[U]p until 1671, all Creoles, Mulattoes, free Negroes, etc., paid a capitation tax. In February 12 of that year, M. de Baas, Governor-General of Martinique, issued an order exempting the Creoles. Those Mulattoes who were also designated as Creoles claimed the same exemption and resisted paying the tax. .M.Patoulet, Intendent, rendered a decision in 1683 and said: “The Mulattoes and free Negroes claimed to be exempt from the captivation tax: I have made them pay without difficulty. I decided that those Mulattoes born in vice should not receive the exemption, and that for the free Negro, that master should give him freedom but could not give him the exemption that attaches to the whites originally from France.
The next year, the Mulattoes refused to pay, and the successor of Minister Patoulet, M. Michel Begou, asked for a law to compel them. In 1696, an agreement was reached exempting the Mulattoes and Creoles, leaving only the free black subject to the tax. But in 1712, a M. Robert, in a decision on a subject, again included the Mulattoes, without, however, mentioning the Creoles, so that only the free Negroes and Mulattoes paid. Thus they were held as a class apart. A free Negro woman, Magdelaine Debern, further contested the matter, and in 1724, in the colony of Louisiana, won a decision exempting free Negros and Mulattoes, and again placing them on the same footing as the Creole. The Creole had a decided advantage, however, because through the favor of those in authority, there was always a disposition to exalt them (Dunbar-Nelson 1916:361).”