Crandall v. The State of Connecticut

10 Conn. 339 (1834)

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Crandall v. The State of Connecticut

Connecticut Supreme Court
10 Conn. 339 (1834)

  • Written by Tammy Boggs, JD

Facts

In an information, the prosecutor (plaintiff) charged Prudence Crandall (defendant) with violating a Connecticut statute that prohibited the teaching or schooling of nonresident Black people without obtaining required written consents. The statute did not apply under certain circumstances, including the school’s proper licensure. The information alleged that (1) Crandall set up a school in the state for the education of Black nonresidents, (2) specified nonresident Black persons boarded and attended the school, and (3) Crandall did not obtain the required consents. The information did not allege that Crandall’s school was unlicensed. At trial, Crandall argued that even if the alleged facts were proved, the nonresident Black students were citizens of their respective birth states and entitled to the privileges and immunities guaranteed to all citizens under the U.S. Constitution. She claimed that the statute was unconstitutional. The trial court instructed the jury that free Black people were not citizens, and the jury convicted Crandall. Her post-judgment motion and appeal focused on the trial court’s instructional error and the statute’s invalidity on constitutional grounds.

Rule of Law

Issue

Holding and Reasoning (Williams, J.)

Dissent (Daggett, J.)

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