*In his 1860 pamphlet The Constitution of the United States: Is It Pro-slavery or Anti-slavery?, Frederick Douglass argued, in parodic emulation of pro-slavery “strict constructionists,” that the so-called fugitive slave clause could not apply to slaves because the word “due” implied a contract and that slaves, by virtue of their non-personhood, could not make or be held to any contract. The clause, he wrote, “applies to indentured apprentices, and any other persons from whom service and labour may be due. The legal condition of the slave puts him beyond the operation of this provision. He is not described in it. He is a simple article of property. He does not owe and cannot owe service. He cannot even make a contract. It is impossible for him to do so. He can no more make such a contract than a horse or an ox can make one. This provision, then, only respects persons who owe service, and they only can owe service who can receive an equivalent and make a bargain. The slave cannot do that, and is therefore exempted from the operation of this fugitive provision. In all matters where laws are taught to be made the means of oppression, cruelty, and wickedness, I am for strict construction. I will concede nothing.” Frederick Douglass, The Constitution of the United States: Is It Pro-slavery or Anti-slavery? by Frederick Douglass; a Speech Delivered in Glasgow, March 26, 1860, in Reply to an Attack Made upon His Views by Mr. George Thompson (Halifax: T. and W. Birtwhistle, 1860), 12.