State v. Mann

Written By Jonathan Murray

The 1829 decision of the North Carolina Supreme Court in State v. Mann declared that slaves had no rights from their masters. Thomas Ruffin authored the opinion of the court, in which he asserted the “full dominion of the owner over the slave.”

The defendant in the case was John Mann, a North Carolinian who had been renting a slave named Lydia. When she committed a trifling offense, Mann whipped her. During the whipping, Lydia attempted to escape, so Mann shot her, gravely wounding her. North Carolina authorities deemed his response to her escape attempt disproportionate and charged him with assault and battery. In the criminal trial, the jury ruled against him. He appealed, claiming that assault on a slave by her master could not be indictable since a slave was property of her master.

The case reached the North Carolina Supreme Court shortly after Thomas Ruffin‘s long tenure on the court began. At the beginning of the opinion, he registered his uneasiness with the case: “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.” 

Nonetheless, Ruffin concluded that “the power of the master must be absolute, to render the submission of the slave perfect.” He argued that inhuman punishment of slaves was indeed legal in North Carolina. He cited “the actual condition of things”—to wit, the extant legal order of North Carolina, which called for slavery. Altering this actual condition of things was not, Ruffin asserted, an activity for jurists. On these grounds, he declined to afford legal protections to slaves.

Ruffin’s opinion remains notorious in the fields of legal and American history. His refusal to rectify or allay slavery’s most brutal aspects attest to the moral confusion that abounded in the early-nineteenth-century United States.  However, in two subsequent cases in the 1830s, William Gaston of the Supreme Court at least modified this justification of cruelty.