One of Boston's earliest recorded slave rescue efforts, in which Black women forcibly freed two fugitives from a Massachusetts courtroom.
Key Facts
- Date
- August 1836
- Venue
- Massachusetts Supreme Judicial Court
- Fugitives rescued
- Eliza Small and Polly Ann Bates
- Origin of fugitives
- Baltimore, Maryland
- Presiding judge
- Chief Justice Lemuel Shaw
- Rescuers
- Spectators, mostly African-American women
Location
Cause → Event → Consequence
Eliza Small and Polly Ann Bates, two enslaved women from Baltimore, fled to Boston in 1836. They were arrested and brought before Chief Justice Lemuel Shaw. Shaw ordered them freed due to a defect in the arrest warrant, but the enslaver's agent immediately sought a new warrant, putting the women at renewed risk of capture and return to slavery.
When the enslaver's agent requested a new arrest warrant in the Massachusetts Supreme Judicial Court, spectators—predominantly African-American women—rioted inside the courtroom and physically rescued Small and Bates before a new warrant could be issued, allowing the two women to escape.
The incident became one of several notable slave rescue efforts in Boston and contributed to growing abolitionist resistance in Massachusetts. It preceded later actions on behalf of George Latimer, Ellen and William Craft, Shadrach Minkins, and Anthony Burns, and was part of the broader pressure that led to the passage of Massachusetts's 1843 Liberty Act prohibiting arrest of fugitive slaves.
Political Outcome
Two fugitive enslaved women, Eliza Small and Polly Ann Bates, were rescued from the courtroom by spectators and escaped re-enslavement.
Fugitive slave arrests enforceable in Massachusetts under federal norms
Growing legal and popular resistance; Massachusetts passed the 1843 Liberty Act barring fugitive slave arrests