Eliza Winston Court Case

Black and white photograph of entrance to Winslow House, St. Anthony. 1860 photo by William H. Jacoby.
Entrance to Winslow House, St. Anthony. 1860 photo by William H. Jacoby.

On August 21, 1860, enslaved African American Eliza Winston was freed from her Mississippi owner in a Minneapolis court. After being granted legal freedom, however, Winston faced white mob violence and was forced to leave the area. The event showed that although slavery was illegal in Minnesota, many white Minnesotans supported the practice when it economically benefited them.

Eliza Winston was forty-two years old in 1860, and she had been close to freedom once before. Her husband was a free man of color who planned to buy Winston's freedom from her owner at the time. But he died during a trip to Liberia, and Winston was pawned or sold to Mississippian Richard Christmas.

In the summer of 1860, Winston traveled to St. Anthony when Christmas, his wife, Mary, and their young daughter went on vacation. Christmas brought Winston along so she could care for the daughter and for Mary, who was ill. He promised to free Winston in July. Like many vacationing Southern slaveholders, the Christmases roomed at the Winslow House.

Although slavery was legal in Southern states, Minnesota banned the practice in its first state constitution of 1857. But under the U.S. Supreme Court's 1857 Dred Scott v. Sandford ruling a few months earlier, an enslaved person could not become free simply because he or she lived in a state that banned slavery. Fortunately for Winston, Northern judges usually ignored the Dred Scott decision. If the circumstances were right, Winston had a chance of being freed.

While Winston was in St. Anthony, she met Emily Goodridge Grey and her husband, Ralph, a free African American couple. The Greys were respected community members and abolitionists with ties to powerful local figures. They introduced Winston to notable local anti-slavery leaders, including W.D. Babbitt, Ariel S. Bigelow, and William S. King, later founder of Northrup, King and Company.

On August 21, Emily Grey, Babbitt, and Grey's white friend Mrs. Gates filed a legal complaint asserting that Winston was being "restrained of her liberty by her master." By this time, the Christmases and Winston had moved from the Winslow House to a cottage on Lake Harriet, in Minneapolis. A judge sent the Hennepin County sheriff to bring her to court. A rowdy crowd of abolitionists accompanied the sheriff.

When the sheriff arrived, Mary Christmas ordered Winston to flee. Winston left slowly, however, and told the sheriff she wished to be free. The sheriff escorted her directly to the courthouse, where a judge could rule on the matter.

The scene outside the courthouse was a volatile one. The Hennepin County Courthouse was just across the river from St. Anthony, within view of the Winslow House, and many people in the area had an economic interest in slavery. If the court freed Winston, slaveholders would be less likely to visit the area. With that in mind, local businessmen and others who feared for their livelihood went to the courthouse to create a ruckus.

In court, Christmas's attorney argued that Winston's enslavement was legal. Winston's attorney read the single sentence from the state constitution and sat down. The judge, Charles E. Vanderburgh, was an abolitionist. He ruled in Winston's favor, and Christmas accepted the decision without complaint. He knew that despite the presence of pro-slavery mobs outside the courthouse, it was the abolitionists in the area who held political power.

The courtroom scene became chaotic, and a crowd outside protested Vanderburgh's decision. Winston's freedom was in danger, so Babbitt helped her escape to his home. That evening, a threatening gang of pro-slavery agitators surrounded the house. By then, however, Winston had disappeared to a safe house. Three days later, she filed an affidavit telling her story.

The Winston case revealed several contradictions in Minnesota's racial politics. On the one hand, the state constitution forbade slavery, and cities such as Minneapolis and St. Anthony were centers of the Midwest's abolition movement. On the other hand, many white Minnesota businessmen benefited from trade with Southern slaveholders, and white Minnesotans could be quick to form racial mobs.

As local business owners had feared, the Winston case did slow Southern tourism to Minnesota. This was a problem for only a few months, however. Southern states began leaving the Union in December 1860, following the election of Abraham Lincoln, and the Civil War erupted the following April.

Cite
Cartwright, R. L.. "Eliza Winston Court Case." MNopedia, Minnesota Historical Society. https://www3.mnhs.org/mnopedia/search/index/event/eliza-winston-court-case
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First Published: October 25, 2013
Last Modified: April 10, 2025

Bibliography

Green, William D. "Eliza Winston and the Politics of Freedom in Minnesota, 1854–1860." Minnesota History 57, no. 3 (Fall 2000): 106–122.
http://collections.mnhs.org/MNHistoryMagazine/articles/57/v57i03p106-122.pdf

———. "The Summer Christmas Came to Minnesota: The Case of Eliza Winston, a Slave." Law and Inequality: A Journal of Theory and Practice 8, no. 1 (November 1989): 151–177.

Grey, Emily O. Goodridge. "A Black Community in Memoir." Ed. Patricia C. Harpole. Minnesota History 49, no. 2 (Summer 1984): 42–53.
http://collections.mnhs.org/MNHistoryMagazine/articles/49/v49i02p042-053.pdf

Lehman, Christopher P. It Took Courage: Eliza Winston's Quest for Freedom. St. Paul: Minnesota Historical Society Press, 2024.

Klement, Frank. "The Abolition Movement in Minnesota." Minnesota History 32, no.1 (March 1951): 15–33.
http://collections.mnhs.org/MNHistoryMagazine/articles/32/v32i01p015-033.pdf

Turner, Lois. "An Analysis of the Negro Slavery Issue in Minnesota, 1819–1861." M.Ed. thesis, Macalester College, 1965.

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Related Audio

MN90: Eliza Winston's Case for Freedom | Details

MN90: Eliza Winston's Case for Freedom

Britt Aamodt tells the story of Eliza Winston and her suit for freedom in Minnesota.
© AMPERS    

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Related Images

Black and white photograph of entrance to Winslow House, St. Anthony. 1860 photo by William H. Jacoby.
Entrance to Winslow House, St. Anthony. 1860 photo by William H. Jacoby.
Black and white photograph of Winslow Hotel, St. Anthony, c.1865.
Winslow Hotel, St. Anthony, c.1865. Visitors playing croquet. Until 1860, the Winslow Hotel was popular among vacationing Southerns who brought the enslaved people they owned with them. Eliza Winston came to the Winslow Hotel with her owner, Richard Christmas, and his family.
Black and white photograph of view of Winslow House, Upton Block and Jarrett House, St. Anthony.
View of Winslow House, Upton Block and Jarrett House, St. Anthony. 1858, photographed by Benjamin Franklin Upton. On the left is the elegant Winslow House, perched above the Mississippi River; at center is a store selling iron and steel nails, groceries, and other provisions; and on the right is the Jarrett House, where Ralph Grey had a barbering business.
Black and white photograph of Winslow House, St. Anthony, 1860.
Winslow House, St. Anthony, 1860.
Black and white photograph of Winslow Hotel and Seven Corners, 1861.
Winslow Hotel and Seven Corners, 1861.
Black and white portrait of Judge Charles E. Vanderburgh.
Judge Charles E. Vanderburgh c.1872. Vanderburgh presided over the Eliza Winston court case in August 1860.
Black and white photograph of entrance to Winslow House, St. Anthony. 1860 photo by William H. Jacoby.

Entrance to Winslow House, St. Anthony

Entrance to Winslow House, St. Anthony. 1860 photo by William H. Jacoby.

Public domain

Holding Location

Minnesota Historical Society
Black and white photograph of Winslow Hotel, St. Anthony, c.1865.

Winslow Hotel, St. Anthony

Winslow Hotel, St. Anthony, c.1865. Visitors playing croquet. Until 1860, the Winslow Hotel was popular among vacationing Southerns who brought the enslaved people they owned with them. Eliza Winston came to the Winslow Hotel with her owner, Richard Christmas, and his family.

Holding Location

Minnesota Historical Society
Black and white photograph of view of Winslow House, Upton Block and Jarrett House, St. Anthony.

View of Winslow House, Upton Block and Jarrett House, St. Anthony

View of Winslow House, Upton Block and Jarrett House, St. Anthony. 1858, photographed by Benjamin Franklin Upton. On the left is the elegant Winslow House, perched above the Mississippi River; at center is a store selling iron and steel nails, groceries, and other provisions; and on the right is the Jarrett House, where Ralph Grey had a barbering business.

Public domain

Holding Location

Minnesota Historical Society
Black and white photograph of Winslow House, St. Anthony, 1860.

Winslow House, St. Anthony

Winslow House, St. Anthony, 1860.

Public domain

Holding Location

Minnesota Historical Society
Black and white photograph of Winslow Hotel and Seven Corners, 1861.

Winslow Hotel and Seven Corners, 1861

Winslow Hotel and Seven Corners, 1861.

Public domain

Holding Location

Minnesota Historical Society
Black and white portrait of Judge Charles E. Vanderburgh.

Judge Charles E. Vanderburgh

Judge Charles E. Vanderburgh c.1872. Vanderburgh presided over the Eliza Winston court case in August 1860.

Public domain

Holding Location

Minnesota Historical Society

Turning Point

On August 21, 1860, Eliza Winston, an enslaved African American woman brought to Minneapolis with the family of her Mississippi owner, is declared free by Judge Charles E. Vanderburgh.

Chronology

1856
Construction begins on the Winslow House, a five-story hotel near the Falls of St. Anthony that soon becomes popular among vacationing Southerners.
March 6, 1857
The U.S. Supreme Court, in Dred Scott v. Sandford, declares that enslaved people are not citizens and thus have no right to sue in federal courts.
August 1857
Minnesota's constitution is completed and outlaws slavery in the state.
1860
Eliza Winston is ruled free by Judge Charles E. Vanderburgh on August 21.
1861
The Civil War begins with the attack on Fort Sumter, South Carolina, on April 12.

Bibliography

Green, William D. "Eliza Winston and the Politics of Freedom in Minnesota, 1854–1860." Minnesota History 57, no. 3 (Fall 2000): 106–122.
http://collections.mnhs.org/MNHistoryMagazine/articles/57/v57i03p106-122.pdf

———. "The Summer Christmas Came to Minnesota: The Case of Eliza Winston, a Slave." Law and Inequality: A Journal of Theory and Practice 8, no. 1 (November 1989): 151–177.

Grey, Emily O. Goodridge. "A Black Community in Memoir." Ed. Patricia C. Harpole. Minnesota History 49, no. 2 (Summer 1984): 42–53.
http://collections.mnhs.org/MNHistoryMagazine/articles/49/v49i02p042-053.pdf

Lehman, Christopher P. It Took Courage: Eliza Winston's Quest for Freedom. St. Paul: Minnesota Historical Society Press, 2024.

Klement, Frank. "The Abolition Movement in Minnesota." Minnesota History 32, no.1 (March 1951): 15–33.
http://collections.mnhs.org/MNHistoryMagazine/articles/32/v32i01p015-033.pdf

Turner, Lois. "An Analysis of the Negro Slavery Issue in Minnesota, 1819–1861." M.Ed. thesis, Macalester College, 1965.

Related Resources