1] One district attorney writes: "It appears to be
almost impossible to enforce the laws of the United States against
offenders after the negroes have been landed in the state."[142] Again,
it is asserted that "when vessels engaged in the slave trade have been
detained by the American cruizers, and sent into the slave-holding
states, there appears at once a difficulty in securing the freedom to
these captives which the laws of the United States have decreed for
them."[143] In some cases, one man would smuggle in the Africans and
hide them in the woods; then his partner would "rob" him, and so all
trace be lost.[144] Perhaps 350 Africans were officially reported as
brought in contrary to law from 1818 to 1820: the absurdity of this
figure is apparent.[145] A circular letter to the marshals, in 1821,
brought reports of only a few well-known cases, like that of the
"General Ramirez;" the marshal of Louisiana had "no information."[146]

There appears to be little positive evidence of a large illicit
importation into the country for a decade after 1825. It is hardly
possible, however, considering the activity in the trade, that slaves
were not largely imported. Indeed, when we note how the laws were
continually broken in other respects, absence of evidence of petty
smuggling becomes presumptive evidence that collusive or tacit
understanding of officers and citizens allowed the trade to some
extent.[147] Finally, it must be noted that during all this time
scarcely a man suffered for participating in the trade, beyond the loss
of the Africans and, more rarely, of his ship. Red-handed slavers,
caught in the act and convicted, were too often, like La Coste of South
Carolina, the subjects of executive clemency.[148] In certain cases
there were those who even had the effrontery to ask Congress to cancel
their own laws. For instance, in 1819 a Venezuelan privateer, secretly
fitted out and manned by Americans in Baltimore, succeeded in capturing
several American, Portuguese, and Spanish slavers, and appropriating the
slaves; being finally wrecked herself, she transferred her crew and
slaves to one of her prizes, the "Antelope," which was eventually
captured by a United States cruiser and the 280 Africans sent to
Georgia. After much litigation, the United States Supreme Court ordered
those captured from Spaniards to be surrendered, and the others to be
returned to Africa. By some mysterious process, only 139 Africans now
remained, 10