William Sampson is one of the most important Irish-Americans in the legal history of New York State, but sadly few remember his name or how this Protestant Irishman made an invaluable contribution both to the rights of Catholic New Yorkers and to the religious freedom of all New Yorkers. Sampson was born the son of a Presbyterian minister in Londonderry in 1764, coming of age at a time when Presbyterians chaffed at the restrictions and injustices imposed on their faith by the Test Acts Church of Ireland. Presbyterians in Sampson’s day were forced to take the Sacrament of the Lord's Supper according to the rites of the Church of Ireland as a condition of holding any office, civil or military, under the Crown.
These restrictions caused bitter resentment amongst educated Presbyterians who were barred from government positions. Many Presbyterians even favored revolting against the British government and creating a Republic that would treat men of all faiths equally. Sampson, like many Northern Presbyterians, was profoundly influenced by the ideals of the enlightenment and it was only natural that he gravitated towards radical revolutionary circles.
He entered Trinity University and then read for the law at Lincoln’s Inn in London. Returning to Ireland, he became a contributor to the radical paper the Northern Star. Sampson defended some of the accused Irish radicals in court and when the United Irishmen rose against British rule in 1798 Sampson was one of the fighters whom the British government sought to imprison.
(Left: Emblem of the United Irishmen.)
He escaped first to the continent and then to New York in 1806 where he became a lawyer, but never abandoned the enlightenment ideals that had made him fight in Ireland for religious and civil liberties. A legal case appeared that threatened religious liberty in New York. The case dealt with the question of whether a Roman Catholic priest could be forced to disclose the secrets learned in the Confessional. In this case, Father Anthony Kohlmann, a Jesuit priest who was acting as vicar general of the newly formed Diocese of New York, was ordered by the city magistrate to reveal the names of people who had been in possession of goods stolen from merchant, James Keating, who had reported the theft of merchandise from his store to the city government.
Charges were then filed against two people who had received the stolen goods, even though these individuals did not commit the robbery themselves. Father Kohlmann had arranged for restitution of the stolen goods to Keating after he learned the names of the guilty parties during confession. Keating then attempted to withdraw the criminal charges after the goods were returned, but the city magistrate demanded that Father Kohlmann release the names of the people who possessed the stolen goods anyway, which would have violated Fr. Kohlmann’s religious vows. When the news of this case became public, it aroused the enmity of the anti-Catholic Nativist element in the city.
In 1813, Catholics comprised only a tiny minority of the city’s population. Several Protestant ministers vociferously condemned Father Kohlmann from the pulpit and the threat of anti-Catholic violence loomed. When the case reached the grand jury, Nativists became even more agitated after the priest explained to the court that revealing the names he had learned in confession violated his clerical vows and that he was duty bound to defy the court. The unsympathetic magistrate was prepared to charge Father Kohlmann with contempt of court for refusing to reveal the identities. With Nativism and anti-Catholicism in New York rising among the New York Protestants, the city’s district attorney, Barent Gardinier, and the mayor, DeWitt Clinton, did not wish to foment further religious tension, so they offered to squelch Father Kohlmann’s prosecution.
(Right: Father Anthony Kohlmann)
Several founding trustees of St. Peter’s Church, the only Catholic Church in the city, in 1813, though, did not wish to have the case dropped. They were anxious to see this governmental challenge to their religious faith defeated in an open court. The district attorney and mayor reluctantly agreed to their request and on June 8, 1813, the Court of General Sessions brought the case of the People Vs. Phillips to trial with Clinton presiding as judge. Luckily, William Sampson, who has been called America’s first Civil Rights lawyer, represented Father Kohlmann. Sampson was one of many non-Catholics who were disturbed by the level of discrimination and violence against members of the Catholic faith.
As a Presbyterian Irishman who was aware of the dangers of an absence of religious liberty, Sampson mounted a vigorous defense of Fr. Kohlmann and limiting governmental interference into religious liberty. Sampson passionately explained to the court the dangers of an overweening government that interfered with religious liberty. Sampson and the defense argued that requiring priests to testify violated both common law principles and principles established by the religious liberty clause in Article 28 of the New York constitution.
Although the state responded that the Catholic clergy was requesting a special privilege that could prove “inconsistent with the peace or safety of this state,” Sampson's own bitter personal experience of religious-based intolerance in Ireland helped him persuade the court that America should not look to British common law for legal precedent when dealing with Catholics, but should look to its own First Amendment religious protections.
The court returned a verdict favorable to Fr. Kohlmann and religious liberty. People v. Phillips (N.Y. 1813), which De Witt Clinton wrote on behalf of the unanimous New York Court of General Sessions, or “Mayor’s Court,” has been described as “a constitutional landmark in equality theory; as the first free exercise case; as the origin of the evidentiary priest-penitent privilege; and as perhaps the earliest instance of group impact litigation. This case reaffirmed the First Amendment’s right to free exercise of religion Sampson died in 1836 and was buried in the Riker Family graveyard in what is now East Elmhurst, Queens, and New York. He was later reinterred in Green-Wood Cemetery in Brooklyn, New York, where he is now buried in the same plot as Matilda Witherington Tone and William Theobald Wolfe Tone, the wife and son of the Irish revolutionary Wolfe Tone, and his daughter Catherine, the wife of William Theobald Wolfe Tone.