## Facts

- Prudence Crandall, a white schoolteacher in Canterbury, Connecticut, operated a boarding school for African American girls, including students from other states.
- Connecticut prosecuted Crandall under a 1833 statute that penalized keeping or supporting a school for “colored persons” who were not inhabitants of any Connecticut town without specified written local consent.
- The information alleged that on September 24, 1833, Crandall “harbour[ed] and board[ed]” named Black students who were not inhabitants of any Connecticut town, without the required written consent, so they could attend her school.
- The State’s proof showed the students were nonresidents who came from Rhode Island, Pennsylvania, and New York to attend the school for ordinary education.
- At trial, Crandall argued the students were citizens of their home states and therefore entitled to Article IV privileges and immunities, making the statute invalid as applied.
- The trial judge refused the requested constitutional instruction and instead instructed the jury that free Black persons were not “citizens” for federal constitutional purposes; the jury convicted Crandall.

## Issues

1. Whether the information adequately alleged all elements necessary to charge an offense under the 1833 statute.
2. Whether free Black persons from other states were “citizens” entitled to the Privileges and Immunities Clause, rendering the statute unconstitutional as applied.

## Decision

- The Connecticut Supreme Court of Errors reversed the conviction.
- The court held the information was legally insufficient because it did not substantially and accurately charge an offense under the statute with the required specificity.
- The court declined to decide the federal constitutional issues regarding Black citizenship and the Privileges and Immunities Clause.
- The reversal effectively ended the prosecution.

## Legal Principles

- A criminal information must plead, with sufficient certainty, the material statutory elements constituting the offense so the accused is informed of the charge and a conviction can be sustained.
- When a case can be resolved on a non-constitutional ground, an appellate court may avoid deciding constitutional questions.

## Conclusion

The court reversed Crandall’s conviction not by ruling on federal constitutional protections, but because the charging document failed to adequately allege a statutory offense, leaving unresolved the broader questions about Black citizenship and interstate privileges and immunities.


Crandall v. State, 10 Conn. 339 (Conn. 1834)