Lemmon v. The People

Virginia residents the Lemmons (defendants), traveling with eight enslaved people through New York en route to Texas (both slave states) with no intent to sell anyone in New York, kept the enslaved people on land overnight while their ship docked in New York Harbor; New York law automatically freed any enslaved person brought into the state for any purpose. New York citizen Louis Napoleon (plaintiff) petitioned for habeas corpus, arguing the enslaved people became free upon touching New York soil; the Lemmons argued they were merely passing through. New York's courts agreed the enslaved people were freed, and the Lemmons appealed.