In the 19th century, women of color were barred from the legal profession. They were forbidden from enrolling in law schools and from obtaining licenses to practice law across the United States. The legal profession was largely controlled by, and reserved for, wealthy White men. But one trailblazers chose to fight and overcome these structural barriers - Charlotte E. Ray. Charlotte Eliza Ray became the first Black female admitted to practice law in the United States of America. She was also the first woman admitted to practice before the Supreme Court of the District of Columbia.
Born on January 13, 1850, in New York, she was one of six children. Her father worked as a minister, journalist, and was a prominent abolitionist. His commitment to civil rights and justice undeniably shaped her aspirations and dedication to societal equality and justice. She was raised in a progressive family that instilled the virtues of courage, hard work, and justice. Education was the key to her dream of becoming a lawyer. She attended a school in Washington, D.C. called the Institution for the Education of Colored Youth, one of a few places in the U.S. where a Black woman could receive a solid education. This school played a crucial role in providing Ray with the foundational knowledge and skills that would later support her historic entrance into the legal profession.
Following graduation in 1869, Ray went on to attend Howard University. Ray became a teacher in the Normal and Preparatory Department, which was the University's Prep School. Ray had other dreams. What she really wanted was to practice law. Since Howard didn’t discriminate on any basis, she was able to take law classes, even though she knew that women weren’t allowed on the bar of the District of Columbia. While teaching at Howard, she registered in the Law Department, under the name “C.E. Ray” to disguise her gender, which would have hindered her chances for acceptance. University officials reluctantly accepted her application and she attended classes while continuing to teach in the Preparatory and Normal Department.
During her time at Howard, Ray excelled academically, impressing both her peers and professors with her her quick grasp of legal complexities. Her time at Howard was challenging. Not only because of their rigorous curriculum, but also because she had to navigate a predominantly male environment. This was not always welcoming to a woman, let alone an African American woman. Ray specialized in business law and became highly regarded as an expert in the legal issues of corporations. Her academic skill was recognized by her membership in the prestigious academic society, Phi Beta Kappa. Charlotte Ray graduated on February 27, 1872, completing a three-year program, as the first woman to graduate from the Howard University School of Law.
The same year that she graduated, Ray passed the District of Columbia (D.C.) bar exam. She was only the third woman in the entire nation to be admitted to the bar. Her admission that year to the District of Columbia bar made her the first woman admitted to practice in the District of Columbia and the first Black woman certified as a lawyer in the United States. She also was admitted to practice in the Supreme Court of the District of Columbia which had recently removed the word “male” from its requirements. Her admission to the D.C. Bar was not merely a personal victory but a monumental stride for African Americans and women in law. Her admission was used as a precedent by women in other states who sought admission to the bar, opening the door for countless others.
However, her achievements did not shield her from the racism and sexism pervasive in society and the legal profession. Her appointment was noted in the Woman's Journal and gained her inclusion as one of the Women of the Century. Ray began her independent practice of commercial law in 1872, advertising in newspapers such as the New National Era and Citizen, owned by Frederick Douglass. She opened a law office in Washington, D.C. Soon she earned a reputation as a skilled and knowledgeable corporation lawyer. Despite her qualifications and competence, she struggled to attract clients. Some sources suggest that she hoped to specialize in real estate law, which would involve fewer appearances in court.
Little is known about Ray’s legal practice. But there was one huge radiant victory for Charlotte Ray. She did represent Martha Gadley in 1875. Martha Gadley’s marriage was a nightmare. When her husband drank, he turned increasingly violent. Gadley was seeking a divorce from her abusive husband. This was a gutsy move for an illiterate Black woman, she was about as powerless as a person could be in the United States legal system. Martha Gadley’s earlier efforts to separate from her violent husband had been dismissed by the lower courts. She filed on the grounds of “habitual drunkenness” and “cruelty of treatment, endangering the life or health of the party complaining.” Ray’s petition graphically describes a terrifying evening when her client’s husband attempted to murder her by using an ax to chop up the floor boards in a second story bedroom so she would fall through the floor and break her neck.
At the time, Ray was one of just a handful of women who practiced law in the United States. Charlotte Ray argued the case in front of the District of Columbia Supreme Court. Martha had been married only three years. Her husband was vicious, even though, as Charlotte stated on the court document, she had “striven by all means in her power to be to said defendant a dutiful, true and affectionate wife. ... [S]aid petitioner prays that your honorable court may pass a decree divorcing the said petitioner from the bond of matrimony with the said defendant, and granting her such other and further relief as the nature of the case may require and the court have power to grant.” But it was 1875, and the law cared little about domestic violence, especially when it involved Black women.
Charlotte’s filing clearly describes the state of Martha’s marriage, cogently and poignantly outlining her husband’s violence, alcoholism, and emotional cruelty. “[W]hile said petitioner was out said defendant returned and finding said petitioner absent, nailed up the two doors of the house in which said defendant and said petitioner were then residing, put a padlock on one door, bolted the other, and threw said petitioner's clothing out of the window.” The petition was a success and Charlotte won a decisive victory for her client. Her success lends credence to Ray’s skill in advocacy. This case marked a monumental victory in American history. This was the first time a woman practiced, argued, and successfully secured a favorable ruling in the District of Columbia’s Supreme Court.
Charlotte Ray was said to be eloquent, authoritative, and "one of the best lawyers on corporations in the country." Yet despite her Howard connections and advertisements, she was unable to maintain a steady client flow, sufficient to support herself. Regardless of her legal knowledge and corporate law expertise, she couldn't maintain a steady client flow due to gender and racial discrimination. Not enough people (Black and White) were willing to trust a Black woman with their cases. Faced with the wall of prejudice that hampered her law career, Charlotte E. Ray returned to New York, where she joined her two surviving sisters working as a teacher in the Brooklyn public school system. She was also an active advocate for social justice. She attended the National Woman Suffrage Association’s (NWSA) annual convention in New York City in 1876 and she joined the National Association of Colored Women (NACW) in 1895.
Ray’s pioneering journey blazed a trail for women and African Americans in the legal profession. In 1897, a White attorney in Wisconsin, Kate Kane Rossi, recalled, “Miss Ray … although a lawyer of decided ability, on account of prejudice was not able to obtain sufficient legal business and had to give up … active practice.” Though Ray had only a short career as an attorney, her life still represents an enormous triumph. As the first Black woman lawyer, and one of the first women lawyers in the nation, Ray opened a door for all the women of color who would come after her. Arabella Mansfield was the first woman admitted to a state bar (Iowa, 1869), and Belva Lockwood was the first woman to argue before the U.S. Supreme Court (1879). Charlotte E. Ray demonstrated that Black women could excel in the field of law, and her achievements helped to inspire others. In 1897, she moved to Woodside. She passed away on January 4, 1911.