In 1819 another act was passed to amend the law of 1808. Slaves brought into the State as merchandise were made subject to a tax of twenty dollars each. A certificate was required as in the law of 1808, but it was not to apply to those brought in for their own use by citizens and immigrants except those from Louisiana and the Alabama territory.[365] An act of 1822 reduced into one the several acts concerning slaves, free negroes and mulattoes, but no important changes were made with regard to the importation of slaves.[366] The new constitution of 1832, like that of 1817, excluded slaves guilty of "high crime in other States." It declared, also, that "The introduction of slaves into this State as merchandise, or for sale, shall be prohibited from and after the first day of May eighteen hundred and thirty-three."[367] This provision of the constitution gave rise to a great deal of litigation;[368] nor was it effective in prohibiting importation of slaves. The latter appears from the fact that in 1837 by an act of the legislature "the business of introducing or importing slaves into this State as merchandise, or for sale be, and the same is hereby prohibited." The penalty was $500 and six months' imprisonment for each slave so brought in, and notes which might be given for slaves were not collectable.[369] This law was repealed in 1846.[370] ALABAMA. The first law passed by Alabama concerning the importation of slaves was for the purpose of carrying into effect the laws of the United States prohibiting the slave trade. This was enacted in 1823 and provided that slaves imported should be employed on public works or sold for the State.[371] But on January 13, 1827, it was enacted that "if any person or persons, shall bring into this State any slave or slaves, for the purpose of sale or hire, or shall sell or hire, any slave or slaves brought into this State after the first day of August next, such person or persons shall forfeit and pay the sum of $1,000 for each negro so brought in, one-half thereof to the person suing for the same and the other half to the use of the State. And, moreover, any person thus offending shall be subject to indictment, and on conviction shall be liable to be fined a sum not exceeding five hundred dollars for each offense and shall be imprisoned not exceeding three months, at the discretion of the jury trying such offense." Citizens of the State, however, were allowed to purchase negroes for their own use but could not sell them until two years after being brought into the State.[372] This law was repealed in 1829.[373]