Common law stipulated that men were legally required to acknowledge their bastard children in addition to their legal ones and give them food and shelter - while they also had the right to put their children to work or hire them out taking any earnings, or arranging an apprenticeship or indenture so that they could become a self-supporting adult. Child labor was a critical benefit both to the family headed by a father in England, and to the development of England's colonies - the child was as property to the father, or to those who stood in place of the father, but the child grew out of that condition as they came of age. Regarding personal property (chattels), common law mandated that the profits and increase generated by personal property (live stock, mobile property) accrued to the owner of the chattel property. Beginning in the Virginia royal colony in 1662, colonial governments incorporated the legal doctrine of partus sequitur ventrem into the laws of slavery, ruling that the children born in the colonies took the place or status of their mothers; therefore, children of enslaved mothers were born into slavery as chattel, regardless of the status of their fathers. The doctrine existed in English common law (which agreed with the civil law in such matters as live stock), but in England, the partus sequitur ventrem doctrine did not make chattels of English subjects. In 1656, multiracial woman Elizabeth Key Grinstead, then classified by an owner's estate as being "Negro" and thus enslaved, won her freedom lawsuit and legal recognition as a free woman of color in colonial Virginia. Key's successful lawsuit was based upon the circumstances of her birth: her English father was a member of the House of Burgesses; had acknowledged his paternity of Elizabeth, who was baptized as a Christian in the Church of England; and, before his death, had arranged a guardianship for her, by way of indentured servitude until she came of age. When the man to whom Key was indentured returned to England, he sold her indenture contract to a second man. The latter prolonged Key's servitude beyond the indenture's original term. At the death of the second owner of her indenture, his estate classified Elizabeth Key and her mixed-race son (who also had a white father, William Grinstead) as "Negro slaves" who were the personal property of the deceased. With William acting as her