Charlotte E. Ray

1850-1911

Attorney, teacher

Charlotte E. Ray's courage, ability, and perseverance enabled her to break race and gender barriers to become the first African-American woman to graduate from an American law school, the first African-American women lawyer in the District of Columbia, and the third woman to be admitted to the U.S. bar. However, even those with the daring and the drive to break society's barriers may achieve success only to find themselves confronted with more obstacles.

From the accounts of those who knew, worked, and studied with her, Ray possessed the legal knowledge and skill that are the hallmarks of successful lawyers. Though Ray is known to have earned the respect of many of her colleagues and to have argued cases capably, she was not able to build a career as a lawyer. She could not surmount the widespread societal prejudice against her and was forced to return to teaching in order to earn a living. Nevertheless Ray's groundbreaking achievements paved the way for other women and people of color to enter the law and other professions that had once been reserved for white men only.

Charlotte E. Ray was born in New York City on January 12, 1850. Her parents, Charles Bennett Ray and Charlotte Augusta Burroughs Ray, had seven children, though two died as teenagers. The Ray household placed a high value on education and work for social justice. Charles Bennett Ray, a man of mixed African, Native American, and European heritage, was a minister at New York's Bethesda Congregational Church, and editor of the Colored American, an abolitionist newspaper. Charlotte Augusta Burroughs, Charles' second second wife, was also an anti-slavery activist who worked with her husband to help escaped slaves travel north to freedom on the underground railroad. The Rays believed strongly that African-American children needed education in order to improve their lives, and they worked hard to ensure that all of their children graduated from college, a most unusual achievement for a black family in the nineteenth century.

For her education, Ray had to move Washington, D.C., in the mid 1860s to attend the Institution for the Education of Colored Youth, one of the few schools where African Americans could obtain an academic education. The Institute had been founded in 1851 by a white educator named Myrtilla Miner, with the help of abolitionists Henry Ward Beecher and his cousin Harriet Beecher Stowe. Miner had taught school in Mississippi until she was refused permission to admit black children into her class. Moving to the nation's capitol, she opened the Normal School for Colored Girls, which in 1865 became the Institution for the Education of Colored Youth.

Upon completing her studies in 1869, Ray began to teach classes at Howard University's Normal and Preparatory Department, which trained students to become elementary school teachers and prepared them for classes in the Collegiate department. Howard had been founded by a group of social reformers in 1866 to provide quality education for the hundreds of new black citizens who had been freed from slavery and their descendents. From the moment of its founding, Howard University had a firm policy of nondiscrimination, admitting both women and men of all races. The first students to enter the new college in 1867 were four white women, and the first graduates from its Normal and Preparatory Department were all women. In the forefront of women's education in the 1800s, Howard graduated a woman doctor in 1872, a woman pharmacist in 1887, and a woman dentist in 1896.

However, even in this atmosphere of relative tolerance, another African-American student, Mary Ann Shadd Carey, who entered Howard Law School during the early 1870s, was not permitted to graduate. Carey believed that the Howard administration discriminated against her because she was a woman. When Ray applied to enter Howard's newly established School of Law in 1872, she filed her application under the name "C.E. Ray." Some historians believe that she did this to conceal the fact that she was a woman, in case that might influence school administrators to refuse her application. However, others point out that many post-slavery blacks used only their initials because they did not want whites or others in authority to be tempted to call them by their first names, as they had during the era of slavery. There is no way to be sure why Ray to used her initials on her application, but she was accepted into Howard University's School of Law.

For the next three years, Ray pursued a demanding course of study, impressing her fellow students and teachers alike with her quick grasp of legal complexities. James C. Napier, a respected lawyer and one of Ray's Howard classmates, called her, "an apt scholar," and General Oliver O. Howard, one of the university's founders, described her as, "a 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," according to Tonya Osborne of the Stanford University Women's Legal History Biography Project. 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. When she graduated in 1872, Ray became the first African-American woman to graduate from a law school in the United States.

Upon finishing her law school program, Ray became the first black woman lawyer to enter the District of Columbia bar, which, not long before, had removed the requirement that applicants must be men. She was only the third woman in the entire nation to be admitted to the bar. She set up a business law practice, advertising in a local newspaper published by famous abolitionist Frederick Douglas, New National Era and Citizen.. Soon she earned a reputation as a skilled and knowledgeable corporation lawyer. In addition to her commercial practice, she filed at least one suit in family law, a divorce petition on behalf of an abused wife.

However, though she was generally thought to be an excellent commercial and courtroom lawyer, Ray found herself, as a woman and an African American, unable to attract enough clients to support herself. White clients seldom chose a black attorney, and African Americans who could afford a lawyer were reluctant to hire a woman. A nationwide economic depression, ushered in by the Panic of 1873, also made it a difficult time to start a new business. After trying for several years to establish a legal practice, Ray was forced to give up. She returned to New York, where she joined her two surviving sisters working as a teacher in the Brooklyn public school system.

Little is known of Ray's later life. She continued to work for social change, attending the national convention the National Women's Suffrage Association and joining the National Association of Colored Women. During the late 1880s, she married a man with the last name of Fraim, and in 1897 she moved to the town of Woodside, New York, in the borough of Queens. She died there on January 4, 1911, from a severe case of bronchitis.

At a Glance …

Born Charlotte E. Ray on January 13, 1850, in New York, NY; died on January 4, 1911, in Woodside, NY; married man with last name of Fraim, 1886(?). Education: Institute for the Education of Colored Youth, certificate, 1869; Howard University School of Law, LLB, 1872.

Career:

Howard University Normal and Preparatory Department, teacher, 1869-1872; private practice lawyer, 1872-187?; Brooklyn Public Schools, teacher, 187?-1897.

Memberships:

Phi Beta Kappa Society; National Association of Colored Women.

Though Ray was unable to continue her career as an attorney, her life still represents an enormous achievement. As the first African-American 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. The Greater Washington Area Chapter of the Women Lawyers Division of the National Bar Association (GWAC), recognized Ray's contribution to the legal profession in 1989, when it established an annual "Charlotte Ray Award," to honor outstanding African-American women lawyers in the Washington area.

Sources

Books

"Charlotte Ray," in Black Women in America: An Historical Encyclopedia, Carlson Publishing, 1993, pp. 965-6.

Periodicals

Howard Law Journal, Winter 2000, p. 121-139.

Jet, April 24, 2006, p. 20.

Journal of Blacks in Higher Education. March 31, 1997, p. 134.

Journal of Women's History. Summer 2002, p. 207.

Louisiana Bar Journal, February 1993, p. 463.

Minnesota Lawyer, December 18, 2006.

On-line

"African American Heritage Trail," Cultural Tourism DC,www.culturaltourismdc.org/infourl3948/infourl.htm (January 20, 2007).

"Attorney Charlotte Ray Was Forced to Teach," African American Registry,www.aaregistry.com/african_american_history/24/Attorney_Charlotte_Ray_was_forced_to_teach (January 20, 2007).

"Charlotte E. Ray," Biography Resource Center,http://galenet.galegroup.com/servlet/BioRC (January 20, 2007).

"Celebrating Women's History Month: Government and Law, Charlotte Ray," Women of Distinction 2006, New York State Senate,www.senate.state.ny.us/sws/wod/gl_ray.html (January 20, 2007).

"Charlotte E. Ray: A Black Woman Lawyer," Women's Legal History Biography Project, Stanford University,http://womenslegalhistory.stanford.edu/papers/CharlotteRay.pdf (January 20, 2007).

                                                             —Tina Gianoulis