Published online by Cambridge University Press: 02 April 2020
Roberts v. City of Boston is a well-known legal case in the history of US education. In 1847, the Boston School Committee denied Sarah C. Roberts, a five-year-old African American girl, admission to the public primary school closest to her home. She was instead ordered to attend the all-black Abiel Smith School, about a half-mile walk from her home. In March 1848, Sarah's father, Benjamin, sued the city of Boston for denying Sarah the right to attend the public school closest to her home. The case wound its way through the courts, eventually reaching the Massachusetts Supreme Judicial Court. In 1850, Chief Justice Lemuel Shaw ruled in favor of the city of Boston, affirming that the Boston School Committee had “not violated any principle of equality, inasmuch as they have provided a school with competent instructors for the colored children, where they enjoy equal advantages of instruction with those enjoyed by the white children.” And thus, the doctrine of separate but equal was born in Massachusetts.
1 Roberts v. Boston, 59 Mass. (5 Cush.) 198 (1850). See, for instance, Kaestle, Carl, Pillars of the Republic: Common Schools and American Society, 1780-1860 (New York: Hill and Wang, 1985), 178-79Google Scholar; Douglas, Davison M., Jim Crow Moves North: The Battle over Northern School Segregation, 1865-1954 (New York: Cambridge University Press, 2005), 12-60Google Scholar; and Moss, Hilary, Schooling Citizens: The Struggle for African American Education in Antebellum America (Chicago: University of Chicago Press, 2009), 164-89CrossRefGoogle Scholar.
2 Some sources state that Sarah C. Roberts was six years old at the time, but based on genealogical records, Sarah was born in September 1842, so she was five years old when her father sued the city of Boston in March 1848.
3 “Sarah C. Roberts vs. The City of Boston” in Reports of Cases Argued and Determined in the Supreme Judicial Court of Massachusetts, vol. 5, ed. Luther S. Cushing (Boston: Little, Brown, 1853), 203.
4 For more on the Plessy case, see Bishop, David W., “Plessy v. Ferguson: A Reinterpretation,” Journal of Negro History 62, no. 2 (April 1977), 125-33CrossRefGoogle Scholar; and Luxenberg, Steve, Separate: The Story of Plessy v. Ferguson, and America's Journey from Slavery to Segregation (New York: W. W. Norton, 2019)Google Scholar.
5 Chapter 256, Acts and Resolves Passed by the General Court of Massachusetts in the Year 1855 (Boston: William White, Printer to the State, 1855), 674-675.
6 One notable exception is an article written by Dargo, George, “The Sarah Roberts Case in Historical Perspective,” Massachusetts Legal History: Journal of the Supreme Judicial Court Historical Society 3 (1997), 37-52Google Scholar.
7 See also, Daniels, John, In Freedom's Birthplace: A Study of the Boston Negroes (New York: Houghton Mifflin, 1914)Google Scholar; Horton, James O. and Horton, Lois E., Black Bostonians: Family Life and Community Struggle in the Antebellum North (New York: Holmes and Meier, 1979)Google Scholar; Levesque, George A., Black Boston: African American Life and Culture in Urban America, 1750-1860 (New York: Garland, 1994)Google Scholar; and Kantrowitz, Stephen D., More Than Freedom: Fighting for Black Citizenship in a White Republic, 1829-1889 (New York: Penguin Press, 2012)Google Scholar.
8 Kendrick, Stephen and Kendrick, Paul, Sarah's Long Walk: The Free Blacks of Boston and How Their Struggle for Equality Changed America (Boston: Beacon Press, 2004), 258Google Scholar.
9 Carl Kaestle's article served as a springboard for this essay. Kaestle, Carl, “Standards of Evidence in Historical Research: How Do We Know When We Know?,” History of Education Quarterly 32, no. 3 (Fall 1992), 361-66CrossRefGoogle Scholar.
10 Kendrick and Kendrick, Sarah's Long Walk, 257.
11 Sarah's possible reticence reminds me of Darlene Clark Hine's concept of the culture of dissemblance, which other scholars have cited to talk about black women's sexuality. See Hine, Darlene Clark, “Rape and the Inner Lives of Black Women in the Middle West,” Signs 14, no. 4 (Summer 1989), 912-20CrossRefGoogle Scholar.
12 For a fascinating article on how to deal with the problem of a trove of sources, see Taylor, Ula, “Women in the Documents: Thoughts on Uncovering the Personal, Political, and Professional,” Journal of Women's History 20, no. 1 (Spring 2008), 187-96CrossRefGoogle Scholar.
13 I remember reading classic texts, such as Cooper, Anna Julia, A Voice from the South: By a Black Woman of the South (Xenia, OH: Aldine Printing House, 1892)Google Scholar; and Wright, Marion Manola Thompson>, The Education of Negroes in New Jersey (New York: Teachers College, Columbia University, 1941)Google Scholar as well as contemporary monographs, such as Perkins, Linda M., Fanny Jackson Coppin and the Institute for Colored Youth, 1865-1902 (New York: Garland, 1987)Google Scholar; Hunter, Tera W., To ’Joy My Freedom: Southern Black Women's Lives and Labors after the Civil War (Cambridge, MA: Harvard University Press, 1997)Google Scholar; and Royster, Jacqueline Jones, Traces of a Stream: Literacy and Social Change Among African American Women (Pittsburgh: University of Pittsburgh Press, 2000)CrossRefGoogle Scholar.
14 White, Deborah Gray, “My History in History,” in Telling Histories: Black Women Historians in the Ivory Tower, ed. White, Deborah G. (Chapel Hill: University of North Carolina Press, 2008), 94CrossRefGoogle Scholar.
15 In fact, I felt encouraged after reading Ronald E. Butchart's historiographical essay on African American education and his call for further scholarship on African American girls’ and women's education. See, Butchart, Ronald E., “‘Outthinking and Outflanking the Owners of the World’: A Historiography of the African American Struggle for Education,” History of Education Quarterly 28, no. 3 (Fall 1988), 333-66CrossRefGoogle Scholar.
16 Crystal Feimster, “Not So Ivory: African American Women Historians Creating Academic Communities,” in White, Telling Histories, 283.
17 Hartman, Saidiya V., Lose Your Mother: A Journey Along the Atlantic Slave Route (New York: Farrar, Straus and Giroux, 2007), 17Google Scholar.
18 I am thinking of recent studies showcasing a brilliant reading and analysis of sources to tell the stories of enslaved African American women. See, for instance, Nathans, Sydney, To Free a Family: The Journey of Mary Walker (Cambridge, MA: Harvard University Press, 2012)CrossRefGoogle Scholar; Dunbar, Erica Armstrong, Never Caught: The Washingtons’ Relentless Pursuit of Their Runaway Slave, Ona Judge (New York: 37 INK/Atria, 2017)Google Scholar; Hartog, Hendrik, The Trouble with Minna: A Case of Slavery and Emancipation in the Antebellum North (Chapel Hill: University of North Carolina Press, 2018)CrossRefGoogle Scholar; and McDaniel, W. Caleb, Sweet Taste of Liberty: A True Story of Slavery and Restitution in America (New York: Oxford University Press, 2019)Google Scholar.
19 Brown, Lois, “Death-Defying Testimony: Women's Private Lives and the Politics of Public Documents,” Legacy 27, no. 1 (June 2010), 138Google Scholar.
20 Bynum, Tara, “Cesar Lyndon's Lists, Letters, and a Pig Roast: A Sundry Account Book,” Early American Literature 53, no. 3 (2018), 841CrossRefGoogle Scholar.
21 I will share a few tips here: finding aids may not identify people (of color) in a collection because archivists who processed the collection may not have known that people of color were even mentioned; names of schools did not remain constant so variations in search terms are required; source transcriptions (particularly from newspaper databases) are unreliable and the original must be examined; a Boolean search on Google might uncover newly processed collections that do identify people of color; and antiquarians, at any given point, might be auctioning fascinating material that could be purchased for a nominal fee.
22 I did not find these sources in chronological order, though I discuss them here that way for the sake of clarity.
23 New Haven City Directory (New Haven, CT: Price, Lee, 1879).
24 I thank reference librarian Jeannie Sherman at the Connecticut State Library for helping me locate this file.
25 “City Court—Criminal Side—Judge Pardee,” (New Haven, CT) Morning Journal and Courier, Feb. 14, 1880, 4.
26 US Census Bureau, Tenth Census of the United States: 1880: Population Schedule, New Haven, Connecticut, roll 105, ED 082, 593D.
27 “List of Unclaimed Letters,” (New Haven, CT) Morning Journal and Courier, Aug. 25, 1880, 4.
28 It is not clear what happened to Sarah's relationship with Charles Caesar. It is unlikely, though, that Charles Caesar and Charles Dyer were the same person.
29 “City Court—Judge Studley,” New Haven (CT) Register, June 4, 1881, 4; “City Court—Criminal Side—Judge Studley,” (New Haven, CT) Morning Journal and Courier, Dec. 29, 1881, 4; “Police Notes,” (New Haven, CT) Morning Journal and Courier, July 8, 1882, 3.
30 “Police Notes.”
31 I also returned to secondary sources, such as Moss, Schooling Citizens; Daniels, John, In Freedom's Birthplace: A Study of Boston Negroes (Boston: Houghton Mifflin, 1914)Google Scholar; and Arthur O. White, “Blacks and Education in Antebellum Massachusetts: Strategies for Social Mobility” (EdD diss., State University of New York at Buffalo, 1971), to understand earlier interpretations of the Roberts case and Benjamin F. Roberts's role.
32 “Death of B[enjamin]. F. Roberts,” Boston Globe, Jan. 25, 1895, 10.
33 Benjamin Roberts, Report of the Colored People of the City of Boston, on the Subject of Exclusive Schools (Boston, n.p., 1850), 2, Boston Public Library, RB XH.860.R54R.
34 “Equal School Rights,” (Boston) Liberator, Feb. 8, 1850, 3.
35 B[enjamin]. F. Roberts, “Our Progress in the Old Bay State,” (Washington, DC) New National Era, March 31, 1870, 1.
36 Baumgartner, Kabria, In Pursuit of Knowledge: Black Women and Educational Activism in Antebellum America (New York: New York University Press, 2019), 152Google Scholar.
37 Annual Report of the School Committee of the City of Boston 1857 (Boston: Geo C. Rand & Avery, 1858), 337.
38 Roberts, “Our Progress in the Old Bay State.”
39 “Death of Mrs. Adeline Roberts,” (Maysville, Kentucky) Evening Bulletin, Feb. 16, 1887, 1.
40 See, for instance, “Speech of Charles Lenox Remond,” (Boston) Liberator, Dec. 28, 1855, 2; and “Triumph of Equal School Rights, in Boston,” Proceedings of the Presentation Meeting Held in Boston, Dec. 17, 1855 (Boston: R. F. Wallcut, 1856). I also argue this point at length in my book, In Pursuit of Knowledge.
41 Death record of Sarah C. Laws, April 27, 1896, Record of Deaths in the Town of Orange 1, 550, Registrar of Vital Statistics, Orange, New Haven County, Connecticut.
42 Recent studies on the history of black girlhood include Simmons, LaKisha Michelle, Crescent City Girls: The Lives of Young Black Women in Segregated New Orleans (Chapel Hill: University of North Carolina Press, 2015)CrossRefGoogle Scholar; Chatelain, Marcia, South Side Girls: Growing Up in the Great Migration (Durham, NC: Duke University Press, 2015)CrossRefGoogle Scholar; Cox, Aimee Meredith, Shapeshifters: Black Girls and the Choreography of Citizenship (Durham, NC: Duke University Press, 2015)CrossRefGoogle Scholar; and Wright, Nazera Sadiq, Black Girlhood in the Nineteenth Century (Urbana: University of Illinois Press, 2016)CrossRefGoogle Scholar. There is a growing body of literature on African American girls and education in the contemporary moment. See, for instance, Fordham, Signithia, Downed by Friendly Fire: Black Girls, White Girls, and Suburban Schooling (Minneapolis: University of Minnesota Press, 2016)CrossRefGoogle Scholar; and Morris, Monique W., Pushout: The Criminalization of Black Girls in Schools (New York: New Press, 2016)Google Scholar.
43 The New Haven County Superior Court Divorce file for the Casneaus did not provide Sarah's age. I weighed the possibility that perhaps New Haven County had, at first, incorrectly recorded Sarah's age and then never changed it, but that fails to explain why the 1880 US Census listed a similar birth year for Sarah.
44 Wright, Black Girlhood in the Nineteenth Century, 8.
45 Baumgartner, In Pursuit of Knowledge, 10.
46 “Cambridge Man Host at Birds’ Dawn Breakfasts,” Boston Globe, Dec. 28, 1929, 12.
47 “Equal School Privileges,” (Boston) Liberator, April 4, 1851, 3.