In the rare instances when the ownership of
slaves by free Negroes is acknowledged in the history books,
justification centers on the claim that black slave masters were simply
individuals who purchased the freedom of a spouse or child from a white
slaveholder and had been unable to legally manumit them. Although this
did indeed happen at times, it is a misrepresentation of the majority of
instances, one which is debunked by records of the period on blacks who
owned slaves.
http://americancivilwar.com/authors/black_slaveowners.htm
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