Dred Scott v. Sandford (Dred Scott citizenship)

Scott's residence in the Minnesota Territory and Illinois, both jurisdictions that prohibited slavery, would ordinarily have resulted in his emancipation under the principle that slavery cannot exist where legally prohibited. However, because the Court held that African Americans, including Scott, could not be citizens of the United States, Scott lacked standing to bring suit in federal court—a jurisdictional bar that rendered the merits of his freedom claim unreachable. The Court further invalidated the Missouri Compromise itself, reasoning that Congress lacked authority to prohibit slavery in the territories because doing so would deprive slaveholders of their property rights in enslaved people without due process, thereby eliminating the legal foundation that might otherwise have granted Scott his freedom.