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Pierre Choteau, Senior, in Error v. Marguerite, a Woman of Colour

Citations: 37 U.S. 507; 9 L. Ed. 1174; 12 Pet. 507; 1838 U.S. LEXIS 368

Court: Supreme Court of the United States; March 18, 1838; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The case involves a legal challenge initiated by Marguerite, a woman of color, in 1825, who sought to establish her freedom from Pierre Choteau, Senior, by claiming descent from an Indian woman, Marie Scipion. Initially, a verdict favored Marguerite, but it was overturned, leading to retrials. The Missouri Supreme Court eventually ruled in her favor, and Choteau appealed to the U.S. Supreme Court. Choteau argued that the jury should have been instructed on the historical context of slavery in Louisiana, particularly regarding the status of Marie Scipion and the implications of the Louisiana treaty. However, the court denied these instructions, and the Missouri Supreme Court upheld the decision favoring Marguerite. Choteau further appealed under the Judiciary Act of 1789, claiming treaty protections. The Supreme Court concluded that the treaty's construction was not questioned, and thus it did not have jurisdiction, citing precedents like Menard v. Aspasia and Crowell v. Randall. The motion to dismiss the writ of error was upheld, emphasizing that state laws govern post-statehood unless federal treaty provisions are explicitly invoked and pertinent to the court's decision.

Legal Issues Addressed

Application of State Laws Post-Statehood

Application: After the admission of a territory as a state, its constitution and laws govern, superseding prior treaty protections unless expressly preserved.

Reasoning: The Court reinforced that the Louisiana treaty’s protections were applicable until statehood, after which state constitution and laws would govern.

Jurisdiction of the Supreme Court Under Judiciary Act of 1789

Application: The Supreme Court's jurisdiction over state court decisions is limited to cases where a federal treaty or statute's construction is directly questioned and decided.

Reasoning: Previous cases, such as Menard v. Aspasia and Crowell v. Randall, established that the Court's jurisdiction in such matters only arises when a pertinent question has been explicitly presented and decided.

Termination of Parental Rights under Civil Code Section 232

Application: The case examines the jurisdiction of federal courts concerning state decisions on slavery and freedom under the Louisiana treaty.

Reasoning: The plaintiff in error claimed protection under the Louisiana treaty regarding the status of Marguerite, who was asserted to be his slave. However, the jury found her to be free, and the circuit court's instructions did not directly reference the treaty, leading to the conclusion that the treaty's construction was not questioned.