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Philadelphia and the End of North and South being split on the slave issue, but later cities like saw more unrest. In the end, Philadelphia played

a vital role in the growing abolitionist Michael Reardon movement in the . Without a Senior, History movement like the one in Philadelphia, it was possible that the Civil War could have Following the gradual emancipation occurred significantly later and slaves would of slavery in Pennsylvania in 1780, have been in bondage for decades longer. Philadelphia and its surrounding areas had a Just four years after the United States lasting impact on the practice in the United declared its independence from Britain, States. Being that Pennsylvania was Pennsylvania passed a law which called for bordered by multiple slave states, it was the slow abolition of slavery within its seen as a viable escape venue for many borders. This act permanently freed all slaves that wanted to escape their bondage. African-Americans that had already been Philadelphia had a long history in the United considered free. Essentially, under this law States’ ongoing slave debate and many anybody who was not already a slave could abolitionists at the time based themselves no longer be sold as property within the out of the Philadelphia area. Over time many commonwealth of Pennsylvania.1 The goal anti-slavery societies developed in the area in enacting this was to not anger current and abolitionists began to surface. These slave owners, but to ensure that abolitionists ranged from simple everyday Pennsylvania’s slave trade did not grow. people to men like Benjamin Franklin who This law brought a new type of society to remains a household name to this day. Pennsylvania. Philadelphia in particular was Along with abolitionists, the one of the most adaptive, as jobs, churches, became a popular and even schools were erected for the black option for slaves hoping to escape and many population. Despite racial issues arising in of the stops along the way were in the the city, and as more African-Americans Philadelphia area. Fugitive slaves often arrived, Philadelphia lived up to its name as escaped to Philadelphia and its suburbs and the “City of Brotherly Love.” As anti- hid out from slave catchers that hoped to slavery societies and anti-slavery rhetoric return them to the South. These grew within the city, Philadelphia quickly Underground Railroad stops made became one of the safest places for ex-slaves Philadelphia integral in slave escapes and in and fugitive slaves to go.2 their quest to obtain long-term freedom. It Despite the praise that Pennsylvania was through major cities in the early United received from many of its citizens, the States that the anti-slavery movement grew passage of this law did not please and the quest toward emancipation began. everybody. There were some who did not Initially, Northerners were content with the believe in the gradual abolition of slavery. In 1

1781, just one year after the law was put into standpoint.5 Philadelphia quickly had the action, there were attempts to repeal it. This largest concentration of African-Americans would have meant that free African- within the state of Pennsylvania.6 Its Americans living within Pennsylvania’s geographical location and growth in borders would once again be subjected to abolitionists within its borders made it an slavery. While the legislature voted against important city for the antislavery movement repealing the act, some of the letters and in the United States. articles that followed show how former One of the best ways for people to slaves coped with the possibility of their get the word of abolitionists to the public return to bondage. One such example of this was through anti-slavery societies. One of comes from a former slave named Cato who the earliest and most famous anti-slavery wrote about how nothing would be worse society to form in Philadelphia was the than granting slaves freedom, letting them Philadelphia Anti-Slavery Society. It was live a free life, and then returning them to founded in 1775, but did most of its work their bondage. Cato said, “Our lots in following Pennsylvania’s gradual abolition slavery were hard enough to bear; but law. The society was located on Walnut having tasted the sweets of freedom, we Street, which provided easy access for both should now be miserable indeed.” 3 He then its white and black members. Its overall goal questions Christianity by saying, “Surely no was to better the African race.7 This society Christian gentlemen can be so cruel!”4 One worked tirelessly at emancipating slaves and of the main tactics in employing the change growing the nation through its anti-slavery in laws at this time was to use freed blacks rhetoric. Many of their platforms stood on to reach out to the population. Ex-slaves’ ideas like slavery being anti-Christian and words were powerful and valuable in the slavery being harmful to the prosperity of fight to abolish slavery throughout the state the United States. The society called for the and country. speedy abolition of slavery and they Philadelphia was a popular believed that this could be achieved destination for fugitive slaves because it was peaceably and rather quickly. In other close to where Pennsylvania bordered slave words, the society believed that slavery states Delaware and Maryland. Slaves that could be abolished nationwide if the United lived in the northern parts of the South often States government took a similar approach recognized Philadelphia as part of their to the state of Pennsylvania. While they journey to freedom. In fact, former slave and waited for the movement to grow, they put abolitionist stated that some of their efforts into improving he would pay attention to how steamboats conditions for free African-Americans living got to Philadelphia. He would learn their in Philadelphia.8 This made them a society routes so that we would have a better for not only slaves, but a society for the understanding of how to get to the city and improvement of race relations in the United where it was from a geographical States. Of course, this did not come easily as 2

even free African-Americans were treated States, however it also had some other poorly throughout Philadelphia and the rest important aspects. In Pennsylvania, the of the country. organization took on smaller tasks like The Philadelphia Anti-Slavery education for the black community and Society was an extensive organization with a legally assisting African-Americans who hierarchy of power and annual membership were endangered by their opposition to fees. Its Constitution laid out the chain of slavery. While the institutions that command as well as the steps that people developed were segregated, they were a start needed to take if they wished to join. Some that very few other cities offered. Following of the rules required to join included being Pennsylvania passing the gradual twenty-one years old and being approved by emancipation law in 1780, this became the the Board of Managers. Once they accepted PAS’s main goal for the rest of the country. somebody into the society, the person would They often approached these types of be required to pay the annual fee of two movements through legal action instead of dollars. Similar to the Constitution of the mass organization. They are noted multiple United States, the society’s Constitution times having petitioned congress, federal required a two-thirds vote by the members courts, and state government. As the of the society to amend the document.9 This abolitionist movement grew, antislavery society essentially led Philadelphia through societies began to appear more often and the its role in the slave debate; its prominence PAS became less popular. Regardless, this was overwhelming throughout the city. The society was huge in starting the fight toward goal, to “never cease our endeavors, until abolition and the ultimate eradication of the slavery shall become entirely extinct, and institution.11 our institutions, effectually purged from the Following in the footsteps of gross impurities which they have acquired societies like the Philadelphia Anti-Slavery under its influence” brought people together Society and the Pennsylvania Abolition in joining and played a part in Philadelphia’s Society, the American Anti-Slavery Society importance during this critical time.10 was formed. This society was not simply an Another major anti-slavery society at organization for the city of Philadelphia or this time was the Pennsylvania Abolition the state of Pennsylvania, but a society Society (PAS). It was also founded in 1775, designed for growing the abolitionist and although the PAS was a statewide movement in the entire country. The other, organization, it was prominent and grew smaller and local societies essentially throughout the city of Philadelphia. It morphed into this bigger, unified society in quickly expanded to become the world’s 1833. While the smaller societies in leading anti-slavery organization during this Philadelphia did not go away, the fact that time. Its main focus was obviously on the American Anti-Slavery Society was abolishing the practice of slavery and housed within Philadelphia’s borders made emancipating every slave in the United the organization more appealing to those 3

serious about advocating for the abolition of Pennsylvania. The earliest signs of slavery.12 The American Anti-Slavery Franklin’s personal interest in the anti- Society was formed in Philadelphia on slavery movement came in the late 1750s, December 4, 1833 and quickly became the but Franklin was careful to keep his largest of such societies in the United States. abolitionist-agenda quiet. In 1729, Franklin Its entire goal revolved around the complete was approached by a writer who wished to emancipation of all slaves in the United publish an antislavery manuscript.16 At this States. Some of the other ideas that the point, Franklin was very wary on the slave society was founded on included elevating debate and did not yet speak of it publicly. the character and condition in which Franklin believed slavery to be a very African-Americans lived as well as complex issue and at the time it was highly improving race relations throughout the contested; Franklin did not yet want to risk United States.13 his reputation on a topic like slavery.17 In The anti-slavery movement in this instance, Franklin did agree to publish Philadelphia brought notable abolitionists, the manuscript, but did not list his one abolitionist of note during this time was publishing company as the printer of the Philadelphia native Benjamin Franklin. document.18 In the 1770s, Franklin decided Despite having one time been a slave owner to participate in both sides of the slave issue. himself, Franklin became an advocate for In letters during this time, Franklin told the emancipation of slaves as he grew older. antislavery advocates that he was with them, In fact, Franklin was even elected at one however, publicly he often supported the point to be the president of the Philadelphia practice. Following the Revolution, Franklin Abolition Society.14 His change from slave became more open about his views on owner to abolitionist was one that many slavery. He felt that prior to the Revolution, cannot pinpoint, but as the United States the main focus should have been on moved past the revolution, it became clear developing and creating the basics of the that Franklin was willing to transfer his country, but once that was complete he was energy into the slave debate. Franklin ready to discuss other issues. By the time frequently addressed public groups in the Franklin joined the Pennsylvania Abolition form of letters and speeches to speak out Society in 1787, he was prepared to make about his views on slavery. In 1789, bold steps toward ending the practice.19 It Franklin gave an address on the atrocities of was at this time that he began regularly slavery where he mentioned how slaves did publishing and speaking out about the not have the ability to make choices and that practice. As the society was growing, everything they did was governed by fear.15 Franklin was noted saying, “I myself The interesting things about Franklin printed…[works] against keeping negroes in as an abolitionist, was that he did not come slavery.”20 He claimed that he had been out publicly as an abolitionist until around publishing works of these abolitionists since the time slavery was abolished in as early as 1729.21 Some may find this rather 4

ironic, since Franklin did not publicly liberty and the pursuit of happiness.”23 The denounce the practice, however many of the expectation brought on by the United States publications that he sent to print were very government to literally capture and send valuable and contributed to the antislavery another human being into bondage, led to rhetoric in Philadelphia at his time. the formation of the Underground Railroad. As the slave debate waged on The beginning of the actual, formal throughout the 1800s, the north and south Underground Railroad began following a struggled to find even ground on the issue. shooting in 1804 in Columbia, PA. During One of the biggest laws agreed upon in this shooting a fugitive slave was shot as he regards to slavery in the United States was attempted to escape. It was here, that many the “Fugitive Slave Act of 1850.” This act mark the beginning of outraged free people effectively required any slave caught (both white and black) coming together to escaping to the North be returned to their help hide these escaped slaves.24 owner. This meant that whether or not a Philadelphia became an important person supported the slave trade, they were stop on the Underground Railroad due to its required by law to bring slave back to their proximately to southern slave states. While owners. Failure to comply with this law early on, following the initiation of the law, could have resulted in penalties, like fines. the Underground Railroad remained quiet in From this point, the effectiveness of the the public realm, however, as tensions began slave conversation in the city of Philadelphia to boil over and the Civil War was on the began to disappear.22 While legal action horizon, citizens began to congregate to slowed for quite some time, the relevance of amend and allow the non-compliance of this slave societies like the Philadelphia Anti- law. In one of these meetings, much was Slavery Society and the Pennsylvania resolved, most importantly, the law was Abolition Society were only just beginning. denounced in Philadelphia and primarily Likewise, the illegal maneuvers by local ignored.25 While this successful change in people to break laws like the Fugitive Slave the law, was important, many slaves saw Act quickly became more popular and successful escape to the north prior to it spread out not only in Philadelphia, but the being recognized by the city of Philadelphia. entire northern region of the United States. In fact, prior to 1860, almost 1,940 runaway The Fugitive Slave Act was opposed slaves entered Philadelphia. Despite many of throughout the northern states, as many felt these slaves staying in Philadelphia, many that it did not match with the principles others continued north on a trek that written about in the Declaration of ultimately brought them to Canada, where Independence. They questioned the ideals of they would be safest.26 the United States, especially the idea “that Some escaped slaves did not hope to all men were created equal; that they were end their venture in Canada, but were endowed by their Creator with certain content to stay around the Philadelphia area inalienable rights; that among these are life, and work. One such man, with the 5

pseudonym Henry Franklin was uninterested families and loved ones.29 While it is unclear in going to Canada and instead worked exactly how successful he was in doing this, carting coal between locations. In doing so, his efforts and successes in simply housing he would often help move slaves on their fugitive slaves shows the importance of quest to freedom. He would do this by abolitionists living in Philadelphia during covering them with straw and carting them this time. along with the coal from stop to stop. Henry Many place the relevance of anti- Franklin worked for many years and moved slavery rhetoric in Philadelphia from not between jobs in not only an attempt to live a only its proximity to slave states, but also its comfortable free life, but to help fugitive successes in establishing the first pro-Black slaves escape in any way he could.27 organizations like anti-slavery societies and One abolitionist who opened his black churches. The African-American doors to escaped slaves was Robert Purvis. population grew dramatically between 1830 Purvis was originally from , and 1860 not only because of the but moved to Philadelphia in 1820. Underground Railroad, but because of the Following the move Purvis attended the abolitionist societies formed in Philadelphia. Clarkson School, which was sponsored by By 1860 Philadelphia alone housed between the PAS. This is where Purvis grew to 30 and 40 percent of Pennsylvania’s support the abolitionist movement and one African-American population. While this of the biggest reasons that he devoted his made up only a measly four percent of the life to the abolition of slavery and freeing state’s population, this was a bigger free escaped slaves through the Underground black population than any city in the United Railroad. Purvis lived at the cross of Ninth States at this time.30 This population became and Lombard streets in Philadelphia where not only a major player in the ongoing quest his house had a secret door to hide runaway to bring slaves to freedom, but was slaves. In 1837, Purvis developed a program important because it even began an early for the purpose of assisting “colored persons Civil Rights movement. Philadelphia’s role in distress.” 28 While this program sent over at this time predominantly was focused on 40 fugitives further north and worked on the freedom of slaves, but this did not over three cases each week, the group prevent free blacks from beginning to start a collapsed in 1842 following an anti- movement for equal rights. In fact, abolition riot. This society was later picked Philadelphia housed the American Society up by , who worked at of Free Persons of Coulour for four days in rebuilding the program to assist about 100 September of 1830. Here, African- fugitives per year during the 1850s. Still was Americans met to discuss ways in which a former slave who hoped to help others they could “devise and pursue all legal escape to freedom. Still took the goal of means for the speedy elevation of ourselves Purvis’s society a little further as he worked and brethren to the scale and standing of with the slaves that he housed to find their men.”31 Many of these early Civil Rights 6

movements were overshadowed by the regain their “property.” It is for this reason, slavery issue. Societies like the ones that many of the slaves who did not stay in previously discussed were able to form and the Bucks County area to work continued grow exponentially because of the further north to Quakertown or the truly free Underground Railroad. As more slaves land of Canada. Another reason for the began to flee to Philadelphia, the city was limited success of slave catchers in Bucks able to grow both culturally and structurally. County, was that the county was small The Underground Railroad helped bring enough to keep the secrets of where slaves fugitive slaves to the city which continued to were kept. Information rarely made its way grow anti-slavery rhetoric in Philadelphia into the wrong hands. When asked by slave and further expanded the call to end slavery catchers for information on the whereabouts on a national scale. Philadelphia’s ability to of fugitive slaves, Bucks County residents grow in this way, was a massive success for often kept quiet and acted like there never the anti-slavery movement. The rhetoric and were and never would be fugitive slaves the ideas being spread from the city of hidden in the county. Simply put, the Philadelphia further spread the message that strategy in this area was simply to deny the slavery needed to be abolished and led the Underground Railroad’s existence. 33 country closer to the Civil War. In many aspects, Chester and Philadelphia certainly played a huge Lancaster Counties proved to be the best role in the emancipation of slaves, but the examples of thriving stops on the surrounding suburbs often proved to be a Underground Railroad. The close proximity better place to hide fugitive slaves. Due to of these counties to the events taking place their smaller population and smaller impact in Philadelphia, made them excellent stops on the rest of the country, suburbs became on the Underground Railroad because they an important place for escaped slaves to stop were more protected and less searched. on their journey to freedom. One of the most These counties were primarily Quaker, notable Philadelphia suburbs to house slaves making it important because at the time, in the 1800s was Bucks County. While Quakers were one of the biggest advocates Bucks County was not among the most against slavery. Northern areas of these popular suburbs for fugitive slaves to run, it counties were far enough from the borders quickly became one of the most that they could house slaves until they could successful.32 Its small population and lack of be transported further North. Unlike Bucks standing out as an Underground Railroad County, Chester and Lancaster Counties “premier stop” made it valuable for high often proved to be primarily temporary profile escapes and slaves wishing to find destinations for fugitive slaves as slaves work. quickly turned over to the north and more Slave catchers rarely came to Bucks slaves would enter. In terms of the routes County in search of their slaves, but if they used in these areas, they ultimately split into did, they would knock on doors in hoping to three separate northern routes. Fugitive 7

slaves would be strategically sent at As the city and the country further different times on these routes to avoid approached secession and the Civil War, the traveling in large numbers. Slave catchers city became more split. Despite its large often followed their suspects through African-American population, anti- Columbia, PA (at the time located in abolitionist sentiment began to increase. Chester), and because of the strategic This was mainly the result of the fear that methods put into play in this area were came with civil war being on the horizon. In seldom able to capture their slaves.34 This fact, a certain sect of the Democratic Party was one of the factors that led to further was advocating for the state of Pennsylvania tension between the slave-owning South and to secede if and when the slave states did. the free North. The North’s failure to Despite some resistance prior to the fall of comply with the Fugitive Slave Act in Fort Sumter, the majority of Philadelphians addition to Philadelphia and its surrounding got on board with the United States’ counties’ ability to allow fugitives to seek government.37 By supporting the U.S. refuge in this area, were incredibly valuable government, Philadelphia showed that it was as the United States geared up for the Civil ready to fight. While this would appear to War.35 perhaps have been an obvious endorsement In the late 1850s, as the Union was by the people of Philadelphia because of its falling apart and the prospect of Civil War long history of anti-slavery rhetoric, it took was becoming a reality, Philadelphia until the fall of Fort Sumter for continued to play its part in the broken Philadelphians to officially support the U.S. country. Philadelphia began to see struggles government in the coming war. politically as they weighed whether they The oncoming war in the United preferred Republicans (who they felt would States at this time, brought fear to many tear the Union apart) or Democrats (who people and rightfully so. The coming they felt would continue the practice of slaughter of United States citizens at the slavery). Until this time surprisingly, hands of their own brethren is one that Philadelphia political figures did not speak should have instilled fear in anybody. The out for or against the practice of slavery. United States at this time was very split and This was mainly because people were so very different, and Philadelphia played a split on the issue and it was such a spirited major part in this division and much later its issue for different people. Much of what ultimate reunification. Philadelphia happened in terms of political issues were represented one of the biggest cities in the handled at the federal level. More often than country at this time, and its involvement in not Philadelphia’s leading political figures such a movement played an extensive part in would not comment or act on things like the what was about to come. Pennsylvania increased use of the Underground Railroad began a movement by enacting a law in their city. Rather, they would often turn a gradually abolishing slavery, and blind eye to the issue. 36 8

Philadelphia acted on and expanded this It later continued as more African- law. Americans entered the city and worked to Antislavery and abolitionist societies grow these practices. No one person created developed in the city of Philadelphia to this movement, but it was one of big bring awareness and help fight the horrors of numbers and passionate Philadelphians. slavery in the United States. Such societies In the end, Philadelphia played a played a major part in growing the major role in the end of slavery in the abolitionist movement throughout the United States. Without the city’s citizens United States, it is through these societies push toward emancipating slaves in the that a movement was built and support was United States, the oncoming Civil War grown. Through these societies abolitionists could have been pushed back many years. were created. One of the most famous names By growing a community that pushed for the at this time was Benjamin Franklin, whose end of slavery, Philadelphia was able to help open stance as an abolitionist began late in put an end to this horrible practice. The life, but who spent a lot of his life working commitment of antislavery societies, behind the scenes toward a movement. abolitionists, and Underground Railroad Later, Philadelphia and its surrounding supporters this movement could have taken counties became major hubs in the a lot longer to accomplish. Philadelphia was Underground Railroad. Through this system, able to become the heart of the antislavery slaves were able to come through movement as its location gave it the prime Philadelphia and gain their freedom. This opportunity to do so. This movement could did not come without controversy, but have taken much longer without the part Philadelphians were ready to break the law Philadelphia played. Its role should not be to do what they felt was right for their forgotten but should be remembered as a fellow man. As the Civil War became bigger piece of history and the emancipation imminent, Philadelphia, despite seeing a of all slaves within the United States’ slight schism, held its ground and supported border. the United States’ government in their upcoming challenges. The part played by Philadelphia from these points cannot be understated. All of these events took place within the city and some of its surrounding counties. The large Quaker population in Pennsylvania played a large part in this. It is through this population, that many slaves were freed, and it is through their ideology of peace and harmony that much of the antislavery sentiment in Philadelphia grew. 9

Notes: 13 The Constitution of the American Anti- 1 "State of Pennsylvania an Act for the Slavery Society (New York, NY: American Gradual Abolition of Slavery," The New Anti-Slavery Society, 1838). Jersey Gazette (Trenton, NJ), May 17, 14 David Waldsteicher, Runaway America: 1780, accessed October 20, 2016, Benjamin Franklin, Slavery, and the http://vv4kg5gr5v.search.serialssolutions.co American Revolution (New York, NY: Hill m/? and Wang, 2004), 229. 2 Richard Newman and James Mueller, 15 Memorandum by Benjamin Franklin, "An eds., Antislavery and Abolition in address to the public, from the Pennsylvania Philadelphia (Baton Rouge, LA: Louisiana Society for promoting the abolition of State University Press, 2011), 29-31. slavery, and the relief of free negroes, 3 Cato, "Having Tasted the Sweets unlawfully held in bondage," November 9, of Freedom," Freeman's Journal, September 1789, accessed October 6, 2016, 21, 1781. https://www.loc.gov/resource/rbpe.1470100 4 Cato, "Having Tasted the Sweets 0/. of Freedom," Freeman's Journal, September 16 Newman and Mueller, Antislavery and 21, 1781. Abolition, 56. 5 Frederick Douglass, Narrative of the Life 17 David Waldsteicher, Runaway of Frederick Douglass, ed. David W. Blight America,198-200. (Boston, MA: Bedford/St. Martin, 2003), 75. 18 Newman and Mueller, Antislavery and 6 Newman and Mueller, Antislavery and Abolition, 56. Abolition, 165-166. 19 David Waldsteicher, Runaway 7 Ibid, 177-178. America,198-200. 8 Philadelphia Anti-Slavery 20 Newman and Mueller, Antislavery and Society, Constitution of the Philadelphia Abolition, 121. Anti-Slavery Society: Instituted fourth month 21 Ibid 121. 30th, 1834 (Philadelphia, PA: T. Town, 22 Lawrence Goldstone, Dark Bargain: 1834), 2-4, accessed November 1, 2016, Slavery, Profits, and the Struggle for the http://vv4kg5gr5v.search.serialssolutions.co Constitution (New York, NY: Walker & m/ Company, 2005), 175. 9 Philadelphia Anti-Slavery 23 Robert Clemens Smedley, M.D., History Society, Constitution of the Philadelphia, 8. of the Underground Railroad in Chester and 10 Philadelphia Anti-Slavery the Neighboring Counties of Society, Constitution of the Pennsylvania (New York, NY: Negro Philadelphia, 12. Universities Press, 1968), 25. 11 Richard Newman, "Pennsylvania 24 Ibid 26 Abolition Society (PAS)," in Abolition and 25 "Fugitive Slave Law in Philadelphia," The Antislavery, ed. Peter Hinks and John Sun (New York, NY), 1850, accessed McKivigan (Santa Barbara, CA: ABC- November 1, 2016, CLIO, 2015), 248-250 http://search.proquest.com/docview/533291 12 Newman, "Pennsylvania Abolition," 270?accountid=14270. in Abolition and Antislavery, 249. 26 Nilgun Anadolu Okur, "Underground Railroad in Philadelphia, 1830-

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1860," Journal of Black Studies 25, no. 5 (May 1995): 537, http://www.jstor.org/stable/2784630. 27 Edward H. Magill, When Men Were Sold: The underground railroad in Bucks County, Pa. : an address delivered before the Bucks County Historical Society (n.p., 1898), 11, accessed November 1, 2016, https://catalog.hathitrust.org/Record/100554 543. 28 Okur, "Underground Railroad," 548. 29 Okur, "Underground Railroad," 548. 30 Ibid 554. 31 Richard Allen, "Address to the Free People of Coulour of These United States," speech, 1830, in Minutes of the Proceedings of the National Negro Conventions,1830- 1864, ed. Howard Holman Bell (New York, NY: Arno, 1969). 32 Edward H. Magill, When Men Were Sold: The underground railroad in Bucks County, Pa. : an address delivered before the Bucks County Historical Society (n.p., 1898), 5, accessed November 1, 2016, https://catalog.hathitrust.org/Record/100554 543. 33 Magill, When Men Were, 10. 34 Ibid 5-6. 35 William Dusinberre, Civil War Issues Philadelphia 1856-1865 (Philadelphia, PA: University of Pennsylvania Press, 1965), 29. 36 Ibid 36-38. 37 Ibid 96.

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