Groves v. Slaughter

Supreme Court of United States
15 Pet. 449 (1841)

ELI5:

Rule of Law:

A state constitutional provision that prohibits an activity but provides no penalties or enforcement mechanisms is merely a directive to the legislature and is not self-executing. Contracts related to such activity remain valid until the legislature enacts a statute to enforce the prohibition.

Facts:

In 1835 and 1836, R. M. Roberts imported slaves into Mississippi for the purpose of selling them as merchandise.
The importation was done for general sale and not pursuant to any prior agreement with the defendants.
On December 20, 1836, John W. Brown purchased slaves from Roberts and executed a promissory note for $7,000, payable to Roberts.
Moses Groves and James Graham endorsed Brown's promissory note.
The slaves were delivered to the purchasers and were never returned or tendered back to Roberts.

Procedural Posture:

R. M. Roberts sued John W. Brown, Moses Groves, and James Graham in the Circuit Court of the United States for the Eastern District of Louisiana to collect payment on a promissory note.
The defendants argued that the note was void because its consideration, the sale of slaves imported into Mississippi, was illegal under the state's 1832 constitution.
The parties submitted an agreed statement of facts for the court's consideration.
The Circuit Court entered a judgment in favor of Roberts, the plaintiff.
Groves and the other defendants (plaintiffs in error) brought a writ of error to the Supreme Court of the United States to seek reversal of the lower court's judgment.

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Issue:

Does a provision in the Mississippi Constitution stating that the introduction of slaves as merchandise 'shall be prohibited' after a specific date, without accompanying enforcement legislation, automatically render a contract for the sale of such slaves void?

Opinions:

Majority - Mr. Justice Thompson

No. The provision in the Mississippi Constitution is not self-executing and does not, by itself, invalidate the contract. The phrase 'shall be prohibited' indicates a command to the legislature to act in the future, rather than a present prohibition. The constitutional provision lacks any penalties or sanctions for its violation, which are indispensable for its enforcement. The Mississippi legislature’s own actions, including its delayed passage of an enforcement statute in 1837 that finally provided penalties, demonstrate that it viewed the constitutional provision as a directive requiring legislative action, not as a self-enforcing ban. Therefore, contracts for the sale of imported slaves made prior to the 1837 statute are valid.

Concurring - Mr. Justice McLean

No. Justice McLean agreed with the Court's judgment but wrote separately to address the Commerce Clause question, which he believed was central to the case. He argued that the power over slavery is a local police power reserved exclusively to the states. While Congress has exclusive power to regulate interstate commerce, states retain the right to protect themselves from the 'dangers of a slave population' through the law of self-preservation, which is 'higher and deeper than the Constitution.' Therefore, a state law regulating or prohibiting the importation of slaves does not unconstitutionally interfere with federal commerce powers.

Concurring - Mr. Chief Justice Taney

No. The Chief Justice concurred with the judgment and wrote to explicitly state his agreement with Justice McLean's constitutional view. He asserted that the power over the introduction and condition of slaves is 'exclusively with the several states.' He believed that Congress could not control state action on this subject through its commerce power or any other constitutional authority.

Concurring - Mr. Justice Baldwin

No. Justice Baldwin concurred in the judgment but offered a sharply different view on the constitutional question. He maintained that the power to regulate interstate commerce is exclusively federal. In his opinion, slaves were property and articles of commerce, and therefore a state could not prohibit their importation for sale from another state without violating the Commerce Clause. He concluded that had the Mississippi constitutional provision been self-executing, it would have been void as an unconstitutional infringement on federal power.

Dissenting - Mr. Justice McKinley and Mr. Justice Story

Yes. The dissenting justices would have found the contract void. The opinion text notes that Justices McKinley and Story dissented, believing the promissory note was void. This implies they viewed the Mississippi constitutional provision as self-executing and immediately effective upon the specified date, thus rendering any subsequent contract for the sale of imported slaves illegal.

Analysis:

This case establishes an important principle of constitutional interpretation, holding that a prohibitory provision without enforcement mechanisms is merely a directive to the legislature, not a self-executing law. The multiple concurrences are historically significant as they reveal the deep divisions on the pre-Civil War Court regarding federalism and slavery. The opinions articulate competing views on whether states' police powers or the federal Commerce Clause controlled the interstate slave trade, previewing the escalating national conflict over the issue.

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