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[31] Human Rights Watch interview with Gabriella G., 42, Lenoir County, North Carolina, May 18, 2013

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What emerged in the Dred Scott decision was a judicial concern for the substance of government action, a view that has come to be known as substantive due process. To some, substantive due process is an oxymoron concept, much like green, pastel redness, in the words of John Hart Ely.[v] In this decision, Chief Justice Roger Taney, joined by six other justices, ruled that the federal government had deprived a slaveholder of property without due process of law by forbidding slavery in free territories under the Missouri Compromise

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