In the absence of a specific stipulation, contracts would be construed under the laws of the state where they had been executed.
A contract to emancipate a slave, with no stipulation that it be executed outside Alabama, was void.
Facts of the Case
On December 15, 1848, planning a move to Texas, Dr. W.P. Kittrell sold a slave blacksmith named Carney to Stith Evans for $1250. Evans agreed that Carney or "his next friend" could purchase his freedom for the amount paid, with 10 percent interest. Kittrell subsequently sued in Greene County Chancery Court, saying that Carney had more than reimbursed Evans though his labor and demanded his removal from Alabama for the purpose of emancipation. Evans responded that he had not been reimbursed for Carneyís purchase and that, furthermore, the agreement to emancipate him was invalid. Judge James B. Clark rendered his decision on June 25, 1857: he ordered that Carney be removed to a free state and liberated.
I.W. Garrott argued Evansí case before the Alabama Supreme Court. He argued, among other things, that the decision in Praterís Administrator was inconsistent with several other Alabama Supreme Court decisions and asked that it be reconsidered.
W.M. Brooks argued Kittrellís case before the Alabama Supreme Court. He argued that his client could lawfully contract with Evans to perform any act that he might lawfully perform himself.
The Courtís Decision
Judge George Washington Stone [former law partner of Chief Justice William P. Chilton, who wrote the decision in Praterís Administrator] wrote the courtís decision. He argued that the contract between Kittrell and Evans did not specifically call for its execution outside Alabama, so the assumption was that it would be executed in-state. In-state emancipation was illegal in Alabama, so the contract was void. This reinstated the principle established in Trotter v. Blocker, which had been followed by the Alabama Supreme Court for most of its history. This overruled Praterís Administrator.