In 1846, Eulalie Mandeville, a “free woman of color” in New Orleans, became one of the richest Black women in the United States. Her intimate but not-married-to partner of five decades, Eugene Macarty, a white man, had left her nothing in his last will and testament—as per the letter of the law. But the pair had for years transferred cash, real estate, and other property, including six enslaved people, to Eulalie’s name. Combined with her own wealth as a successful businesswoman, all this made her worth some $155,000—$5 million in today’s money.
Smelling a windfall, forty-five of Macarty’s white collateral heirs, led by Eugene’s brother, sued to get what they considered their share of Eugene’s worth. They contended the mere $12,000 disbursed in his will was only a small portion of the total wealth and that the rest of it was hidden by fraud. Macarty et al. v. Mandeville, the resulting civil suit, lasted two years.
“Records, especially those of the local courts, offer an important vantage point into the lives of Black Americans,” historian Kimberly Welch writes, because such records
preserve oral histories and personal papers and documents that no longer exist elsewhere. Here we find family lore retold in plaintiff’s petitions, defendants’ answers, and witness testimony, along with long-lost letters, deeds, certificates, maps, images, accounts, and much, much more.
Court records can thus function as a kind of archive for those without any other paper trail, such as free people of color and the enslaved. Macarty et al. v. Mandeville is an unusually rich case in point. As Welch explains, the case archive
spans more than 350 pages of witness testimony, interrogatories; attorney’s arguments; summonses; evidence such as personal letters, deeds, accounts, and contracts; and judicial opinions (complete with the judges’ doodles, scribbles, and crossed out sections)—a rich and extensive handwritten case file that includes both the lower court trial record and the appeal to the Supreme Court of Louisiana.
No other archive of Eulalie Mandeville’s life exists. Covering “matters ranging from the moral and social implications of mixed-raced relationships to the sanctity of property in a slave society—and an individual’s ordinary or intimate predicaments,” the case therefore shines a light on a person and her times in a way no other historical record can.
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In the suit, Eulalie argued that the “property was hers, not Eugene’s, and the fruits of a long and productive life.” Welch writes that Eulalie, as an unmarried woman, “acted autonomously before the law and in the economy, and she built and operated a vast and successful business in her own right.”
Enslaved at birth in 1774, Eulalie was manumitted by her father and “owner” and became a member of his white family. When she met Eugene Macarty in 1793, she was already well-off as a dry goods dealer of “high-end French imports.” Eugene was penniless and in debt to his sister to the tune of $2,000. In sexual and financial partnership, the two proceeded to build up quite a fortune, with Eugene becoming a highly successful moneylender and “shaver,” one who bought promissory notes and bills of exchange low and sold them high.
The plaintiffs, meanwhile, argued the Eulalie Mandeville was nothing but a “Black ‘concubine’ and a small-time peddler, a person whose race and gender made her illegitimate as a legal wife and incapable of being an economic actor of any gravity.” In essence, writes Welch, “the lawsuit involved [Eulalie’s] right to secure a future for her children—the specific right contested by Eugene’s white heirs, who contended that the transfer of wealth should never benefit the mixed race and ‘illegitimate’ offspring […].”
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In fact, Eulalie and Eugene worked for decades to “to keep Eugene’s family out of their money and move wealth to their children, whose rights of inheritance the law did not fully protect.” The record shows careful estate planning fueled by intimate knowledge that “the relatives would rely on racial arguments and stereotypes to prevail over the wealth in question.” Eulalie and Eugene shrewdly used fair means, ambiguous means, and downright fraudulent means to their ends, knowing the law, written by white elites, was very much on the side of the “legitimate” white heirs.
Eulalie Mandeville ended up submitting “a mountain of evidence” to corroborate her case. Plaintiffs could present no evidence of fraud. They ended up relying on racist canards and insults. The Second District of New Orleans found for Eulalie Mandeville, ordering the plaintiffs to pay costs. Macarty et al. appealed to the Supreme Court of Louisiana. But that court also decided in Eulalie’s favor, protecting what the lower court judge called “the stability of fortunes,” unusually in this case for Eulalie and her heirs.
Eulalie Mandeville died five months after the final court decision, “her succession swift and without contention” as her fortune passed down to her and Eugene’s children.
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