## Facts

- Margaret Morgan, enslaved for life under Maryland law, left Maryland and lived in Pennsylvania beginning in 1832.
- Pennsylvania statutes, including an 1826 law, criminalized forcibly taking and carrying away a Black person from Pennsylvania with intent to hold that person as a slave for life.
- Edward Prigg, a Maryland citizen acting as an agent for the claimed owner, sought to reclaim Morgan as a fugitive from labor.
- Prigg obtained a warrant from a Pennsylvania justice of the peace, but the magistrate refused to proceed.
- Prigg nevertheless seized Morgan and her children in Pennsylvania, took them to Maryland, and delivered them to the claimant.
- Pennsylvania indicted and convicted Prigg under the 1826 statute based on a special verdict establishing the material facts.

## Issues

1. Whether the Fugitive Slave Clause (U.S. Const. art. IV, § 2) grants slaveholders a federal right to recapture fugitives that states may not restrict through penalties or procedural conditions.
2. Whether Congress may enact implementing legislation for fugitive-slave rendition and whether the Fugitive Slave Act of 1793 is constitutional.
3. Whether federal authority over fugitive-slave rendition is exclusive so that conflicting state laws are preempted.
4. Whether a state may require its officials to participate in enforcing the federal rendition scheme, or conversely compel enforcement of state restrictions against federal claimants.

## Decision

- The Supreme Court reversed Prigg’s conviction.
- The Court held the Fugitive Slave Clause created a federal right of reclamation that state law could not qualify or restrain.
- The Court upheld the Fugitive Slave Act of 1793 as a valid exercise of congressional power to implement the Clause.
- The Court ruled Pennsylvania’s 1826 statute unconstitutional as applied because it conflicted with the federal constitutional and statutory scheme and was therefore preempted under the Supremacy Clause.
- The Court stated states were not constitutionally required to use state officers or state magistrates to enforce the federal fugitive-slave law; state officers could act only if state law permitted.

## Legal Principles

- The Fugitive Slave Clause confers an affirmative federal right on the claimant to recover a person held to service or labor who escapes into another state; states may not impose conditions that burden or obstruct that right.
- Congress may provide a uniform federal process to enforce fugitive-slave rendition; the Fugitive Slave Act of 1793 was within congressional power.
- When Congress legislates in this area, conflicting state measures—especially those imposing criminal penalties or alternate procedures on federal claimants—are invalid under federal supremacy.
- Although federal law is supreme, states are not obligated to supply state executive or judicial officers to administer or enforce the federal rendition process; participation by state officials is voluntary unless state law forbids it.

## Conclusion

The Court invalidated Pennsylvania’s application of its kidnapping statute to a fugitive-slave recapture, holding that the Constitution and the federal Fugitive Slave Act of 1793 displaced conflicting state restrictions, while also recognizing that state officials could not be compelled to enforce the federal rendition regime.


Prigg v. Pennsylvania, 41 U.S. (16 Pet.) 539 (1842)