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43 Howard L.J. 121 (1999-2000)
Charlotte E. Ray Pleads before Court

handle is hein.journals/howlj43 and id is 131 raw text is: Special Feature

Charlotte E. Ray Pleads Before Court
J. CLAY SMITH, JR.*
The life of Charlotte E. Ray remains almost a mystery in relation
to the practice of law. Books and articles written about women law-
yers have casually mentioned that Ray practiced law in the District of
Columbia after being admitted to practice in 1872, shortly after she
became the first woman to graduate from Howard University School
of Law. She was one of the first women admitted to the bar in the
District of Columbia and the United States. She also was one of this
country's first women solo practitioners.'
Written accounts have suggested that Ms. Ray practiced corpo-
rate law.2 However, until now no writings by her have ever been dis-
covered or published confirming that she actually practiced law in the
courts.3 Articles and commentaries have suggested that because she
was a woman, Ray was mysteriously admitted to the District of Co-
lumbia bar by using her initials C.E. Ray to avoid being denied admis-
sion to the bar.4 While it is agreed that women of the nineteenth
century were locked in a cage5 because of their gender, it appears
that Ray, a black woman, may not have been totally fenced out. If she
was in a cage, she broke the lock and redefined societal attitudes to-
ward the worth, value and interests of women.6
* Professor of Law, Howard University School of Law.
1. See J. Clay Smith, Jr., Black Women Lawyers: 125 Years at the Bar; 100 Years in the
Legal Academy, 40 How. L.J. 365, 366-372 (1997) [hereinafter Black Women Lawyers].
2. Id. at 371; See also J. CLAY SMrrIH, JR., EMANCIPATION: THE MAKING OF THE BLACK
LAWYER, 1844-1944, at 141 n.137 (1993).
3. Id. at 372.
4. Id. at 370 n.27.
5. See Frontiero v. Richardson, 411 U.S. 677, 684 (1973)(using this metaphor).
6. See Richard L. Aynes, Bradwell v. Illinois: Chief Justice Chase's Dissent and the Sphere
of Women's Work, 59 LA. L. REV. 521, 539 (1999) (discussing Kate Chase, the daughter of
Justice Salmond P. Chase).
2000 Vol. 43 No. 2

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