Author: William Fernandez Hardin

JD, PhD, a history teacher at Montgomery Bell Academy, in Nashville, Tennessee
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Pleasants v. Pleasants (1799)

Pleasants v. Pleasants was the largest judicial manumission of enslaved persons in U.S. history. Decided May 6, 1799, the Virginia Supreme Court of Appeals ruled that more than 400 enslaved persons were entitled to freedom under a provision in the wills of their deceased former enslavers: John Pleasants III and his son, Jonathan Pleasants, both of Henrico County. John Marshall, future chief justice of the U.S. Supreme Court, represented the enslaved at the behest of Robert Pleasants, son of John and brother to Jonathan, and executor of both estates. Robert Pleasants asked family members to free the enslaved people in the estate as required by the wills after passage of a manumission act in 1782 that made it possible to free an enslaved person. Family members refused, and so Pleasants filed suit. Chancellor George Wythe first heard the case in the High Court of Chancery. Wythe upheld the freedom provisions in the wills, ordered the manumission of the enslaved, and directed their former enslavers to pay them back wages. On appeal, the Virginia Supreme Court of Appeals found the will’s freedom provisions valid, but struck down Wythe’s order assigning retributive pay to the formerly enslaved. As a result of the ruling, 185 enslaved persons were freed soon after the decision. Another 246 were deemed to have a vested right to liberty executable when they turned thirty years of age. The Pleasants decision helped establish the legal and ideological framework for manumission in post-Revolutionary Virginia. More broadly, it demonstrated to litigants, lawyers, judges, and lawmakers how to selectively employ and skillfully manipulate common law doctrines while incorporating the interests of slavery and slaveholders. The deference to liberty established in the Pleasants case would give way to a more rigid and less libertarian jurisprudence in the antebellum period.

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The Virginia Society for Promoting the Abolition of Slavery

The Virginia Society for Promoting the Abolition of Slavery, and the Relief of Free Negroes and Others, Unlawfully Held in Bondage, and Other Humane Purposes was a Richmond-based antislavery organization active from 1790 to 1804. Founded by Robert Pleasants, a wealthy Quaker slaveholder-turned-abolitionist from Henrico County, the society at its high-water mark claimed more than 100 members, many of whom were Quakers and more than a few of whom were Methodists. The Virginia Society petitioned the U.S. Congress and the General Assembly in support of gradual emancipation and provided legal support to wrongfully enslaved individuals. Although it enjoyed limited success in its early years, by the turn of the century it had lost members and support as white Virginians grew increasingly hostile to emancipation. By 1804, the society had ceased meeting completely. The Virginia Society, unlike most other antislavery organizations, was located in a slavery-based society and economy. The call for gradual emancipation, by definition, implied a radical transformation of the economy and society. Following the American Revolution (1775–1783), when all manner of change seemed possible, more than few white Virginians entertained and even endorsed abolition and emancipation in the abstract. Members of the Virginia Society attempted to capitalize on this feeling, but within the span of a decade, the once vigorous antislavery campaign had dissipated in Virginia.

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Robert Pleasants (1723–1801)

Robert Pleasants was an antislavery activist who founded the Virginia Society for Promoting the Abolition of Slavery and sued to enforce the manumission of his family’s slaves as called for in his father’s and half-brother’s wills. The resulting case, Pleasants v. Pleasants (1799), is the largest legal case in U.S. history involving the manumission of enslaved people. Born in Henrico County to a wealthy slaveholding Quaker family, Pleasants was educated in Philadelphia before returning home to help tend the family’s business interests. He encouraged his father and half-brother to write wills in the 1770s freeing their slaves contingent on the passage of a Virginia law in which such a manumission became legal. When such a law was passed, in 1782, surviving family members did not fulfill their responsibilities, causing Pleasants to sue and leading to the eventual freedom of at least 400 men, women, and children. Pleasants founded and served as president of the Virginia Society for Promoting the Abolition of Slavery from 1790 until his death in 1801, providing legal support to persons claiming to be wrongfully enslaved and submitting petitions against slavery and the transatlantic slave trade to the General Assembly and the U.S. Congress. Upon his death, Pleasants bequeathed Gravelly Hills, a 350-acre estate in Henrico County, to his former slaves as well as endowing a school for their descendants that operated until 1821.

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