Even emancipated and free-born Black people were often considered to be presumptive fugitives to be hunted, captured, and sold into slavery. As one nineteenth-century court ruled, “The presumption arising from the color of a person indicating African descent is, that he is a slave.”10 Some Northern states and territories, including Illinois, Indiana, and Oregon, banned the immigration of free Black people; some Southern states required that enslaved people who obtained freedom from their enslavers leave the state, to avoid any confusion about what Black people represented in American society.
