Location: On Broad Street at Freemason St., Edenton
County: Chowan
Original Date Cast: 2023
State v. Mann is one of the most important cases in American law related to slavery and perhaps the most infamous ruling concerning enslavement issued by a state court. Justice Thomas Ruffin, who wrote the ruling on behalf of the North Carolina Supreme Court, gave slaveholders the power of nearly unlimited physical force in disciplining enslaved persons. The ruling served as a major point of criticism of slavery by abolitionists in the 1850s.
John Mann, a poor white resident of Edenton, N.C., had hired an enslaved woman named Lydia from her owner Elizabeth Jones. On March 1, 1829, Mann began to whip Lydia, who ran from him. Mann shot her as she fled. He was charged with assault and battery and put on trial in the county superior court. As Mann was not Lydia’s owner but had hired her from her owner, he was considered liable for the assault by the jury and convicted. Mann then appealed the decision to the North Carolina Supreme Court.
The court overruled Mann’s conviction. Ruffin wrote the decision, which negated the distinction between a slaveowner and a hirer as to disciplinary authority. The ruling represented one of the franker statements on the subject of slavery from representatives of the slaveholding class, as it omitted much of the paternalistic triteness common in contemporary arguments regarding slavery and instead asserted the absolute right of control over an enslaved person by a slaveowner, and, by proxy, someone in temporary possession of an enslaved person. Slavery, wrote Ruffin, existed for the exclusive benefit of the masters, and that was it; thus, both an owner and a hirer had the right to use whatever methods were necessary to coerce obedience from an enslaved person, including violence. This holding did not mean that such violence was necessarily consequence free; for example, someone like Mann could possibly be sued for damages by the person from whom he had hired the enslaved person for injuring him or her, as that could possibly affect the economic value of the enslaved person for the owner.
The impact of State v. Mann went far beyond its influence on how the judicial system regulated slavery. Abolitionists frequently cited the ruling and examples from its text as illustrations of the brutal immorality of slavery. The ruling and its text were central to the plot of Harriet Beecher Stowe’s 1856 novel Dred: A Tale of the Great Dismal Swamp.
References:
Sally Greene, “The Birth of Black Power,” The American Scholar, Spring 2021, available at https://theamericanscholar.org/author/sally-greene/
Sally Green, “Judge Thomas Ruffin and the Shadows of Southern History, Southern Cultures, 17:3 (Fall 2011), 66-90.
Sally Greene, “State v. Mann,” Milestone Documents in African American History, ed. Paul Finkelman, I:231- 240 (2010).
Sally Greene, “State v. Mann Exhumed,” North Carolina Law Review, 87:3 (2009), 701-755.
Sally Greene, “State v. Mann: Lydia’s Journey,” Black Perspectives, African American Intellectual History Society, February 23, 2022, State v. Mann: Lydia’s Journey | AAIHS .
Timothy S. Huebner, The Southern Judicial Tradition (1999).
Records of trial of John Mann, Chowan County Superior Court (1829), North Carolina Office of Archives and History.
State v. Mann, 13 N.C. (2 Dev.) 263 (1829), available at http://moglen.law.columbia.edu/twiki/pub/AmLegalHist/TedProject/Mann.pdf.
Harriet Beecher Stowe, Dred: A Tale of the Great Dismal Swamp (1856).
Mark V. Tushnet, Slave Law in the American South: State v. Mann in History and Literature (2003).
Heather Andrea Williams, American Slavery: A Very Short Introduction (2014).