Although little is known about Chloe Cooley, an enslaved woman in Upper Canada, her struggles against her “owner,” Sergeant Adam Vrooman, precipitated the Act to Limit Slavery in Upper Canada, 1793 — the first legislation in the British colonies to restrict the slave trade.

The Act recognized enslavement as a legal and socially accepted institution. It also prohibited the importation of new slaves into Upper Canada and reflected a growing abolitionist sentiment in British North America.

The Struggle of Chloe Cooley

Chloe Cooley was a Black woman enslaved by United Empire Loyalist Sergeant Adam Vrooman — a resident of Queenston, Upper Canada. On 14 March 1793, Vrooman violently bound Cooley in a boat and transported her across the Niagara River to be sold in New York State. Cooley resisted fiercely, causing Vrooman to require the assistance of two other men — his brother Isaac Vrooman and one of the five sons of Loyalist McGregory Van Every, a number of whom served with their father in the Butler’s Rangers.

Peter Martin, a Black Loyalist and fellow veteran of Butler’s Rangers, witnessed Cooley’s struggles and screams and, along with witness William Grisley, reported the incident to Lieutenant-Governor John Graves Simcoe and the Executive Council of Upper Canada. Grisley, a white resident of nearby Mississauga Point and employee of Sergeant Vrooman’s, was able to provide a detailed account of the events as he was on the boat that transported Cooley, but did not assist in restraining her.

However, this was not the first time Cooley fought against her bondage. She regularly protested her enslavement by behaving in “an unruly manner,” stealing property entrusted to her on Sergeant Vrooman’s behalf, refusing to work and engaging in truancy (leaving her master’s property without permission for short periods of time and then returning).

Chloe Cooley, Bereft of Rights

Some time before the incident, Vrooman had purchased Cooley from Benjamin Hardison of Bertie Township (now Fort Erie, Ontario), a farmer, miller and member of the Legislative Assembly. Vrooman took Cooley to his farm just north of Queenston. She likely worked as a domestic servant in both the Hardison and Vrooman households. Vrooman enslaved at least one other person, a Black man named Tom, at the time he owned Cooley. Tom was in Vrooman's possession in 1783, and Vrooman sold Tom to Adam Krysler in 1792, seven months before the Cooley incident.

At the time of the Chloe Cooley incident, whispers of abolition and freedom circulated in the Niagara area among slaveholders and enslaved Blacks alike. These rumours pushed Vrooman and other slaveholders to liquidate their slave assets rather than lose money on their investments should the reports prove true. William Grisley further testified that he saw another Black person bound in the same manner as Cooley and also made light the fact that other slaveholders planned to sell their slaves in the United States.

The Executive Council resolved to put an end to the violent removal of slaves and instructed Attorney General John White to prosecute Vrooman for disturbing the peace. Within the next few weeks, White filed charges against Vrooman in the Court of Quarter Sessions held at Newark (now Niagara-on-the-Lake, Ontario). On 18 April 1793, Vrooman responded to the charges in a petition in which he stated that he had:

[...] been informed that an information had been lodged against him to the Attorney General relative to his proceedings in his Sale of said Negroe Woman; your Petitioner had received no information concerning the freedom of Slaves in this Province, except a report which prevailed among themselves, and if he has transgressed against the Laws of his Country by disposing of Property (which from the legality of the purchase from Benjamin Hardison) he naturally supposed to be his own, it was done without knowledge of any Law being in force to the contrary.

This petition confirms that a charge (called “an information”) was filed against Vrooman as the Executive Council had recommended. Additionally, Vrooman identified from whom he purchased Cooley, which gives credence to the legality of the buying and selling of slaves in Upper Canada. Lastly, Vrooman’s petition reveals that he provided a defence of ignorance to his sale of Cooley, stating that he did not break the law. The charges against Vrooman were dropped. Cooley and other enslaved Black persons in the province were considered chattel and did not have any rights to defend in court.

Enslavement in Upper Canada

British abolitionists such as William Wilberforce, James Ramsay, Granville Sharp and Thomas Clarkson had argued against the Atlantic slave trade since the 1770s, and Simcoe had been influenced by the growing abolitionist movement prior to his arrival in Upper Canada in 1791. By then, abolitionists of African heritage were also playing a vital role in the struggle. Olaudah Equiano (also known as Gustavus Vassa), once enslaved in England, published his autobiography in 1789 and toured the United Kingdom to speak out against the inhumanity of enslavement. These abolitionist opinions spread to Upper Canada, where Simcoe and White led the call for abolition in the province.

However, the status of slaves was not recognized under English law. Unlike French civil law, which provided limited protection to the enslaved under the Code noir, British law treated Cooley and other slaves as property, which meant that she did not have any rights as a person and could be legally sold just like any other object. The decision in the 1772 case Somerset vs. Stewart, which had rendered enslavement illegal in England, did not apply to British colonies. Enslaved Black persons were bought and sold alongside household furniture and farm animals. They were also bequeathed to heirs in wills and given as gifts. The lieutenant-governor of Upper Canada could do little against the “property rights” of slave owners within the confines of the law.

Enslavement had expanded sharply in Upper Canada following the American Revolution and was legally and socially accepted. In fact, Britain extended legal protection to slavery in the colonies to encourage settlement. The 47th Article of Capitulation of 1760 allowed French inhabitants to keep their slave property under British rule (see Capitulation of Montréal 1760). The Imperial Act of 1790 encouraged settlers to bring their slaves into the colony duty-free. Loyalists subsequently brought approximately 2,000 slaves with them to Canada — between 500 and 700 to Upper Canada. The law enforced and maintained enslavement through contracts — transactions that involved buying, selling or hiring out enslaved persons were legally binding, as were the terms of wills in which slaves were bequeathed.

Simcoe used the Chloe Cooley incident as a means to introduce legislation to abolish slavery in Upper Canada. On 19 June 1793, Attorney General John White introduced an abolition bill to the House of Assembly, which he said received “much opposition but little argument” from government slaveholders. At least 12 members of the 25-person government owned slaves or were members of slave-owning families. After going through the legislative process, the government brokered a compromise and passed An Act to Prevent the further Introduction of Slaves and to limit the Term of Contracts for Servitude (also known as the Act to Limit Slavery in Upper Canada). Simcoe gave the bill Royal Assent on 9 July 1793 and expressed his hope that those who were enslaved “may henceforth look forward with certainty to the emancipation of their offspring.”

The Act Enacted

No enslaved persons in the province were freed outright as a result of the enacted legislation. Though the Act prohibited the importation of enslaved persons into Upper Canada, it did not prevent the sale of slaves within the province or across the border into the United States. Newspapers in the province continued to publish advertisements of slaves for sale and requests for slaves to purchase. One of the last recorded sales of a slave in Upper Canada took place in March 1824 when Eli Keeler of Colborne sold 15 year-old Tom to William Bell in Thurlow (now Belleville, Ontario). Many slave owners in Upper Canada continued to sell slaves in New York State until 1799, when a similar legislation was passed to gradually abolish slavery in that state.

The Act stated that enslaved persons who were in the province at the time of its enactment would remain the property of their masters or mistresses for life, unless manumitted (freed) by their owners. Children born to enslaved women after 1793 would be freed when they reached 25 years of age. Children born to this cohort were free at birth. Slaveholders were required by law to provide food and clothing to the young children they enslaved. In addition, the Act required that former slaveholders provide security for recently freed slaves by ensuring that they were held in trust by a local church or town warden so as not to become a public charge. This measure encouraged slaveholders to employ their former slaves as indentured servants. The maximum term for an indenture contract was nine years and could be renewed. Structured as it was, the Act set the course for the abolition of slavery after one generation.


Little is known about Chloe Cooley’s early life or where she went after March 1793. Still, her plight is a testament to the struggle of enslaved Black persons in Canada and the Atlantic World and the various ways in which they resisted their servitude. Long before enslaved African Americans fled towards freedom in Canada, many enslaved Africans in Upper Canada and other provinces in British North America escaped to the free states of the northern US (Michigan, Ohio, Pennsylvania, Indiana, Illinois, Wisconsin and the northeastern part of Minnesota) where slavery was outlawed or restricted in 1787. For instance James Ford, enslaved by a British officer near Fort Malden (now Amherstburg) escaped to Ohio. Henry Lewis found freedom across the border in Schenectady, New York, from his master William Jarvis, the Sheriff of York (Toronto). An enslaved Black male held by Colonel Alexander McKee crossed the Detroit River in 1795 to escape bondage. In 1806, eight of the estimated 60 slaves held by Loyalist Matthew Elliott fled across the Detroit River, adding to his loss of escaping slaves.

Others employed resistance tactics similar to Chloe Cooley’s. Peggy, an enslaved woman who was owned by Executive Council member and provincial administrator Peter Russell, did the same. She frequently left her master’s property for short periods of time, so much so that Russell had Peggy jailed. In 1803, Russell published a notice in the Upper Canada Gazette warning the public not to harbour Peggy, who absented “herself from his service.” Peggy’s son Jupiter, also owned by Russell, was described by Russell’s sister Elizabeth as defiant, and was also jailed on several occasions. These strategies were employed by enslaved Africans as a way to disrupt the daily lives of their masters and mistresses and to resist their forced servitude.

Chloe Cooley’s defiance garnered attention that precipitated legislative change. The Act was the first and only piece of legislation to limit enslavement in the British Empire until 1833, when An Act for the Abolition of Slavery throughout the British Colonies; for promoting the Industry of the manumitted slaves; and for compensating the Persons hitherto entitled to the Service of such Slaves (later called the Slavery Abolition Act) abolished enslavement in all British holdings, including Canada, as of 1 August 1834. Freedom was celebrated on what came to be known as Emancipation Day, or August First.

The Act to Limit Slavery also signalled a growing shift in attitudes toward slaveholding in British North America, and contributed to the beginnings of an anti-slavery movement in Upper Canada. Yet, the Act added to the complex social status of Black people in the province. There were hundreds of enslaved Black persons who were deemed chattel property and did not have any rights or freedoms. There were also some free Black persons — less than 50 — who were primarily Black Loyalists, men who fought in the British Army during the American Revolution and were freed for their service. They had legal rights as British subjects, but often these rights and freedoms were limited by racial barriers. Due to the Act, there were soon freeborn Black subjects in Upper Canada. Meanwhile, a trickle of refugees from enslavement in the United States began to enter the province. In short, there were people of African descent with conflicting statuses living in close proximity to one another — at times within the same family.

The Act to Limit Slavery and the Slavery Abolition Act set the stage for the extension of the Underground Railroad farther north into Canada. As runaways became free upon arrival in Upper Canada, many enslaved African Americans made the difficult passage north. Though exact figures are not certain, it is believed that as many as 30,000 refugees from American enslavement found freedom in Canada either by way of the railroad or on their own. The railroad's traffic reached its peak between 1840 and 1860, and particularly after the United States passed the Fugitive Slave Act on 10 September 1850.