and John. 111 (1820) [strict enforcement of Delaware attestation requirements for witnesses to deed of manumission]. On the other hand, the master's failure to comply with stringent provisions on importation of slaves resulted in freedom in Henderson v. Negro Tom, 4 Har. and John. 282 (18117). 104. Miller v. Negro Charles, 1 Gill and John. 390 (1829). The Court held that the payment clause was a condition subsequent. No condition subsequent could be effective to deprive an individual of his freedom. 105. . Maryland Laws 1810 Ch. 15 §3. 106. Maryland Laws 1817 Ch. 112. 107. Maryland Laws 1818 Ch. 208. The statute was commented on in Slemaker v. Marriott, 5 Gill and John. 406 (1833), noting that the act permitted the commitments of slaves "at the instance of owners not engaged in the slave traffic." 108. "The Formation of the American Colonization Society," 2 J. Neg. Hist. 209, 227 (1917). Other Maryland founders included J.S. Shaaf, Wm. Dudley Digges, J. Mason, and John C. Herbert. 109. Leroy Graham, Baltimore The Nineteenth Century Black Capital 63-77 (1982). 110. Maryland Laws 1826 Ch. 172. 111. Maryland Laws 1831 Resolution No. 124. 112. Russel B. Nye, William Lloyd Garrison and the Humanitarian Reformers 24-29 (1955). 113. Petitions for the gradual abolition of slavery were referred to a committee in 1827 which called slavery a national calamity but said legislation was inexpedient at that time. A petition in 1829 from Frederick county was ignored, but in 1832 a committee was ordered to enquire into the expediency of gradual abolition. Nothing came from these petitions. Brackett, supra note 1 at 55-56. In 1837 the state constitution was amended to prohibit the abolition of slavery except by unanimous vote of both houses of the legislature. Maryland Laws 1836 Ch. 197 §26. 114. Maryland Laws 1831 Ch. 323 §7. 115. Maryland Laws 1831 Ch. 323 §1,2. The free negro would thus be subject to all the laws prohibiting immigration from another state. 116. In 1833 the legislature noted that the American Colonization Society had not drawn on the state treasury for appropriations for several years and, in light of the state's own colonization project, repealed the appropriations. Maryland Laws 1832 Ch. 314. 207