Singleton Vaughan, a Missouri slaveholder, purchased Sam, Mariah, and their child from a slave trader in 1836. In 1837, with help from the Underground Railroad, the enslaved family escaped from Missouri to Hamilton County, Indiana, where they farmed using the surname of Rhodes. Vaughan discovered them in 1844 and obtained a warrant for their arrest. 

When Vaughan forcibly served the warrant, neighbors came to the Rhodes’ aid. Vaughan agreed to take his case to the Noblesville court to adjudicate the dispute, but on the road to Noblesville, amid a crowd of over 150 neighbors, the Rhodes escaped.

Vaughan filed a lawsuit in federal court in Indianapolis charging Owen Williams, the Quaker ringleader of the crowd, with obstruction. Meanwhile, the Rhodes’ neighbors organized an aid association to pay for the defense. The defense claimed that, since Indiana had not been a state when the U.S. Constitution was ratified (the Fourth Article required that fugitive enslaved individuals be returned), a slaveholder could not reclaim his property in Indiana. The judge ruled against this proposition, arguing that when Indiana accepted statehood it agreed to abide by the Constitution.

Vaughan lost the case against Williams, however, because the jury found the Rhodes entitled to their freedom before Vaughan had even bought them. Their previous master had moved with the other enslaved persons to Illinois and, upon learning that they should have gained their freedom after living in a free state for six months, abducted them and sold them to a slave trader in Missouri, who in turn unlawfully sold them to Vaughan.

The case set the precedent for the return of runaway enslaved persons from free states that had entered the Union after 1789, thus ensuring that the local Underground Railroad would remain in operation. The case also affirmed a right to freedom if enslaved individuals lived in a free state for more than six months with their master. Finally, it demonstrated the support of a local antislavery community in Hamilton County and Indianapolis that engineered and paid for the Rhodes’ defense.

Revised June 2021

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