census did not always include all of the slaves, especially in the West. California was admitted as a free state and reported no slaves. However, there were many slaves that were brought to work in the mines during the California Gold Rush. Some Californian communities openly tolerated slavery, such as San Bernardino, which was mostly made up of transplants from the neighboring slave territory of Utah. New Mexico Territory never reported any slaves on the census, yet sued the government for compensation for 600 slaves that were freed when Congress outlawed slavery in the territory. Utah was actively trying to hide its slave population from Congress and did not report slaves in several communities. Additionally, the census did not traditionally include Native Americans, and hence did not include Native American slaves or Native African slaves owned by Native Americans. There were hundreds of Native American slaves in California,<ref>Castillo, E.D. 1998. "Short Overview of California Indian History" , California Native American Heritage Commission, 1998. Retrieved October 24, 2007.</ref> Utah and New Mexico that were never recorded in the census. Distribution of slaveholders As of the 1860 Census, one may compute the following statistics on slaveholding: Enumerating slave schedules by county, 393,975 named persons held 3,950,546 unnamed slaves, for an average of about ten slaves per holder. As some large holders held slaves in multiple counties and are thus multiply counted, this slightly overestimates the number of slaveholders. Excluding slaves, the 1860 U.S. population was 27,167,529; therefore, approximately 1.45% of free persons (roughly one in 69) was a named slaveholder (393,975 named slaveholders among 27,167,529 free persons). By counting only named slaveholders, this approach does not acknowledge people who benefited from slavery by being in a slaveowning household, e.g., the wife and children of an owner; in 1850, there was an average of 5.55 people per household, so on average, around 8.05% of free persons lived in a slave-owning household. In the South, 33% of families owned at least one slave. According to historian Joseph Glatthaar, the number of soldiers of the Confederacy's Army of Northern Virginia who either owned slaves or came from slave owning households is "almost one of every two 1861 recruits". In addition he notes that, "Untold numbers of enlistees rented land from, sold crops to, or worked for slaveholders. In the final tabulation, the vast majority of the volunteers of 1861 had a direct connection to slavery."