This line of reasoning was followed in numerous subsequent Missouri cases, including Rachael, A Woman of Color v. Walker, 4 Mo. 350 (1836), Ralph (A Man of Color) v. Duncan, 3 Mo. 194 (1833), Tramell v. Adam, A Black Man, 2 Mo. 100 (1829), and Merry v. Tiffin, 1 Mo. 391 (1827). Rachael, A Woman of Color v. Walker, is particularly instructive because it concerned a slave taken into Missouri Territory by her master, an Army officer. The Missouri court held in that case that, although slaveholders did not lose their property rights in their slaves merely by passing through a free state, a slave held in Missouri Territory for more than two years was free under Missouri Compromise. Still, there were contrary cases, such as that of Theoteste v. Chouteau, 2 Mo. 93 (1829), in which the Missouri court held that slaves who were taken past the Northwest Ordinance could continue to be held as slaves under theory of vested rights. In Scott's case, the lower Missouri state court granted him a favorable ruling in line with that state's judicial precedent. But this ruling was subsequently overturned by the Missouri Supreme Court, which held that Missouri was not compelled to extend comity (respect) to foreign laws in cases that did not involve the United States Constitution (Dean 713). Thus, according to the Missouri Supreme Court, Missouri courts could ignore the "freedom" prov
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