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In page Benjamin Butler:

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While in command at Fort Monroe, Butler declined to return to their owners fugitive slaves who had come within his lines. He argued that Virginians considered them to be chattel property, and that they could not appeal to the Fugitive Slave Law of 1850 because of Virginia's secession. Furthermore, slaves used as laborers for building fortifications and other military activities could be considered contraband of war.[15] [16] It was later made standard Union Army policy to not return fugitive slaves.[17] This policy was soon extended to the Union Navy. [18]