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Thursday, February 08, 2007

Nat v. Ruddle I: The Facts

The crucial facts in Nat v. Ruddle, 3 Mo. 400, 1834 WL 2555 (1834), were hotly contested. The parties apparently agreed that Nat was originally Ruddle’s slave in Missouri until 1829; and that in 1829 Ruddle moved from Missouri to Illinois and “left the plaintiff Nat hired out in Missouri.” But there, the stories diverged.

Ruddle claimed that Nat “ran away from Missouri and went to Illinois, and was frequently at his master’s house on visits to the family. By both plaintiff and defendant, evidence was given that plaintiff hired himself out in Illinois; but there was no evidence that Ruddle received the hire.”

Nat, in contrast, contended that “he was employed on the farm of the defendant in the State of Illinois, to which place he was brought from Missouri, and after staying some time in Illinois he was sent back to Missouri.” In the alternative, Nat seems to have suggested a more subtle scenario. In this version, Nat left Missouri without permission and went to Ruddle’s farm in Illinois “on a visit.” When Ruddle discovered him there, Ruddle did not object and instead put him to work and hired him out.

Nat filed his suit for freedom in the Circuit Court of St. Louis County. The trial court charged the jury that they should find in Nat’s favor if “they believe that the defendant took the plaintiff into the State of Illinois and used him as a slave there or permitted him to be used as such.” On the other hand, if they believed Ruddle’s story, they should find for him. “[I]f the plaintiff went into that State [Illinois] on a mere voluntary visit, or ran away from Missouri to that State, he would not thereby be entitled to his freedom.”

Neither of the instructions precisely addressed the alternate factual scenario advance by Nat. Nat’s lawyer asked the judge to instruct the jury that, if they believed this account, they should rule for Nat:

“The counsel of the plaintiff then asked the court instruct the jury that if they found that the plaintiff went on a visit to the master’s house and the master made no objection to such visit to Illinois, but employed him in planting corn and harvesting in Illinois and permitted the plaintiff to hire himself to labor in that State, they ought to find for the plaintiff.”

The trial judge declined to give this instruction. The jury returned a verdict in favor of Ruddle. Nat appealed to the Supreme Court of Missouri.

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