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Charlotte Ray

Kathryn S Gardiner | Published on 2/11/2023

Forgotten Foremothers

Profiles of lesser-known heroines in the fight for women’s rights

On Jan. 13, 1850, New York City couple Charles Bennett Ray and Charlotte Augusta Burroughs Ray welcomed a daughter, Charlotte E. Ray. Young Charlotte was one of seven children, though only four would live to adulthood. She was the youngest of the three surviving daughters. While no detailed record remains of Charlotte’s childhood, the public works of her parents—all decades before the Civil War and the Emancipation Proclamation—can give us the tenor of her youth.


The Rays had a politically active and industrious marriage. Father Charles pastored at Bethesda Congregational Church after a long career with abolitionist newspapers. He’d been the first African American student at Wesleyan University in Connecticut until white protests and harassment drove him out in 1833. He and his first wife, who died after just two years of marriage in 1836, had been active “conductors” of the Underground Railroad, helping enslaved people out of bondage.

Mother Charlotte was a pastor herself, as well as a dedicated suffragist and abolitionist. She served as editor of The Colored American, an anti-slavery newspaper, and worked with the American Equal Rights Association. Dani Williams-Jones writes for Alexander Street, “As a Black woman, [Charlotte B.] Ray knew first hand that Black women suffered all the legal disabilities of white women, yet theirs was a more capricious conundrum which was compounded by their having survived the institution of chattel slavery.”


The Rays insisted all their children attend college, which was exceptionally rare at the time and the opportunities sparse. “Before the Civil War, the vast majority of the Black population, including nearly one hundred percent of the Blacks living in the south, did not enroll or were prohibited from enrolling in college,” states Brian Haynes in Black Undergraduates in Higher Education: an Historical Perspective. “Given the fact that the majority of Blacks living in America at this time in history lived south of the Mason-Dixon Line, there was limited access to higher education thereby creating a dearth in the numbers of Blacks graduating from college.” Prior studies “found that before 1860, the number of Blacks graduating from an American college or university stood at only twenty-eight.”

Public Domain

Charlotte joined this small population when she attended and graduated from Normal School for Colored Girls, which had been founded just a year after her birth. Now called the University of the District of Columbia, the school was one of the precious few in the United States that would accept Black women. After that, Charlotte began classes at Howard University during its very first years. Howard University was established in 1866 and educated nearly 150,000 formerly enslaved Black Americans by 1872.


As a Howard University graduate, Charlotte began teaching classes in the Normal and Preparatory Department, training other teachers, and she applied to the Howard University School of Law. According to an article by Lelia J. Robinson in The Green Bag, “A Useless but Entertaining Magazine for Lawyers,” published in 1890, “I have been told that her admission to the bar was secured by a clever ruse, her name being sent in with those of her classmates as C.E. Ray, and that she was thus admitted, although there was some commotion when it was discovered that that one of the applicants was a woman.” Still other sources insist the School of Law was open to women, so her application would not have been prohibited.

Charlotte's handwriting

Regardless of how her advanced schooling began, Charlotte became the first woman graduate of the Howard University School of Law on Feb. 27, 1872. Within days, she was admitted to the District of Columbia Bar. 


“In 1872 Charlotte E. Ray became the first Black woman lawyer in the United States and the first woman lawyer in the District of Columbia,” Karen Berger Morello reports in “Women’s Entry into the Legal Profession” published in a 1983 issue of American University Law Review. “The trustees at Howard Law School were stunned watching ‘this colored woman who read us a thesis on corporations, not copied from the books but from her brain, a clear incisive analysis of one of the most delicate legal questions.’”


Later in 1872, Charlotte founded her private practice. She advertised her legal services in the New National Era, the publication owned and initially edited by Frederick Douglass until his son, Lewis H. Douglass, took over around this same time. Unfortunately, Charlotte’s legal career was a short one. Like her father at Wesleyan before her, she represented the sort of progress that meets resistance from the status quo. As Erin Blakemore writes for History, “Being a black, female lawyer was so novel at the time that Ray faced prejudice and could not secure enough clients.”


But before her legal career ended, she had one, big case. 


Martha Gadley’s married life was a nightmare. “[O]ne night while said petitioner was in bed, said defendant took hold of the bedstead at the footboard, and broke it to pieces, so that said petitioner was compelled to lie on the floor,” Charlotte wrote in 1875 in her even, sinuous handwriting of her client Martha and the defendant, Martha’s abusive husband. “[S]aid defendant then went down stairs, got an ax and returning, ripped up the planks in the floor by where said petitioner was lying, for the purpose of causing said petitioner to fall into the room below, saying that he would break her neck.”


In a special feature in the Howard Law Journal titled “Charlotte E. Ray Pleads Before Court,” Professor of Law J. Clay Smith Jr., notes that, “Written accounts have suggested that Ms. Ray practiced corporate law. However, until now no writings by her have ever been discovered or published confirming that she actually practiced law in the courts. ... The purpose of this piece is to lay to rest any doubt that Ms. Ray practiced law. The pleading that follows, filed by Ray, is conclusive that Ray's admission to the bar, as suggested by some, was not clandestine.” This feature from the year 2000 contains a transcript of the Gadley v. Gadley pleading that Charlotte filed before the Supreme Court of the District of Columbia on June 3, 1875. 


Martha Gadley’s earlier efforts to separate from her violent husband had been dismissed by the lower courts. As an illiterate Black woman, she was about as powerless as a person could be in the United States legal system. As Erin Blakemore notes, “It was 1875, and the law cared little about domestic violence.” In her pursuit of an uncommon ruling, Martha sought the assistance of an uncommon lawyer. Charlotte and Martha took their appeal to the District of Columbia Supreme Court, fighting for Martha’s right to divorce. 


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.”


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 Martha was granted her sought-after divorce. The filing endures as “the first known writing, publication of a pleading and verified signature of Charlotte E. Ray ever discovered and reproduced.”


Charlotte’s thread in history becomes more obscure after this event. She closed her law practice in 1879 and returned to teaching. Ever her parents’ daughter, however, her activism never stopped. She worked with both the National Woman Suffrage Association and she joined the National Association of Colored Women. In the late 1880s, when Charlotte herself was in her late 30s, she married a man with the surname of Fraim. The couple moved to Woodside, Long Island, in 1897.


“I must also admit that I knew something about Charlotte E. Ray because of the years that I’ve been in this space,” Michele Coleman Mayes, a legal professional herself, said in a 2018 speech, later published in a 2020 issue of Perspectives. “As I found out more about her, a poem, ‘Harlem,’ kept running through my mind:

“What happens to a dream deferred?

“Does it dry up

like a raisin in the sun?

Or fester like a sore—

And then run?

Does it stink like rotten meat?

Or crust and sugar over—

like a syrupy sweet?

“Maybe it just sags

like a heavy load.

“Or does it explode?

—Langston Hughes”

On Jan. 4, 1911, Charlotte died of bronchitis at the age of 60. For all the dreams that may have been deferred in her life, her legacy is a powerful one. The Minority Corporate Counsel Association gifts the Charlotte E. Ray Award to “a woman lawyer for her exceptional achievements in the legal profession and extraordinary contribution to the advancement of women in the profession.”

Michele Coleman Mayes was the first recipient of this award, in 2018, when she spoke of Charlotte’s dreams. She ended her acceptance of the Charlotte E. Ray Award as follows: “What happens to a dream deferred? Dreams course through the veins of all those who follow. That’s what I choose to believe. I say thank you to MCCA (for the award). Thank you to Charlotte E. Ray for the dream. And I say to all of you: Have a dream. Have a dream and fight for it.”


Black Undergraduates in Higher Education: an Historical Perspective by Brian Haynes Charlotte E. Ray’s Brief But Historic Career as the First U.S. Black Woman Attorney

Wikipedia: Charlotte E. Ray, Charlotte B. RayNew National Era

HeinonlineWomen’s Entry into the Legal Profession by Karen Berger Morello; Charlotte Ray was the woman who proved the law of the land wrong by J. Clay Smith, Jr.; What Happens to a Dream Deferred? by Michele Coleman Mayes; Charlotte E. Ray Pleads Before the Court by J. Clay Smith, Jr. Who Was Charlotte E. Ray?

Colored Conventions: Charles Bennett Ray

Alexander Street: Biographical Sketch of Charlotte B. Ray

African American Registry: The Normal School for Colored Girls (Washington, D.C.)

Black America Web: Little Known Black History Fact: Howard University

The Green Bag: 1890 Article by Lelia J. Robinson

History of American Women: First African American Woman Lawyer

Minority Corporate Counsel Association: Charlotte E. Ray Award