Early Years and Revolution
Pleasants was born in 1723 at the family’s plantation, Curles Neck, in Henrico County alongside the James River. He was the second son of John Pleasants III and his first wife, Margaret Jordan Pleasants. When he was a young man, his parents sent him to Philadelphia to live with the Pemberton family, who, like their Virginia counterparts, were a prominent, wealthy, and respected Quaker family. Upon his return home, Pleasants helped his father successfully expand the family’s various business enterprises. By 1771, the family owned more than 220 slaves and thousands of acres of land. In the meantime, Robert Pleasants remained active in the Society of Friends. He corresponded with his fellow Quakers and hosted influential visiting ministers in his home. Additionally, he served as clerk of the Quarterly Meeting of Virginia in 1750 and 1757, a relatively important position in the Society. By the 1770s, many Quakers, beginning in in Philadelphia and spreading to other northern colonies, had embraced antislavery, challenging fellow members to free any of the men, women, and children they held as slaves.
Inspired by Anthony Benezet, a leading Quaker abolitionist, pamphleteer, and educator, Pleasants sought to manumit his own slaves and suggested his father to do the same. John Pleasants eventually relented, composing a will in 1771 that stipulated freedom for the slaves when manumission became legal in Virginia. Robert Pleasants’s half-brother, Jonathan Pleasants, left a similar provision in his will. During the colonial period, only the House of Burgesses had the power to free slaves and only did so for meritorious service (such as informing on other slaves), or by removing them from the colony. Encouraged by antislavery reforms in the 1770s, and international opposition to the transatlantic slave trade, Robert Pleasants and his allies were confident that the law would eventually change. John Pleasants III, Robert’s father, died in 1771, and Jonathan Pleasants followed in 1777. As executor of both wills, Robert Pleasants distributed the two men’s enslaved people to various family members as required.
Efforts at legal reform were delayed by the onset of the American Revolution (1775–1783). British and Patriot forces occupied Robert Pleasants’s plantation and pillaged his property on numerous occasions. In spite of these depredations, Pleasants organized relief efforts for civilians affected by the war. When Patriot artillery set fire to the commercial and tobacco shipping center of Norfolk, Pleasants took donations, purchased relief supplies, and, despite Patriot suspicion of his assistance to the heavily Loyalist population of the town, endeavored to assist refugees fleeing the destruction. Beyond creating material deprivations, the war also tested Quaker commitments to pacifism and political neutrality. More than a few young Quaker men considered serving in the Continental army, including Pleasants’s own son, Robert Pleasants Jr. Pleasants counseled young Quakers not to compromise their religious commitment to pacifism, but a few did enlist in the army and were subsequently disowned by the Society of Friends.
Quakers who refused to serve in the military, however, attracted the suspicion of Patriot leaders who doubted their loyalty. In 1777, as British forces marched toward Philadelphia, Patriot leaders in the city arrested Robert Pleasants’s brother, Samuel Pleasants, along with members of the Pemberton family and other Quaker leaders, transporting them to Winchester, Virginia, where they were held under guard without legal process. Robert Pleasants lobbied for the release of these so-called Virginia Exiles, which did not come until April 1778.
Continued Antislavery Activities
Despite the hardships associated with the war, Pleasants believed that the conflict’s end signaled a new covenant between the new nation and God. In exchange for independence, Americans were duty-bound, according to Pleasants, to eliminate slavery. He and other Quakers renewed their antislavery lobbying efforts, helping to win the passage of the Manumission Act of 1782. Now slaveholders were allowed to free their slaves without government approval and without freedpeople being forced to leave the state. The General Assembly did require, however, that freed slaves be “of sound mind and body” and be able to provide for themselves. If they could not, then it was the former owner’s legal responsibility to support and maintain the freed people.
During the war, Pleasants had illegally freed a number of his father’s slaves and settled them on Gravelly Hills, a 350-acre plantation he owned in Henrico County. He shielded them from hostile neighbors but was eventually fined by local authorities for allowing putatively enslaved people to live unsupervised. With the new law’s passage, in 1782, he was finally able to legally manumit them. Other Virginia masters followed suit and there was a short-term surge of manumissions in the 1780s. In the following decade, however, the frequency of manumissions markedly declined. More distressing to Pleasants was the continued refusal of his relatives to free the slaves they held under his father’s and brother’s wills.
In 1784, the Virginia Yearly Meeting of Quakers declared that slaveholders who refused to manumit would be expelled from the meeting. When Pleasants pressed his family to follow the new rules, more than a few left the Society rather than comply with his demands. Religious and legal duty, he discovered, provided insufficient leverage to effectuate manumission. When persuasion failed, he petitioned the General Assembly in September 1790 to pass a law specifically enforcing his father’s and half-brother’s wills. After considering both sides of the matter, the assembly decided the case was best adjudicated in a court of law and declined to intervene.
Simultaneous to his private manumission campaign, Pleasants also waged a public one calling for the emancipation of all slaves. In 1790, he founded and became president of 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. Under his leadership, the society supported emancipation efforts by petitioning the General Assembly and the U.S. Congress, and assisted people who claimed they were wrongfully enslaved with litigation. The group was small, numbering just more than 100 members, and only a few were actively involved. The core membership remained primarily Quakers, and when Pleasants tried to recruit prominent Virginians such as St. George Tucker, Patrick Henry, and James Madison, they all declined. Further recruitment efforts stalled, and in December 1794 Pleasants was unable to find any members willing to attend an antislavery convention in Philadelphia. Following Pleasants’s death in 1801, meetings became infrequent and within several years, the society had dissolved.
Pleasants v. Pleasants
After failing to convince family members, including his brother-in-law Charles Logan, to manumit their slaves, Robert Pleasants filed suit in 1797. On September 12, 1798, Chancellor George Wythe of the High Court of Chancery ruled in favor of Robert Pleasants and the family’s enslaved men, women, and children. He ordered the defendants to pay reparations to the wrongfully enslaved for the economic losses they suffered while illegally detained. The defendants appealed the decision to the Virginia Court of Appeals. John Marshall, who was then practicing law in Richmond, represented Robert Pleasants and the enslaved people. Marshall conceded in oral arguments, delivered early in November 1798, that when the will was written, manumission was illegal under colonial law; however, the grant of freedom became good when the General Assembly legalized manumission in 1782. The enslaved, therefore, were entitled to freedom. Opposing counsel argued that when the will was probated, manumission was illegal, and the estate had been completely settled. The laws in place should determine probate of the estate, they argued. Lawyers representing the Pleasants family also argued that the rule against perpetuities, a doctrine of common law established to prevent indeterminacy in the disposition of an estate, rendered the freedom provision void.
The court’s judges, led by Spencer Roane, declined to apply the rule against perpetuities in the case. Roane explained that the rule was designed for estates in land, not cases of human freedom. Even if the rule were applied, Roane explained, the bequest would still be enforceable because there was no indeterminacy in it—either a slave became free in her lifetime or she did not. The gift of freedom would vest in that slave’s life or it would not, thus obviating the rule’s application. The court ruled in favor of freedom, but the judges limited the ruling in two important ways. First, the court unanimously struck down Wythe’s award of reparations, fearing that it would unsettle and destabilize slaveholder titles across Virginia. Second, the court required some of the enslaved people to serve their masters until they turned thirty years of age. Thus many of them would be forced to wait years for freedom and none would see recompense for the years they spent unlawfully enslaved.
Pleasants v. Pleasants is the largest legal case in U.S. history involving the manumission of enslaved people. The court found that 186 of Robert Pleasants’s slaves alone qualified for immediate freedom, and although the total number of Pleasants slaves manumitted is uncertain, at least 400 or so individuals held a legal right to freedom. Pleasants also took steps to assist the people formerly enslaved by his family. He was convinced that freed slaves, and their children, desperately needed an education to fit them for the demands of liberty and eventual citizenship. In 1796 and 1797 he corresponded with Thomas Jefferson on the subject and circulated a proposal for the establishment of a school for black children. In his will, Robert Pleasants left an endowment of land and money to establish such a school “for the benefit of the Children and descendants of who have been Emancipated by me, or other black Children whom they may think proper to admit.” He died on March 4, 1801, and the local Quakers working with the free African Americans of Gravelly Hills operated the school until 1821.
