by the minute.”[2] This executive order has raised, for many Americans, questions about the role of executive power in a political system that reveres checks and balances, how this will affect refugees from war torn regions, and about our nation’s core identity as a country of immigrants.

Although our twenty-first century context is much different, the implementation of habeas corpus to rescue a detainee from state or federal custody harkens back to the enslaved people detained under the Fugitive Slave Law of 1850. This law was intended to protect slaveholders’ property interests and reinforce a pro-slavery interpretation of the U.S. Constitution. It mandated that in fugitive slave cases where the alleged fugitive was taken into custody in a free state, normal judicial processes were not in force—there was no opportunity for appeal, no jury was present, the alleged owner (i.e. “slave claimant”) was not required to have a warrant, and the appointed slave commissioner had significant leeway in determining what constituted adequate evidence of enslavement. Even more controversially, the act stated that the commissioner was entitled to a ten-dollar fee if he found for the claimant, and only a five-dollar fee if he found for the alleged fugitive. It was a system that encouraged corruption.[3]

Like President Trump’s executive order, the Fugitive Slave Law unleashed a torrent of controversy. Blacks across the nation, whether free or enslaved, knew that this legislation would make it more difficult for fugitives to remain safe in the North, and it would also make it easier for kidnappers to abduct free Northern blacks and sell them into slavery. Proslavery Americans were ecstatic about its passage, since it marshaled the power of the federal government to protect slaveholders’ property rights. Many white Northerners were appalled by the fact that what they believed to be normal judicial processes could simply be swept away. Lewis Tappan noted that “the heart of every antislavery individual will deeply sympathize with the panting fugitive…. In every way in which it can be viewed, it is a disgrace to the nation, an act of extreme cruelty, and can be viewed as an experiment on the part of the Slave Power to see how much the Free States will bear.”[4] In Massachusetts, a group of citizens stated that “the foundations of our government are shaken, and unless the work of destruction shall be stayed, we may soon see that great union, our honor and safety abroad and at home, broken into weak, discordant and shattered fragments.”[5] Much like recent conversations about executive authority, and our obligation to refugees and legal immigrants, the Fugitive Slave Law had a polarizing effect on political discourse.

Political cartoon illustrating a woman being taken into custody
“Practical Illustration of the Fugitive Slave Law,” E. C. del., 1851. Courtesy of the Library of Congress.

Although the use of habeas corpus has evolved over the past 160 years, it remains an example of our shared conviction that all persons are born free and cannot be deprived of that freedom without due process. Then, as now, a writ of habeas corpus was used to uncover why a person was being restrained or incarcerated; in the antebellum period, “upon the presentation of a prima facie case for issuing the writ, it would be directed to the person detaining another, commanding him to bring the person detained before the judge and to state the reasons for depriving him of his freedom.”[6] Counsel could request a writ, but it was issued by a judge who directed it to the state official responsible for the alleged fugitive’s arrest. Due process is a right enshrined in the 5th Amendment to the U.S. Constitution, and habeas corpus was one mechanism for protecting this right.

In the antebellum South, however, there was no presumption that all persons were born free, and indeed African Americans were presumed to be slaves unless they could prove otherwise. Northern states, however, began to pass personal liberty laws in the early nineteenth century, as a way to prevent the kidnapping of free blacks. No federal anti-kidnapping law existed, so this power remained with the states. Personal liberty laws became even more significant after 1850. For instance, in 1855 the Massachusetts legislature passed a stringent personal liberty law that not only guaranteed the alleged fugitive a writ of habeas corpus and the right to a jury trial, but also promised serious punishment for anyone who took into custody a free person. The slave claimant could not seek counsel from local citizens. Although the Fugitive Slave Law allowed a mere affidavit by the claimant, at the commissioner’s discretion, this state law went further to require “at least two credible witnesses.”[7] Its passage initiated a prolonged struggle in the Massachusetts statehouse between conservatives and moderates, each jockeying for power to either repeal the law altogether or amend it to ease the burden on slaveholders. In March 1858 the law was amended, but the right to the writ remained.[8]

Similar situations played out in other Northern states, particularly in New England and the mid-Atlantic, which saw a number of high profile fugitive slave cases during the 1850s, and some prior to the new law’s passage, such as the Supreme Court case Prigg v. Pennsylvania (1842).[9] There are also less well-known cases where a writ was applied, such as that of Archy Lee in San Francisco in 1858 and Charley Fisher in Kansas in 1859.[10] The courts were caught between the property rights of slaveholders and a guarantee of due process for those who might be legally free. Antislavery resistance to an unjust law came, in these situations, through legal means.

Advertisement Seeking Assistance for Lee’s Legal Fees, c. 1858. Courtesy of Blackpast.org.

Before the Civil War, states could issue writs to rescue fugitives from federal custody, and national courts could not intervene at the state level.[11] This was, much to the chagrin of white Southerners, a states’ rights argument that contravened slavery instead of supporting the peculiar institution (the irony of this should not be lost on us today). From the antislavery perspective, free states should be able “to legislate on this subject for the preservation of their own peace and the protection of their own soil from insult and aggression,” to quote two attorneys who argued the Prigg v. Pennsylvania case.[12] This contest between federal and state power continued in other fugitive cases, including the prominent case of Joshua Glover in Wisconsin, where the territorial Supreme Court ignored a writ of error from the U.S. Supreme Court and even ruled that the Fugitive Slave Law was unconstitutional. Their decision was overturned in Ableman v. Booth (1859), when Chief Justice Roger Taney asserted that state courts did not have authority over federal courts.[13] States may have had the right to protect their citizens, but Congress and the Supreme Court also had responsibilities to slaveholders. Therein lay the rub.

The world of the 1850s is strikingly different from the world of 2017. Today we face challenges that would be unfamiliar to antebellum Americans who did not experience the 9/11 terrorist attack, nor had they seen their nation survive a civil war and two world wars. The current administration’s immigration restrictions are predicated on the argument that they will protect us from terrorism, a justification decidedly unlike the property-rights argument used to justify the Fugitive Slave Law. Still, both then and now, those seeking to help detainees turned first to habeas corpus. Today we ask ourselves many of the same questions our nineteenth-century counterparts did. What are the limits of federal power? How freely should we accept immigrants and refugees, whether they be escaping slavery, or escaping war and persecution? What do we owe our allegiance to, human law or a higher law? Americans do not agree on the answers to these questions, nor did they in the 1850s. There is no doubt that the judicial system—and its defense of the Constitution—will play a central role in shaping the outcome.

[1] Brooke Seipel, “Refugees Detailed at US Airports After Trump Exec Order,” The Hill, http://thehill.com/blogs/blog-briefing-room/news/316656-refugees-detained-at-us-airports-following-refugee-ban (accessed January 28, 2017). This writ is available at https://www.scribd.com/document/337777796/1-Complaint?content=10079&campaign=Skimbit%2C+Ltd.&ad_group=&keyword=ft500noi&source=impactradius&medium=affiliate&irgwc=1 (accessed January 29, 2017).

[2] Michael D. Shear and Nicholas Kulish, “Trump’s Order Blocks Immigrants at Airports, Stoking Fear Around Globe,” The New York Times, https://www.nytimes.com/2017/01/28/us/refugees-detained-at-us-airports-prompting-legal-challenges-to-trumps-immigration-order.html?smid=tw-share (accessed January 28, 2017).

[3] “Fugitive Slave Act of 1850,” The Avalon Project: Documents in Law, History and Diplomacy, http://avalon.law.yale.edu/19th_century/fugitive.asp (accessed April 20, 2016).

[4] Lewis Tappan, The Fugitive Slave Bill: Its History and Unconstitutionality; With an Account of the Seizure and Enslavement of James Hamlet, and His Subsequent Restoration to Liberty (New York: William Harned, 1850), preface, https://www.loc.gov/resource/llst.076 (accessed February 11, 2017).

[5] To the Citizens of Massachusetts; The Undersigned Are Moved by an Imperative Sense of Duty to Address their fellow-citizens of the State of Massachusetts, Concerning the Portentous Condition of Our Public Affairs (1850), 1, https://www.loc.gov/resource/rbpe.06501000/ (accessed February 11, 2017).

[6] Thomas D. Morris, Free Men All: The Personal Liberty Laws of the North, 1780-1861 (Baltimore: The Johns Hopkins University Press, 1974), 9.

[7] Mark Voss-Hubbard, “The Political Culture of Emancipation: Morality, Politics, and the State in Garrisonian Abolitionism, 1853-1863” Journal of American Studies 29 (August 1995): 172.

[8] Voss-Hubbard, 173.

[9] Prigg v. Pennsylvania 41 U.S. 539 (1842), https://supreme.justia.com/cases/federal/us/41/539/case.html (accessed February 8, 2017).

[10] Samuel May, The Fugitive Slave Law and Its Victims (New York: American Anti-Slavery Society, 1861), 97-98, 111-112.

[11] Morris, 10.

[12] Morris, 95.

[13] Early Maltz, “Slavery, Federalism, and the Constitution: Ableman v. Booth and the Struggle over Fugitive Slaves” Cleveland State Law Review 83 (2008): 92.

Kristen Epps

Dr. Kristen Epps is an assistant professor of history at the University of Central Arkansas. She is the author of Slavery on the Periphery: The Kansas-Missouri Border in the Antebellum and Civil War Eras (Georgia, 2016). Her research focuses on slavery, abolition, and the sectional crisis. She can be reached at kkepps@uca.edu.

New Political Histories of the Sectional Crisis: A Report from the AHA

In August 2016, Kenneth Osgood and Fredrik Logevall (fresh from winning the Pulitzer Prize for his recent book on the Vietnam War, Embers of War) co-authored an op-ed for the New York Times titled “Why Did We Stop Teaching Political History?”[1] Like so many nostalgic jeremiads, it assumes that we have stopped teaching political history (or military history, or “traditional” history, etc.), and that politics is now a marginalized field. This is a familiar complaint rising and falling with predictable regularity, and it remains a relevant discussion in Civil War and Reconstruction studies.

At an AHA panel in Denver, historians presented their work in response to this op-ed at Session 150, “Linking the Local and the National in the Politics of Sectional Conflict.” The panel was chaired by Amy Greenberg and included roundtable presentations and discussion featuring Rachel Shelden, Corey Brooks, and Joanne Freeman. Their scholarship confirmed what we were all probably thinking when we saw the Logevall/Osgood op-ed: historians of the antebellum and Civil War eras have never stopped writing or teaching political history. Yes, certainly, there are historians working on less overtly political topics, yet we recognize the many ways in which social and cultural history supplement or alter our writing and teaching about politics. As social and cultural histories become integrated into political history, New Political History emerged, and perhaps what we are all engaged in now is as I once heard Jonathan Earle ironically call label it: the New New Political History. Put whatever label you’d like to on it, but as Shelden emphasized, political history remains as urgent a field of inquiry as ever for scholars of sectionalism.

Shelden’s Washington Brotherhood (2013) exemplifies the way in which political historians have integrated social and cultural history into their studies of the deeply widening sectional conflicts between the war with Mexico and the Civil War. In her current research, Shelden plans to provide just the same new political history approach—integrating non-traditional forms of social and cultural history into her examination of how personal engagement and friendship, collegiality and rivalry, partisanship and ideology all affected the judicial outcomes of the era. Shelden maintains that compared to the Presidency and Congress, the judiciary remains understudied. There is nothing more traditionally political than giving a branch of the federal government close scrutiny, and detractors aside, political history today must be more than the traditional focus on only elite actors in official capacities. Her examination of the pre-Civil War judiciary proposes to be just the kind of scholarship that would satisfy both political and social historians, because it will take the best of both approaches and illuminate an area of the emerging political crisis of the Civil War so often overshadowed by case studies of Dred Scott.

In his book Liberty Power (2016), and at the session, Corey Brooks argues that antislavery activists and the few politicians sympathetic to their aims used Congressional debates not to win over colleagues, and therefore votes, but instead as a national lyceum. The published speeches and reprinted pamphlets provided much needed labor in building a northern consensus from the 1830s to the 1860s that slavery, if not abolished, certainly needed to be limited in the West. Through the antislavery associations and ultimately through the Liberty Party, Free Soil Party, and Republican Party, Brooks attends closely to the ways in which partisans made effective use of both Congress and the press to move public opinion in the years leading to the election of Abraham Lincoln. For Brooks, the election of Lincoln, and perhaps the Civil War itself, is best explained by studying how political antislavery activists and politicians lobbied, petitioned, and simply harangued their constituents until politicians like Lincoln could express sentiments or support for policies (policies that a generation or two before would have been inconceivably marginal). For many historians of abolition, it is the social pressure of Garrisonians and the moral weight of antislavery intellectuals like Frederick Douglass which capture our attention when writing and teaching about antislavery. Often it is our understanding of the increasing anxiety in the U.S. about how to integrate newly acquired western lands into a nation with sharply diverging sectional economic structures, or the rise of Southern nationalism, or the collapse of the Democratic party, which dominate our understanding of the rise of the Republican party in the 1850s. Brooks, like Shelden, makes the best use of social and cultural history produced over the past twenty-five years in support of his argument that antislavery third-party politics needs greater attention because its role in the politics of the 1840s and 1850s has too long been overshadowed by other explanations for why the War came.

In her classic work Affairs of Honor (2001), Joanne Freeman may well have established the model for the New New Political History by taking seriously the role that cultural traits related to honor, reputation, and violence played in the lives and careers of early national politicians. Not surprisingly, the Hamilton-Burr duel brings many readers to Freeman’s book. (Too soon to call it a classic? I will anyway.) Since its publication Freeman edited Alexander Hamilton: Writings (2001) for the Library of America and has been consumed lately with interviews about the Broadway musical Hamilton (its success attests to the public’s continued interest in “traditional” political history). Her next research project carries her interest in political violence and early U.S. history into the 1830s and 1850s. For Freeman, this period experienced a noticeable shift in print culture in terms of format, content, and accessibility, which along with western expansion, led to the rise of a particular class of “fighting men” within partisan politics. Beyond “affairs of honor” such as duels, these antebellum fighting men provided election day muscle to intimidate people into voting (or not), demonstrated to voters and partisan opponents that words would and often were backed by actions, and may well have led to the escalation of violence in America’s urban centers, but also, of course, in Kansas. She suggests that Representative Preston Brooks’s vicious caning of Senator Charles Sumner in 1856 is in need of greater political context than traditional explanations of Southern honor codes and widening sectional indecorum on the floor of Congress. So frequently in the Northern antebellum press, but also in our scholarship, political violence is attributed to either the genteel Southerner bound to defend his reputation or, alternatively, the barbaric lower classes, often immigrants, who resorted to violence rather than politics or law to settle their disputes. Despite these assumptions, Freeman has identified “fighting men” in the North and South, among Democrats and Republicans, and it may no longer be tenable to maintain that political violence operated on the margins, utilized only be those to be deplored.

Generally, when anyone bewails the decline of the study of traditional forms of history, I tend to shrug because I know that they are wrong. Traditional history is just fine, and I also find the ongoing inquiry into less traditional topics to be both interesting in its own right, but also so obviously useful to political historians like those who participated in this AHA panel. For models of scholarship that integrate social and cultural history into political history on the coming of the Civil War, you could do little better than reading or teaching these panelists.

[1] Fredrick Logevall and Kenneth Osgood, “Why Did We Stop Teaching Political History?” https://www.nytimes.com/2016/08/29/opinion/why-did-we-stop-teaching-political-history.html (accessed January 17, 2017).

Nicholas Cox

Nicholas P. Cox is currently the Program Coordinator for the History Department of Houston Community College. He is currently writing a political biography of Colonel Richard M. Johnson of Kentucky, as well as instructional supplements for OUP’s Texas history textbook, Gone to Texas. He has given presentations on his research and teaching at the AHA, SHEAR, TXSHA, ETHA, and HASH; referees article submissions for the Journal of South Texas; and reviews books for a number of journals. You can easily find him on Twitter @npcox or by email at nicholas.cox@hccs.edu.

Abolitionism, Vigilance Associations, and the Rhetoric of “Law and Order”

In today’s heated political climate, only days away from a contentious Presidential election, Americans are no stranger to public threats of intimidation or violence as a mechanism for maintaining “law and order.” From Donald Trump’s frequent references to the need for restoring “law and order” in urban communities, to his pleas for poll watchers, to the Bundy brothers’ revolt in Oregon, and the state action against #NoDAPL protesters in North Dakota, this theme of restoring the rule of law is inescapable.[1] In many news outlets, and even in casual conversations across the nation, there is a sense that we have lost our way. In many cases, these statements are a reaction to the perceived loss of political power or social hegemony. As women, African Americans, immigrants, the LGBT community, and other groups continue to fight for equality, those who had previously enjoyed significant social privilege are left with a sense of powerlessness. Promises of restoring law and order are both a mechanism for taking back what has been lost and a strategy for silencing dissent.

Such concerns would have been quite familiar to western Missourians living in the 1850s. The strife of Bleeding Kansas had shaken their world. In April 1855, an antislavery minister named Frederick Starr documented the goings on in Platte County, Missouri, a center of pro-slavery sentiment on the Kansas-Missouri border (in what is now the Kansas City metro). He wrote in a letter that “we are in the midst of terrible times…. The ballot box is violated, the press overthrown, the church denounced, surely pro-slavery forces are making great advances and one victory crowds on the heels of another…. Glorious nation this.”[2] He referred here not only to the Kansas troubles, but also to a nearly year-long struggle between Missouri anti-slavery advocates, like himself, and their pro-slavery neighbors. In addition to the battle to populate Kansas, Platte County simultaneously encountered profound internal conflicts over the presence of free-soilers and abolitionists in their midst, men and women whose antislavery views challenged the social order.

image-1-frederick-starr
Frederick Starr, a Presbyterian minister in Platte County, Missouri. From Milton E. Bierbaum, “Frederick Starr, A Missouri Border Abolitionist: The Making of a Martyr” Missouri Historical Review 58, no. 3 (April 1964), 309.

To some extent, this was a contest between anti- and pro-slavery value systems, a battle for the future of the United States. But as abhorrent as anti-slavery views might be to slaveholding leaders, it was only once abolitionist, free-soil, or colonizationist views became public, that they became a public problem, and abolitionists became public nuisances. To protect their definition of how proper slaveholding communities should function, cracking down on dissenting views was necessary to maintain law and order. In response, dissenters like Frederick Starr presented their own interpretations of law and order, critiquing pro-slavery rhetoric and offering a counter-narrative of the community’s needs and values.

Despite the fact that Starr did not preach against slavery from the pulpit, by 1854 he had become known throughout Platte County as an opponent of slavery. Starr’s primary antagonist was an organization called the Platte County Self Defensive Association (PCSDA), which formed at a public meeting in Weston on July 20, 1854, to protect the community from abolitionist threats. These groups were often known as vigilance associations or vigilance committees. They policed any “suspicious looking persons” who emigrated to Kansas, distributed abolitionist literature, or associated with slaves and free blacks. They also styled themselves as protectors of pro-slavery settlers in Kansas who might face abuse from Northern neighbors. They eventually adopted secret passwords and badges. The association had hundreds of members at its height, including such prominent figures as David Rice Atchison and Benjamin Stringfellow.[3]

Members of the PCSDA had repeatedly asked Starr to join, and he always politely declined, on the grounds that he had no slave property to protect. However, while shopping one day in a downtown Weston business, Starr found himself accosted by a slaveholder and PCSDA member, Jack Vineyard. Vineyard was frustrated by Starr’s refusal to recognize that “every good citizen, when there were certain legal institutions and interests in the community where he lived, should do all he could to maintain harmony and quiet and to protect legal property.”[4] In response to this very public disagreement, the PCSDA staged a mock “trial” of Starr. Several hundred people attended. In his vigorous defense, Starr outlined his own, competing definition of the challenge to law and order. Those who harassed citizens based on hearsay and false accusations were the true criminals, he believed, using extra-legal means and intimidation to silence citizens. When it came to Northern transplants like himself, Southerners could expect “that he will not be a disturber of the peace of the community nor disturb the legal rights of any man…. But it [the South] has no right to expect that a man will lay aside or change his opinions and principles.”[5]

image-2-weston
An early lithograph of the Weston waterfront. From Missouri Valley Special Collections, Kansas City Public Library, Kansas City, Missouri, http://www.kchistory.org/u?/Montgomery,7170.

By the fall of 1854, the Self Defensives’ posturing had tested the Weston community’s patience.[6] On September 1, 1854, citizens of Weston who opposed the use of violence (by either faction), and who were “favorable to law and order,” met in protest.[7] Their published pamphlet referenced the community’s need for stability and protection, stating that “our rights and privileges, as citizens of Weston, Platte county, Mo., have been disregarded, infringed upon, and grievously violated within the last few weeks, by certain members of the ‘Platte County Self-Defensive Association.’” Indeed, these actions had disrupted “the domestic quiet to our families, the sacred honor of our sons and daughters, the safety of our property, the security of our living and persons, the ‘good name’ our fathers left us, [and] the ‘good name’ of us all.”[8]

What mattered above all else, for those of either orientation, was stability. For slaveholders and their supporters, abolitionists were treasonous, cowardly, deceitful rabble-rousers who disrupted the peaceful workings of these Platte County communities. In response, anti-slavery residents, whether self-identified abolitionists or not, forwarded their own definition of law and order, decrying the PCSDA’s extra-legal maneuvers aimed at white dissenters and free blacks, their embrace of violence, and their attempts to constrain the freedoms of speech and press.

We find ourselves in a much different political context today, but Platte Countians’ internal war can provide some powerful lessons. The varying definitions of “law and order” that Republicans and Democrats adopt today—and that anti-slavery and pro-slavery partisans adopted in the 1850s—illustrate how divisive politics can be, particularly when it appears to threaten the normal, predictable workings of our society. This rhetoric of “law and order” speaks to our need for consistency and structure, and our human desire for a society that fundamentally makes sense. But claims (made by anyone) to restore law and order usually hearken to the need for extra-legal resistance as a mechanism to restore that law and order; Trump’s poll watchers and the PCSDA both serve as a perfect example of such cognitive dissonance. Such assumptions also liken the rule of law to justice, a dangerous false equivalency (as we learned from Nixon’s rhetoric in the 1970s, which led to an epidemic of mass incarceration). The American right to protest, guaranteed by the 1st Amendment, gives the lie to the idea that law and order is the answer to injustice, or that restoring some mythic past will generate stability. Indeed, much of today’s rhetoric in this regard seeks to silence those who speak out against injustice, or to limit the rights of minority communities. Regardless of where one falls on the political spectrum, this rhetoric carries weight, and those who engage in such language must bear the burden of that rhetoric if—or when—it leads to violence.


[1] For some examples, please consult “We Have to Bring Back Law and Order,” CNN Politics, accessed October 29, 2016, http://www.cnn.com/videos/politics/2016/09/27/clinton-trump-debate-hofstra-stop-and-frisk-sot-five.cnn; Trip Gabriel, “Donald Trump’s Call to Monitor Polls Raises Fears of Intimidation,” The New York Times, accessed October 29, 2016, http://www.nytimes.com/2016/10/19/us/politics/donald-trump-voting-election-rigging.html?_r=0; Maxine Bernstein, “Jury finds all Oregon standoff defendants not guilty of federal conspiracy, gun charges,” The Oregonian, accessed October 29, 2016, http://www.oregonlive.com/oregon-standoff/2016/10/oregon_standoff_verdicts_annou.html; Sam Levin and Nicky Woolf, “Protesters pushed back after mass arrests at North Dakota pipeline site—as it happened,” The Guardian, accessed October 30, 2016,  https://www.theguardian.com/us-news/live/2016/oct/27/north-dakota-access-pipeline-police-protesters-live-updates.

[2] Frederick Starr to Unknown, April 1855, Frederick Starr Papers, Western Historical Manuscript Collection, Columbia, Missouri.

[3] History of Clay and Platte Counties, Missouri (St. Louis: National Historical Company, 1885), 634-635.

[4] Frederick Starr to Dear Father and All, October 30, 1854, Starr Papers, WHMC.

[5] Frederick Starr to Dear Father, January 15, 1855, Starr Papers, WHMC.

[6] Lester B. Baltimore, “Benjamin F. Stringfellow: The Fight for Slavery on the Missouri Border,” Missouri Historical Review 62, no. 1 (October 1967): 18.

[7] At least four members of the committee appointed to draft their resolutions, George T. Hulse, Elijah Cody, A. B. Hathaway, and J. V. Parrott, were slaveholders according to the 1850 census.

[8] “Citizens Meeting,” Starr Papers, WHMC. This was published as a broadside that Starr included in his personal papers.

Kristen Epps

Dr. Kristen Epps is an assistant professor of history at the University of Central Arkansas. She is the author of Slavery on the Periphery: The Kansas-Missouri Border in the Antebellum and Civil War Eras (Georgia, 2016). Her research focuses on slavery, abolition, and the sectional crisis. She can be reached at kkepps@uca.edu.