State v. Mann: 1829
State v. Mann: 1829
Defendant: John Mann
Crime Charged: Assault and battery
Chief Defense Lawyer: No record
Chief Prosecutor: No record
Judge: Thomas Ruffin
Place: North Carolina
Date of Decision: December 1829
Verdict: Judgment reversed, and judgment entered for the defendant
SIGNIFICANCE: A Southern judge with little sympathy for slavery rendered a powerful and logical pro-slavery opinion, further entrenching Southern slavery, while opening it to Northern attack.
NI orth Carolina had fewer slaves than most other states in the future Confederacy. But in the two decades leading up to the Civil War, that state's Supreme Court produced one of the most notorious pro-slavery opinions in American history.
In 1829 Elizabeth Jones, who owned a slave named Lydia, hired her out for a year to John Mann of Chowan County. Lydia was unhappy with the arrangement, and at one point Mann decided to punish her, possibly by whipping her. But Lydia escaped during the punishment, and began to run away. Mann shouted to her, ordering her to stop, but Lydia continued to run. Mann then shot and wounded her. Such, at least, was Mann's story.
The circumstances were so odd, however, that a local grand jury took the unusual step of indicting Mann for assault and battery against a slave. During the trial, the judge told the jury that if it believed that the punishment Mann inflicted was "cruel and unwarrantable, and disproportionate to the offense committed by the slave that, in the law the Defendant was guilty," particularly since he was not even her owner. This is obviously exactly what the jury thought, for it found Mann guilty. Mann then appealed to the Supreme Court of North Carolina.
Thomas Ruffin was the chief justice of that court, and the appeal put him in a very bad position. He disliked the idea of slavery, and he was horrified that a white man had used such violence against a black woman. On the other hand, he could not escape the fact that slavery was perfectly legal in North Carolina. Torn between his sense of justice and his sense of duty to the law, he penned a startling opinion.
"A Judge cannot but lament, when such cases as the present are brought into court," he began. "The struggle … in the Judge's own breast between the feelings of the man, and the duty of the magistrate, is a severe test." But despite his veiled denouncement of the evils of slavery, Ruffin then proceeded to side with the law. "It is criminal in a Court to avoid any responsibility which the laws impose. With whatever reluctance therefore it is done, the Court is compelled to express an opinion upon the extent of the dominion of the master over the slave in North Carolina."
In Defense of Slavery
The rest of Ruffin's opinion, in fact, was one of the most readable, logical, and capable defenses of slavery that a Southerner ever wrote. Ruffin observed that although Mann did not own Lydia, and that Elizabeth Jones might well be able to sue him for damaging her property, Mann still had the right to use as much force to control Lydia as Jones herself would have had, since Lydia was legally under his control. The question, then, was how much force a master could use against his slave.
Ruffin's conclusion was blunt. Slavery was designed for the good of the master, and not for the good of the slave, he wrote. In order for the master to have the full benefit of the slave, he had to be able to break the slave's will, to make the slave obey him. "Such obedience," wrote Ruffin, "is the consequence only of uncontrolled authority over the body. There is nothing else which can operate to produce the effect." The court could not interfere with the master's power over his slave, continued Ruffin. "The slave, to remain a slave, must be made sensible, that there is no appeal from the master." In short, Ruffin held, the law gave the master absolute power over the slave. He recognized that this was unjust, but clearly it was the law.
The Mann opinion came down just as abolitionism was gaining ground in the North. It highlighted the tension between law and justice, and the fact that more and more people were coming to see that slavery was wrong, even though it was both legal and constitutional. In 1856 Harriet Beecher Stowe, author of Uncle Tom's Cabin, wrote Dred: A Tale of the Great Dismal Swamp. In this new antislavery book she modeled the character of Judge Clayton after Thomas Ruffin, and she had Clayton deliver an opinion that strongly resembled the one in State v. Mann. The case, as well as Stowe's fictionalized treatment of it, helped widen the breach between North and South and gave the abolitionists further ammunition to use against the legal system and the judges who protected the morally evil institution of slavery.
—Buckner F. Melton, Jr.