State v. Mann

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 State v. Mann Remains Infamous



John Mann, a North Carolinian rented a slave named Lydia. When she committed an insignificant offense, Mann whipped her. During the punishment, Lydia struggled to escape, so Mann shot her, seriously wounding her. A North Carolina jury judged his response to her escape attempt disproportionate and Mann was ruled guilty of assault and battery. He appealed the conviction, on the grounds that assault on a slave by her master could not be illegal since a slave was the property of her master.


The Supreme Court of North Carolina heard the case and reversed the conviction. The court found that since Mann had possession of the slave he was entitled to the same authority as the owner. Consequently, as an acting owner, Mann was not liable for battery on the slave. According to this 1829 decision, slaves had no rights against their masters. Judge Ruffin wrote the opinion of the court affirming the "Full dominion of the owner over the slave." He argued that the inhuman punishment of slaves was indeed legal in North Carolina. Altering this actual condition of things was not, Ruffin declared, an activity for jurists. On these grounds, he declined to afford legal protections to slaves in the state of North Carolina.


At the beginning of the opinion, Ruffin disclosed 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, he upheld the power of the master to demand the complete submission of the slave. With this case the unjust precedent, that a slave could not appeal against his master's power and the master's power could not be usurped, was set.


At the time of the Mann decision, North Carolina precedent provided grounds to refute a master's absolute authority over his slave. But in Mann, Judge Ruffin made the judicial choice to preserve the relational status quo between the master and slave rather than recognize slaves as sentient beings entitled to rights afforded by the rule of law.


In this case, the Court’s refusal to correct or lessen slavery’s most brutal aspects demonstrated the moral confusion that abounded in the early-nineteenth-century of the United States. State v. Mann remains infamous in the fields of legal and American history.



Sources

The State v. John Mann, 13 NC 263 (North Carolina Supreme Court, 1829), http://plaza.ufl.edu/edale/Mann.htm (accessed December 9–11, 2008); Julius Yanuck, “Thomas Ruffin and North Carolina Slave Law,” The Journal of Southern History 21, No. 4, 456–475.

https://scholarship.law.unc.edu/cgi/viewcontent.cgi?referer=&httpsredir=1&article=4370&context=nclr


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