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Dictionary-Act

Doctrine Foreclosed

The movement claim that statutes addressed to 'persons' bind only those who hold the corresponding legal status — leaving 'free men and women' outside the statute's reach — is foreclosed

Byron Beers's central definitional move, recurring across Treatises 2, 7, 9, and 10, distinguishes 'person' (a creature of civil law, a status the sovereign confers and can revoke) from 'man' (the natural condition outside that taxonomy). The historical fact that older legal dictionaries treated 'person' as a status term is correct. The operative claim Beers builds on it — that statutes addressed to 'persons' don't bind people who decline the status — is foreclosed, but by an interpretive chain rather than by a single express statutory definition. The Internal Revenue Code's § 7701(a)(1) and the Dictionary Act at 1 U.S.C. § 1 both define 'person' to include 'an individual' alongside corporate and entity categories. Neither statute separately defines 'individual.' The operative meaning is supplied by three converging sources: the plain-meaning canon of statutory construction (which applies a term's ordinary English meaning when Congress hasn't defined it), Treasury Regulation 26 CFR § 1.1-1(a)(1) (which operationalizes the income tax on 'every individual who is a citizen or resident'), and uniform federal case law rejecting the natural-man / declination argument. The chain is doctrinally sufficient to foreclose the argument under current law; the verdict is foreclosed under that chain, not by an unalterable express statutory definition. The two-types-of-slaves taxonomy Beers attributes to Dred Scott v. Sandford as further support for the distinction is not in Taney's opinion.

8 min read May 11, 2026