United States v. Libellants & of the Schooner Amistad
10 L. Ed. 826, 40 U.S. 518, 15 Pet. 518 (1841)
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Rule of Law:
Individuals who were unlawfully kidnapped and enslaved are not property or 'merchandise' under international treaties. Courts are not bound by fraudulent documents claiming ownership and must recognize the captives' inherent right to liberty.
Facts:
- In early 1839, a group of Africans, including an individual named Cinque, were kidnapped from their homeland in Africa and illegally transported to Havana, Cuba.
- In Havana, Spanish subjects Jose Ruiz and Pedro Montez purchased a number of these recently-arrived Africans.
- Ruiz and Montez obtained fraudulent 'passes' from the Governor General of Cuba that falsely identified the Africans as long-time, property slaves.
- The Africans were boarded onto the Spanish schooner L'Amistad to be transported from Havana to another Cuban port, Puerto Principe.
- During the voyage, the Africans revolted, killing the captain and cook, and took command of the vessel in an attempt to sail back to Africa.
- Unable to navigate properly, the L'Amistad drifted north for two months until it was discovered off the coast of Long Island, New York.
- Lieutenant Gedney of the U.S. brig Washington took the vessel, its cargo, and the Africans into custody and brought them to the District of Connecticut.
Procedural Posture:
- Lieutenant Gedney filed a libel for salvage in the U.S. District Court for the District of Connecticut.
- Jose Ruiz and Pedro Montez filed libels claiming ownership of the Africans and parts of the cargo.
- The U.S. Attorney, at the request of the Spanish minister, filed a claim on behalf of Spain for the restoration of the vessel, cargo, and Africans under the 1795 treaty.
- The Africans, through their counsel, filed an answer asserting they were free men who were unlawfully kidnapped.
- The U.S. District Court (trial court) ruled that the Africans were free individuals who had been kidnapped and decreed they should be delivered to the President of the United States to be transported back to Africa.
- The United States, as the appellant, appealed the District Court's decision to the U.S. Circuit Court for the District of Connecticut.
- The U.S. Circuit Court (intermediate appellate court) affirmed the decree of the District Court.
- The United States then appealed the Circuit Court's decision to the Supreme Court of the United States.
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Issue:
Does the 1795 treaty between the United States and Spain require the return of Africans who, after being illegally kidnapped from Africa and enslaved, seized control of the vessel transporting them and landed in United States territory?
Opinions:
Majority - Mr. Justice Story
No. The treaty with Spain does not require the restitution of the Africans because they are not the property of the Spanish claimants. The evidence overwhelmingly demonstrates that the Africans were not lawful slaves but were free individuals who had been recently kidnapped from Africa and illegally imported into Cuba, in direct violation of Spain's own laws and treaties abolishing the slave trade. As they were unlawfully detained, their actions to secure their freedom cannot be classified as piracy or robbery under the law of nations. The Court is not bound by the fraudulent documents presented by Ruiz and Montez, as fraud vitiates any transaction, and the treaty's requirement for 'due and sufficient proof' of property cannot be met with forged papers. The treaty was intended to protect bona fide property rights, not to compel the return of illegally captured human beings to their captors. Consequently, the Africans are free individuals and must be dismissed from the custody of the court.
Dissenting - Mr. Justice Baldwin
Mr. Justice Baldwin dissented without a written opinion.
Analysis:
The Amistad decision established a powerful precedent that U.S. courts could look behind official foreign government documents to uncover fraud, particularly where fundamental human rights like liberty were at stake. While it did not challenge the legality of domestic slavery within the United States, the ruling was a significant victory for abolitionists, as it affirmed that the status of 'property' in a person was not absolute and could be nullified if rooted in illegal acts like the international slave trade. The decision reinforced principles of natural law and justice within the U.S. legal system, asserting that the rights of foreign individuals to liberty could be recognized and protected by American courts, even when those rights conflicted with treaty obligations concerning property.
