North Carolina v.
State v. Mann, as it
would have been identified within North Carolina), is a decision in which the Supreme Court of North
Carolina ruled that slaveowners had
absolute authority over their slaves and could not be found guilty
of committing violence against them.
In 1828 or
1829, Elizabeth Jones, who owned a slave named Lydia, hired her out
for a year to John Mann of Chowan County.
Mann shot and wounded Lydia when she
struggled to escape a whipping. Mann was found guilty of battery
by a jury of twelve white men drawn
from his community and the court (Superior Court Judge Joseph J. Daniel
) imposed a five dollar fine. The
North Carolina Supreme Court overruled the conviction on the
grounds that slaves were the absolute property of their owners who
could not be punished at common law
unless the legislature authorized such punishment.
The judgment of the state supreme court was written by Judge
, who stated that "the
power of the master must be absolute, to render the submission of
the slave perfect", but noted that slaves did have legal right of
protection from persons other than their owners. Ruffin, however,
made it clear that his opinion was a legal one, and that his
sympathy lay with Lydia. He wrote that "the struggle, too, in the
Judge's own breast between the feelings of the man, and the duty of
the magistrate is a severe one, presenting strong temptation to put
aside such questions, if it be possible. It is useless however, to
complain of things inherent in our political state. And it is
criminal in a Court to avoid any responsibility which the laws
impose." Harriet Beecher Stowe
cited State v. Mann as a source for her depiction of slavery in her