Ohio became the Territory of Ohio, and that part of the Northwest
Territory lying west and north of Ohio was erected into the Territory
of Indiana; by like Acts, January 11, 1805, the Territory of Michigan
was formed, and February 3, 1809, all that part lying west of
Indiana and Lake Michigan became the Territory of Illinois. Prior,
however, to the last Act, the Legislature of Indiana Territory
(September 17, 1807) passed an act "to encourage emigration," making
it lawful to bring negroes and mulattoes into the Territory, "owing
service or labor as slaves."

The act provided that these people and their children should be
held for a term of years, and if they refused to serve as slaves
they might be removed, "within sixty days thereafter," to any place
where they could be lawfully held. This statute was substantially
re-enacted by the Legislature of the Territory of Illinois in 1812.

The first Constitution (1818) of Illinois did not prohibit slavery.
The first section of Article VI, declared that: "Neither slavery
nor involuntary servitude _shall hereafter be introduced_ into this
State, otherwise than for the punishment of crimes." Slavery
existed in Illinois after it became a State. The French and Canadian
inhabitants or their descendants continued to hold colored and
Indian slaves, and others were held under the Territorial Acts of
1807 and 1812. The old slaves and their descendants, held at the
time of the cession by Virginia to the United States, were sold
from hand to hand in the State, and transported to and sold in
other slave States.(23)

The Constitution of Indiana (1816) prohibited slavery, but slaves
were held therein until its Supreme Court in 1820, in a _habeas
corpus_ case, held the Constitution freed all persons hitherto held
in bondage, including the old French slaves, regardless of the
Ordinance of 1787, of the deed of cession of Virginia, or of any
treaty stipulations.(24)

After the separation (1805) of Michigan from Indiana, the former's
Territorial Chief Justice held slavery existed in Michigan by virtue
of the Jay treaty (1796) with Great Britain (not otherwise)
notwithstanding the Ordinance of 1787,(25) but Michigan's Constitution
(1837) put an end to slavery in the State, as did also the Constitution
(1802) of Ohio, likewise the Constitution (1848) of Wisconsin.
Slaves shown by census reports in Ohio, Indiana, Michigan, and
Wisconsin after they became States, were there by tolerance