had agreed to free her slave, Beverly Dowling, on payment of $200. She let him act as a free
man to earn the money to pay for his freedom, including allowing him to work as a waiter on a
steamboat in New York. After paying $173, he returned to Baltimore and tendered the last $27
payment for his freedom through a white intermediary, but the payment was refused. Bland had
Dowling arrested and she sold him to the slave trader Austin Woolfolk. On his petition for
freedom, Beverly Dowling received a judgment of freedom. The appellate court held that
Dowling could not enforce the contract to purchase his freedom. "[W]e cannot maintain the
principle that a slave can enter into any binding contract with his master, or that he could appear
as a suiter in any of our courts of justice, legal or equitable, to enforce any alleged contract."134
Nevertheless, the contract could be used to show that he had permission from Bland to leave the
state to earn money so that he could fulfill the promises. Having allowed Dowling to leave the
state on his own, she would be in violation of the law against the importation of slaves if she
attempted to exercise rights of ownership. Therefore the Court affirmed the judgment of freedom
for Dowling.

A later case involved a will provision that stated the testator's slaves should be free at
thirty eight years of age, providing they left the state within thirty days after reaching that age and
never returned. If they returned, they were to become slaves of the master's heirs. One of the
slaves became thirty eight in 1845 and received a certificate of freedom. He stayed in Maryland
for four years as a freeman until the second husband of his old mistress told him he must give
security or leave the state. To protect himself, he filed suit for freedom. The Baltimore County
Court and the Court of Appeals both held that he was free. A testator could prescribe the period
when freedom may begin, but he could not put an end to the state of freedom.135 Thus, the
manumission was effective and enabled the freed slave to get a certificate of freedom, and a
separate suit was necessary to force his emigration. That suit had to be brought by the board of
managers, and they seem to have had little stomach for such action. Perhaps one further reason
for the ineffectiveness of the forced emigration law was that it required the Board of Managers to
pay for costs in emigration if other sources could not be found.

From time to time, legislative committees considered further measures to rid the state of
its free black population. In 1836 the House Committee on Colored Population considered and
rejected a plan to require all free blacks to renew annually their certificates of freedom. The
committee balked, noting that the proposal would be an administrative nightmare and the ensuing
confusion might make escape for slaves easier. They also noted that the additional burden on an
already impoverished class would be unfair. The committee then considered alternative
proposals to compel free blacks to emigrate within a stated time. Once more the committee
rejected the idea, saying that forcing the free black population to move to the free states would
ease the road for runaway slaves and make cause with "fanatic" abolitionists. Further, coerced
removal was unjust.

However much every well-wisher of Maryland may desire to see her rid of the
free blacks, at present a vicious and degraded population, yet we do not think, said
the committee, that the enlightened legislators of the State are prepared, in the

55