Roberts v. City of Boston is a well-known legal case in the history of US education.Footnote 1 In 1847, the Boston School Committee denied Sarah C. Roberts, a five-year-old African American girl, admission to the public primary school closest to her home. She was instead ordered to attend the all-black Abiel Smith School, about a half-mile walk from her home.Footnote 2 In March 1848, Sarah's father, Benjamin, sued the city of Boston for denying Sarah the right to attend the public school closest to her home. The case wound its way through the courts, eventually reaching the Massachusetts Supreme Judicial Court. In 1850, Chief Justice Lemuel Shaw ruled in favor of the city of Boston, affirming that the Boston School Committee had “not violated any principle of equality, inasmuch as they have provided a school with competent instructors for the colored children, where they enjoy equal advantages of instruction with those enjoyed by the white children.”Footnote 3 And thus, the doctrine of separate but equal was born in Massachusetts.
Shaw's ruling in Roberts v. City of Boston was significant both in the long term, with subsequent legal cases such as Plessy v. Ferguson, and in the short term, given its impact on African American activists. In 1896, the United States Supreme Court issued a decision in Plessy v. Ferguson upholding the constitutionality of racial segregation, citing the doctrine of separate but equal.Footnote 4 It would take a little over a century to abolish this doctrine. Even in the 1850s, the decision in the Roberts case was a major blow to African American activists who had been fighting for educational equality in Massachusetts since the late eighteenth century. Continued protest by these activists eventually led to the passage of an 1855 law directing all Massachusetts public schools to integrate.Footnote 5 Those directly involved in the Roberts case were impacted, including Sarah's parents, Benjamin and Adeline Roberts; Sarah's siblings; and Sarah herself.
Much of the existing literature on this case completely loses sight of Sarah.Footnote 6 How did she feel about this case that her father had initiated on her behalf? And what difference, if any, did this case make in her life? The leading book on educational equality and African American activism in antebellum Boston is Stephen Kendrick and Paul Kendrick's Sarah's Long Walk: The Free Blacks of Boston and How Their Struggle for Equality Changed America.Footnote 7 The book contextualizes the Roberts case, profiling leaders such as William C. Nell. But not much information exists about Sarah's life that could begin to answer the questions posed above. Kendrick and Kendrick concluded that Sarah “was and remains a historical tabula rasa.”Footnote 8 Such a conclusion provokes even more questions about Sarah as well as the process of researching the early educational histories of African Americans, women, children, and the poor and working class.
Sarah is not exactly a historical tabula rasa, however. In fact, the case that bears her name makes it clear that there was more to know and learn—not only about black girlhood and education in nineteenth-century Boston but about archival research practices concerning African American children. I began my own quest by first studying the politics of the archive and then hunting down new sources. This essay describes that quest, one that historians and genealogists alike regularly follow. What I uncovered, however, enriches how we read and interpret what we thought we already knew about this case.Footnote 9
I take as my point of departure Kendrick and Kendrick's claim that “only glints and glimmers” of Sarah C. Roberts exist.Footnote 10 The fact that only glints and glimmers exist might actually have been deliberate—not just because the archive is a site of contestation over power that determines whose stories are preserved and whose are not, but also because maybe Sarah wanted to leave the Roberts case where it was—in the past.Footnote 11
The Politics of the Archive
My approach to archival research has been informed by decades of scholarship in the fields of African American women's history and slavery studies. As a scholar trained in African American studies, I have read often about the “source problem,” which could be defined in a few ways: nontraditional primary sources that other scholars question; a dearth of primary sources on a particular subject; or a trove of sources that, at first glance, seem to reveal little about the subject that interests the scholar.Footnote 12 Reading pathbreaking work in the aforementioned fields has shaped my historical thinking and my approach to studying and writing about African American women's and girls’ education.Footnote 13
I remember in graduate school reading Deborah Gray White's pioneering study A'rn't I a Woman? Female Slaves in the Plantation South in conjunction with her incredibly honest and illuminating essay describing the travails of publishing her research. White faced criticism and rejection not because her sources were insufficient, but because they were not “traditional white sources” like plantation records and southern newspapers.Footnote 14 Rather, she drew from hundreds of interviews of formerly enslaved people published by the Works Progress Administration in the 1930s. Her commitment to her research and her drive to stay the course inspired me. She is a trailblazer, and emerging scholars like me benefited—I did not have to defend my research question on African American women and education in the nineteenth century.Footnote 15
Of course, this question about searching for sources was not new: a whole generation of historians learned and taught others to, in Crystal Feimster's words, “read the silences and against the grain. … Sources were not nicely collected in folders filed numerically in cardboard boxes neatly stacked on shelves in some university archive.”Footnote 16 Moreover there was the reality that archives were violent spaces, erasing and fragmenting the stories of people of color. In Lose Your Mother, Saidiya Hartman's sobering words reverberated: “To read the archive is to enter a mortuary.”Footnote 17 Given my own interests in nineteenth-century African American women's history and childhood studies, I knew that my research process would require the kind of approach that Feimster had outlined as well as a sensibility that Hartman described. I continued to turn to scholarship in African American women's history and slavery studies as models, not just for argument and storytelling but for methodology, particularly the challenge of writing about a subject with a seemingly thin source base.Footnote 18
Once I acknowledged the politics of the archive and then bracketed the “source problem,” I felt less constrained and better positioned to rework known written materials, dive into the archive, and see what was there. Lois Brown has long encouraged scholars of nineteenth-century African American literature and history to “read what we have, behold the intimate, value the private that is exhibited in public buildings and private spheres, and make history hers in as many ways as we can [emphasis in original].”Footnote 19 A similar sentiment emerges in the work of Tara Bynum, who reminds us that searching in an archive for narratives of resistance or even “direct action” is a “present-day misunderstanding or a misguided expectation” of historical actors.Footnote 20 Both Brown and Bynum not only called for a reorientation toward archival work but also modeled it. I noticed in their scholarship something akin to an idea of archival optimism, which engages how racism, sexism, colonialism, and other forms of domination shape archival methods but which also embraces a commitment to reading what is there in archival collections. I adopted this archival optimism as I searched for Sarah.Footnote 21
Searching for Sources
I searched for Sarah by examining documents related to her parents as well as her extended family, and I tracked her marriage records. This approach neither sped up the research journey nor simplified it; on the contrary, there were quite a few cycles of searching for months, stopping, and then beginning again. Every time, I found an interesting primary source: Sarah's marriage and divorce records, Sarah's father's obituary and then her mother's obituary and will, Sarah's brother William's reflections on his family and even a photo of William in a Boston Globe article, and, eventually, Sarah's death record.Footnote 22 Each document on its own did not reveal much, but taken together, I started to generate new information that demanded a reinterpretation of the Roberts case with Sarah at the center.
Kendrick and Kendrick had learned that Sarah resided in New Haven with her then husband, John Casneau, a black ship's steward whom she married in February 1867 at the age of twenty-four in Boston. In the 1879 New Haven City Directory, Sarah C. Casneau is listed as a widow living at 39 Lafayette, the same address as her sister Caroline and her brother-in-law Eugene.Footnote 23 I conducted research in New Haven and turned up nothing after a months-long, time-consuming, and painstaking investigation. I then retraced my steps, looking for John's death record and will. I learned that he had not died but had moved to Providence, Rhode Island, and remarried. So, what really happened? I tracked John in city directories in New Haven and Providence. On a hunch, I examined the New Haven County Superior Court Divorce Files on microfilm and was rewarded when I found the Casneau divorce file. Perhaps when the New Haven City Directory was printed, Sarah reported that she was a widow, but legally she was not. In October 1879, John had filed for divorce, citing Sarah's affair with a man named Charles Caesar. The divorce was granted the following month.Footnote 24 How I wish I had more evidence to understand what else transpired between John and Sarah.
Adultery was a criminal offense in late nineteenth-century Connecticut. In February 1880, both Sarah and Charles Caesar were convicted of fornication and fined.Footnote 25 At minimum, these records proved that Sarah had resided in or around New Haven and dealt with legal issues. Strangely, however, after multiple searches, I could not find Sarah C. Roberts or Sarah C. Casneau in the 1880 US federal census. Given how often census takers mangled the spelling of Sarah's married surname, I looked for an approximate spelling. A Sarah Cassanny appears but there were numerous discrepancies: this Sarah was a twenty-three-year-old single black woman born in Connecticut to parents also from Connecticut. Her occupation was listed as washing and ironing.Footnote 26 Almost none of the data matched Sarah C. Roberts except for the race and name, which was actually a fairly close approximate spelling. In any case, Sarah C. Casneau had an unclaimed letter at the New Haven Post Office in August 1880, which further substantiated that she remained in the city after her divorce and conviction.Footnote 27
On December 11, 1880, Sarah C. Roberts Casneau married a thirty-five-year-old African American butcher named Charles Dyer.Footnote 28 The couple resided at her residence on Frank Street in New Haven. Curiously, her age was recorded as twenty-nine-years-old, but that is certainly incorrect as Sarah was born in 1842, not 1851. But all other data matched—name, race, and birthplace. The age discrepancy had to be a clerical error, I decided. It was thrilling, nonetheless, to have learned a little bit more about Sarah.
Unfortunately, her marriage to Charles was an unhappy one. He was arrested, jailed, and fined multiple times for assaulting Sarah—once sometime around June 1881, again around December 1881, and then again in July 1882.Footnote 29 During the July 1882 incident, he “assault[ed] his wife and kick[ed] her out of doors” and also attacked the police officer who arrested him.Footnote 30 It is unclear when, where, or if the marriage dissolved, at least legally. A Sarah Dyer was listed in the New Haven City Directory from 1882 to 1884 residing at 33 Winter Street, but no records have emerged yet to confirm these entries as Sarah C. Roberts. Hitting the proverbial wall, I revisited the documents related to the Roberts family, specifically Sarah's father, Benjamin.Footnote 31
Long after his death from epilepsy in September 1881, Benjamin Roberts was remembered as a successful African American printer who “made the final and winning fight at law” for equal school rights.Footnote 32 As a young man, he had attended one of Boston's segregated public schools, which made him feel “unworthy to be instructed in common with others.”Footnote 33 Similarly, African American educator Charles L. Reason decried racially exclusive schools for “teaching one child to feel that [another child] was … inferior in position and destiny.”Footnote 34 Benjamin sought to shield his children from any feelings of inferiority, so he waited until, in his words, he occupied a “more fitting position” to embark upon a “practical experiment” to enroll Sarah at an all-white public school closest to their family home.Footnote 35 He called it “an experiment”—a loaded term that signified hypothesizing, planning, and testing. Well aware of mid-nineteenth-century cultural values, particularly those associated with girlhood and innocence, that could be manifested to make racially exclusive schools a thing of the past, Benjamin pushed Sarah forward as the icon around which educational justice should be realized.Footnote 36 Yet, by filing a lawsuit on her behalf, he pushed her into a legal environment, hoping that jurists would recognize and protect her girlhood by affirming her right to an equal education. The court did not.
Even though the Roberts case did not result in the desegregation of Boston public schools, five years of African American protest, including multiple petition drives—first by Benjamin Roberts and then later by Nell—and subsequent legislation, achieved that result. With a statute declaring that “in determining the qualifications of scholars to be admitted to any public school … no distinction shall be made on account of the race, color or religious opinions,” Massachusetts became the first state to outlaw racial exclusion in public education.Footnote 37 Benjamin described the moment triumphantly:
The doors were thrown wide open, and it was to us the greatest boon ever bestowed upon our people. Our children do not feel now as their predecessors felt a thousand times while passing a school-house—as inferiors and outcasts. To them new ideas are opened; a number are learning trades; there is a growing anxiety to get into the professions, and it will not be many years ere the full results of this glorious change will find many of our successors in the full enjoyment of positions of honor and emolument [emphasis in original].Footnote 38
For Benjamin, whole new vistas of possibility had opened. Given his hopeful remarks here, I too wondered whether Sarah had carried the mantle of African American education, most likely as a teacher. I soon learned that she did not.
Five years after Benjamin's death, Sarah's mother, Adeline, died at the age of seventy from uterine cancer. Adeline left a will. To her sons William and Samuel she left her Boston home on Barton Street. The remainder of her estate was split among her seven living children, including Sarah C. Dane. This document confirmed that Sarah was indeed alive in February 1887, but her surname was incorrectly spelled in the will. Moreover, newspapers around the country, from Ohio to Tennessee, republished Adeline Roberts's death notice, which credited her husband, Benjamin, as the purveyor of the Roberts case.Footnote 39 In contrast, neither Adeline nor Sarah were accorded any role in the matter, even though African American mothers and children played a key role in antebellum educational reform.Footnote 40
In December 1887, Sarah resurfaced in a vital record, identified as Sarah Casno and married to twenty-seven-year-old Mahlon Laws, an African American laborer. This marriage record misspelled her surname as Casno and again provided the incorrect age—thirty-years-old, but the birthplace and race were accurate. Between 1887 and 1896, there is another gap in the record about Sarah. Did she leave New Haven County? What did she do for a living in the late 1880s?
After searching through reels of microfilm, I stumbled upon an undeniable source: the death record of Sarah C. Laws. Upon reading it, I knew I had a document that tied all of these earlier sources together and confirmed her identity. On April 27, 1896, Sarah died of cancer, the same disease that took her mother's life almost a decade earlier. Sarah's death record matched—her birthplace was Boston; her parents were listed as Benjamin and Adeline Roberts; and her place of death was Orange, West Haven, Connecticut, not far from the city of New Haven.Footnote 41 Sarah C. Roberts Casneau Dyer Laws: 1842–1896.
Interpreting the Sources
I drew from recent scholarship on the history of black girlhood to contextualize parts of Sarah's story and to reinterpret well-mined sources such as the legal arguments of Charles Sumner, a white lawyer who joined the Roberts legal team and later became a US senator from Massachusetts, the mountains of newspaper articles in the Liberator about Boston's equal school rights campaign, and African American petitions sent to the Massachusetts state legislature. Reform movements, among other factors, contributed to shifting perceptions of black girlhood in the late nineteenth and early twentieth centuries.Footnote 42 Historian Marcia Chatelain, for example, redefined black urbanization by exploring the Great Migration through the experiences and voices of black girls. As I studied the nineteenth-century Northeast, I discovered that Sarah C. Roberts was not the only black girl at the center of the equal school rights campaign. Other significant events also involved black girls, like Sarah Parker Remond in Salem, Massachusetts, and Eunice Ross in Nantucket, Massachusetts. This finding generates a new perspective, namely that black girls became symbols of educational justice. In the twentieth century, black girls such as Ruby Bridges were the face of school desegregation efforts, later immortalized in Norman Rockwell's 1964 painting The Problem We All Live With. But my work and the Roberts case demonstrate that this association has its origins in the nineteenth-century Northeast.
I also sat with the gaps and silences embedded within some of these sources, especially the strange business around Sarah's age. I surmise that the age discrepancy in Sarah's vital records could not be explained away as a mere clerical error. Rather, Sarah had altered her age, perhaps right around the time that she divorced John Casneau.Footnote 43 This misrepresentation surprised me and I have no explanation for it, but I am struck by the possibility that it could have been a form of self-protection—again, from what or whom, I am unsure. But this misrepresentation has implications as it relates to the Roberts case. When Sarah C. Roberts Casneau Dyer married her last husband, she indicated that her birth year was 1857, seven years after the Roberts ruling. The fact of the matter is that she likely would not have spoken publicly about the impact of the Roberts case since it would have exposed this lie about her age. Any reflections from her about the case or her activist family would have been done privately, anonymously, or, very possibly, not at all.
Since I do believe that Sarah misrepresented her age, then the 1880 US federal census record of Sarah Cassanny is indeed her. That means in late nineteenth-century New Haven Sarah labored as a washerwoman, like many other African American women, educated or not. If not washerwomen, then some worked as domestic servants. As scholar Nazera Wright argues, African American leaders knew that “no matter … how educated a black girl might become, she would face nearly insurmountable obstacles when she left her family home to make her way in the world.”Footnote 44 The popular belief in education as an elixir for freedom and prosperity completely ignores sociopolitical forces that constrained African American life. In other words, schooling did not suddenly broaden the occupational opportunities for even most African Americans nor did it protect them from economic uncertainty.Footnote 45
The Roberts case had a long-term impact on the identity of the Roberts family. In December 1929, a Boston Globe reporter wrote an article about William F. Roberts, a seventy-seven-year-old retired bookbinder who fed hungry pigeons and sparrows corn and breadcrumbs every day before the crack of dawn. The reporter focused on William, not so much as an old man who fed birds, despite what the article's title indicates, but because William was part of an African American family with deep roots in Massachusetts. William's father was Benjamin; his paternal grandfather was Robert, a servant, abolitionist, and later author of The House Servant's Directory: A Monitor for Private Families (1827); and his sister was Sarah, the plaintiff in the Roberts case. What William remembered, or at least what the reporter chose to print, was that Benjamin was “the first colored man in Boston to protest the exclusion of colored children from the public schools.”Footnote 46 At no point in the article did William mention his sister Sarah, who had been dead for some thirty-three years. Rather he talked about his father as the leader of the campaign for equal school rights—with no mention of Adeline either. No matter his own education, whatever that may have been, William and his wife were poor.
Despite the fact that education did not promise financial stability, African Americans fought hard for it nonetheless. Childhood was a time of intellectual and character development, and African American parents wanted their children to learn at the best schools. In that sense, many, though definitely not all, African American women, men, and children championed equal school rights, pursuing a host of strategies and tactics in the 1830s and 1840s. To think of Sarah's long walk as spur-of-the-moment activism is simplistic and overly romantic. Such an interpretation gives short shrift to the hours, days, and weeks of planning by activists, and it fails to account for the energy and activity needed to lead and participate in such a cause.
Conclusion
How did the documents I uncovered affect my interpretation of the Roberts case? While Sarah was at the center of this case, it was Benjamin's cause, one his whole life had primed him to take up. He did not wake up suddenly having to navigate segregated spaces; rather, he had them mapped out as a boy himself. A believer in education as an “immense value” and “powerful agent,” Benjamin seemed to want his children to regard education as a godsend and school as a democratic space.Footnote 47
Moreover, Sarah is not a historical tabula rasa, as mentioned earlier; she was a five-year-old girl thrust into the legal spotlight to win equal school rights in Boston. As a woman, she made New Haven County her home, navigating life's many challenges—personal, social, and legal. Her education did not result in upward social mobility later in life. Hence, searching for her was critical: to gain a deeper appreciation for the contours of African American protest; to locate civil rights as a nineteenth-century struggle with tactics and strategies that would inspire activists in the twentieth century; to wrestle with the importance of education as well as its limits, especially for marginalized people; and, most of all, to consider the consequences of placing vulnerable children at the center of causes that should not require their presence at all.
My approach to archival work invites historians of education studying people of color in the distant past to acknowledge the politics at work in the archive, which often fragment their stories. Instead of remaining stuck in that disappointment, stymied by silence, historians of education can explore what is there in the archive. Such a search centers the subject, and new theories emerge. Recent scholarship—in this case, on the history of black girlhood—can then frame a reinterpretation of sources, bringing more voices and stories to the fore.
