Chief Justice Roger Taney’s majority opinion in *Dred Scott* was one of the most consequential and catastrophic judicial decisions in American history. Taney held that enslaved people were not citizens of the United States and had no standing to bring a case in federal court. He held further that Congress had exceeded its authority in prohibiting slavery in certain territories under the Missouri Compromise. The implication was that enslaved people could be carried into any territory and that the prohibition of slavery in free states applied only to their domestic law, not to any claim of freedom for enslaved people brought within them.
The *Dred Scott* decision did not formally invalidate state-level freedom suits in the way Hayes conducted his proceedings. California was not a territory but a state, and its own constitution’s prohibition on slavery was a matter of state law rather than federal constitutional law. But *Dred Scott* significantly changed the legal environment in which such cases could be brought and the political climate in which judges would rule on them.
If Robert Smith’s December 1855 departure had succeeded and Mason and her family had reached Texas, the subsequent legal path would have been dramatically more difficult. Texas was a slave state, and a Texas court would have had no reason to apply California constitutional law to the question of their status. The *Dred Scott* ruling, one year later, would have foreclosed federal remedies. The only plausible path to freedom would have been through the Civil War and the Thirteenth Amendment in 1865 — nine years later than the actual ruling, and under completely different and far more violent circumstances.