In the nineteenth century, this labor was supplied by Black Americans. The conditions on Navassa were so brutal that Black workers protested, only to be met with violent repression by the white management of the Navassa Phosphate Company, prompting a revolt in which several white men were killed.

While three men (George S. Key, Henry Jones, and Edward Smith) were initially sentenced to death for murder, their supporters launched a legal challenge to the Guano Act and the jurisdiction of U.S. courts, arguing it all the way up tothe U.S. Supreme Court as Jones vs. U.S.