{{Short description|1601 court case in England}} {{Use dmy dates|date=April 2022}} {{Infobox court case | name = Henry Clifton v. Robinson | court = Star Chamber | image = The Star Chamber (engraving, c. 1890).jpg | date decided = 1601 | full name = Henry Clifton vs. The Blackfriars Company (Robinson, Gyles & Evans) | citations = | judges = | prior actions = | subsequent actions = none | opinions = | transcripts = | keywords = {{hlist|Forced drama|Early English Choir Schools|Sexualisation|Children}} }} '''The Clifton Star Chamber Case''' or ''Clifton vs. Robinson'' was a court case of early modern England, in 1601, before the Star Chamber, concerning the abduction of children by choir schools.<ref>{{Cite web|url=https://mapoflondon.uvic.ca/CLIF3.htm|title=Henry Clifton|date=2016|website=mapoflondon.uvic.ca|language=en|access-date=2020-02-18}}</ref>
==The case== In 1601, Henry Clifton, a nobleman from Norfolk,<ref name="Heller">{{cite book |last= Heller |first= Herbert Jack |date= 2000 |title=Penitent Brothellers: Grace, Sexuality, and Genre in Thomas Middleton's City Comedies|url=https://books.google.com/books?id=osKRuBKU344C |location=Newark |publisher= University of Delaware Press |page=123 |isbn= 9780874137019 |author-link= }}</ref> sued the Blackfriars company (headed by Gyles, Robinson, and Evans) for their abduction of his son Thomas, on 13 December 1600.<ref>{{Cite web|url=https://blog.nationalarchives.gov.uk/kidnapped-order-child-actors-shakespeares-day/|title=The National Archives - Kidnapped to order: child actors in Shakespeare's day|last=Archives|first=The National|date=2016-05-12|website=The National Archives blog|language=en-GB|access-date=2020-02-18}}</ref> Clifton obtained a warrant from Sir John Fortescue, who granted it using his authority as a member of the Privy Council due to his connections and high social status.<ref>{{cite web |url=http://mapoflondon6.uvic.ca/BLAC6.htm#CLIF3 |title= Blackfriars Theatre |last=Jenstad |first=Janelle |date=29 September 2017 |website= The Map of Early Modern London |publisher= University of Victoria |access-date=30 October 2017 |quote=}}</ref><ref>{{cite book |last=Forse |first=James H. |date=1993 |title=Art Imitates Business: Commercial and Political Influences in Elizabethan Theatre |url=https://books.google.com/books?id=r7gHKfW5zSEC |location=Bowling Green |publisher=Bowling Green State University Popular Press |pages=191–194 |isbn= 9780879725952 |author-link= }}</ref><ref>{{cite book |last1= Bullough |first1= Vern L. |last2= Bullough |first2= Bonnie |date=1993 |title=Cross Dressing, Sex, and Gender|url=https://books.google.com/books?id=KcD7nVelXJgC |location=Philadelphia |publisher=University of Pennsylvania Press |pages=80–81 |isbn= 9780812214314 |author-link= }}</ref> The basis for the case was not that Thomas was forcibly impressed into the choir school (which was entirely legal) but that he was made to act in the plays of Children of the Chapel.<ref name="Ackroyd">{{cite book|last1=Ackroyd|first1=Julie|title=Child Actors on the London Stage, Circa 1600: Their Education, Recruitment, and Theatrical Success|date=2017|publisher=Sussex Academic Press|location=Chicago, IL|isbn=9781845198480|pages=4–58}}</ref>
===Ostensible consequence=== In 1606, possibly as a result of this case, the royal patent allowing the Master of the Children of the Chapel Royal to impress children into service was revised to stipulate that choristers who had been forcibly impressed would not be "used or employed as Comedians or Stage players."<ref>{{Cite book|title=Performing Childhood in the Early Modern Theatre: The Children's Playing Companies, 1599-1613|last=Lamb|first=Edel|publisher=Palgrave Macmillan|year=2009|isbn=978-0230202610|location=Basingstoke|pages=10}}</ref>
==Importance of the case== The Clifton case is one of the only surviving objection records to the common practice of forcibly impressing boys into (ecclesiastical) choir schools in medieval and early modern England. It is notable that the objection is to the child's involvement in the controversial children's theatre companies of the period. Forcible impressment was royally condoned as seen in letters from Elizabeth I on 15 July 1597 for the Master of the Children of the Chapel.<ref name="Ackroyd"/> The prevalence is evidenced by documents such as an authorization for the Chapel Royal in 1420 and ''An Ordinance of the Lordes and Commons Assembled in Parliament, for the Apprehending and Bringing to Condigne Punishment, All Such Lewd Persons as Shall Steale, Sell, Buy, Inveigle, Purloune, Convey, or Receive Any Little Children'' (9 May 1644).<ref name="Ackroyd"/> Others such as Salmon Pavey, Avery Trussell, John Chappell, Nathan Field, John Motteram, Philip Pykman, and Thomas Grymes are known such impressees.<ref name="Ackroyd"/><ref name="Corrigan">{{cite book|url=https://books.google.com/books?id=5FoVUIYGXdgC|title=Playhouse Law in Shakespeare's World|last=Corrigan|first=Brian Jay|date=2004|publisher=Fairleigh Dickinson University Press|isbn=9780838640227|location=Madison|pages=74–75|author-link=}}</ref>
==References== {{reflist}}
Category:1600 in English law Category:1600 in case law Category:Star Chamber cases Category:English criminal case law Category:Child abduction in England Category:Blackfriars, London Category:17th century in London Category:17th-century theatre