Slave Court Cases

North Carolina legal statues regarding the rights of slave owners and hirers become of importance when assessing Ruffin’s infamous ruling in State v. Mann. According to North Carolina common law, homicide of a slave was forbidden. Furthermore slave owners were given legal protections against any damage or harm which was afflicted upon a hired out slave. However, a person accused of battery upon a slave need only offer a justification and reasoning for which to defend his actions; crimes against slave, as opposed to battery against a white, were therefore not always a chargeable offense. (Yanuck 1955, 459)

            John Mann, the temporary owner of a hired female slave, was charged for battery after shooting the slave for resisting an alleged punishment. Yet in ruling for the Supreme Court, Justice Ruffin maintained, “One who has a right to the labor of a slave, has also a right to all the means of controlling his conduct which the owner has…hence one who has hired a slave is not liable to an indictment for a battery on him, committed during the hiring.” (Devereux 1898, 229) Furthermore, according to Ruffin, “The power of the master must absolute to render the submission of the slave perfect...” However upon these seemingly harsh verdicts against any rights slaves may invoke for protection, the entirety of Ruffin’s opinion must be read in full context to analyze his sincere opinions towards slaves and the institution of slavery. “A judge cannot by lament when such cases as the present are brought into judgment…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 temptations to put aside such questions, if it be possible. It is useless, however, to complain of things inherent in our political state…I most freely confess my sense of the harshness of this proposition; I feel it as deeply as any man can; and as a principle of moral right every person in his retirement must repudiate it. But in the actual conditions of things it must be so. There is no remedy. This discipline belongs to the state of slavery. They cannot be disunited without abrogating at one the rights of the master and absolving the slave form his subjection. It constitutes the curse of slavery to both the bond and free portion of our population. But it is inherent in the relation of master and slave.” Yet in contrast to this judgment, Ruffin also stated, “that there may be particular instances of cruelty and deliberate barbarity where, in conscience, the law might properly interfere, is most probable. “The difficulty,” continued Ruffin “is to determine were a Court may properly begin.” (Devereux 1898, 229)

  Here Judge Ruffin seemingly evokes the reasoning of his father Sterling in past discussions of slavery while he was attending Princeton.  In closing the ruling, Ruffin stated, “I repeat that I would gladly have avoided this ungrateful question…And this we do upon the ground that this dominion is essential to the value of slaves as property, to the security of the master, and the public tranquility, greatly dependent upon their subordination; and, in fine, as most effectually securing the general protection and comfort of the slaves themselves.”

The ruling in Mann, therefore becomes a gateway into the reasoning of Ruffin’s harsh judgment against eventual personal freedom for slaves. Ruffin dedicated himself to protecting the institution of slavery for the betterment and protection of slave labor in North Carolina, securing to absolute boundaries of freedom and bondage, while at same time showing concern for “the general protection and comfort” of slaves.  In analyzing Ruffin’s holding in Mann, one legal scholar commented that, “Ruffin left the door open for situations in which the master’s power would not be absolute…Ruffin, therefore, accomplished a dual purpose…One the one hand, he signaled that the institution of slavery and the master-slave relationship would remain in accordance with “the established habits and uniform practice of the country.” On the other hand, Ruffin left a moral escape hatch for himself and his colleagues by noting that acts of excessive cruelty against slaves would not receive the approbation of the court.” (Huebner 1999, 147-148)

Yet for the purpose to further complicate the legacy of Ruffin’s ostensibly “absolute submission of slaves,” and therefore shed light on a more complete version of his true sentiments towards master and slave, subsequent rulings after Mann, notably become valuable. In State v. Hoover (1939) Justice Ruffin clearly defined a certain limit to the absolute power of a master: killing a slave without justification. The cases surrounded a owner who brutally tortured his slave Mira, whom after suffering from repeated injuries died.  Ruffin, in his ruling stated, “If death unhappily ensue from the master’s chastisement of his slave, inflicted apparently with a good intent, for the reformation or example, with no purpose to take life or to put it in jeopardy, the law would doubtless tenderly regard every circumstance which, judging from the conduct generally of masters towards slaves, might reasonably be supposed to have hurried the party into excess.” However, “the acts imputed to this unhappy man do not belong to a state of civilization. They are barbarities which could only be prompted by a heart in which every humane feeling had long been stifled; and indeed, there can scarcely be a savage of the wilderness so ferocious as not to shudder at the recital of them…” (Devereux 1901, 505)

Ten years later in State v. Boyce (1849) Ruffin again seemed to deviate from the harshness of the decision of Mann when he ruled in favor of allowing slaves to congregate, dance, and celebrate the Christmas holiday. The case involved a defended who was charged by a fellow neighbor for “keeping a disorderly house” by allowing his slaves to celebrate with his permission. Ruffin, in apparent sympathy for slaves leisure activities outside of constant labor, argued, “It would be a source of great regret, if, contrary to common custom, it were to be denied to slaves, in the intervals between their toils, to indulge in mirthful pastimes, or if it were unlawful for a master to permit them among his slaves, or to admit to the social enjoyment the slaves of others, by their consent…We may let them make the most of their idle hours, and may well make allowances for the noisy outpourings of glad hearts, which providence bestows as a blessing on corporeal vigor united to a vacant mind…There was nothing contrary to morals or law in all that---adding, as it did, to human enjoyment, without hurt to any one, unless it be that one feel aggrieved that these poor people should for a short space be happy at finding the authority of the master give glace to his benignity, and at being freed from care and filled with gladness.”(Devereux 1896, 541-542)

In two final cases, Judge Ruffin in Waddill v. Martin (1845) not only sanctioned slaves the right to retain access to products listed in their masters will but also, in Heathcock v. Pennington (1850), specifically recognized spiritual characters of slaves. In Waddill v. Martin, when presented the question of “whether the estate of a deceased planter should include the value of the little crops of cotton he had allowed his slaves to raise for themselves,” Ruffin noted, “the extent of such slave privileges, calling them wholesome, and insisted that although slaves could not legally own property, their right to the product had received the sanction of custom and public sentiment.” (Genovese 1972, 539) Furthermore, in Heathcock v. Pennington (1850) reflecting upon the misfortunate death of a young slave boy who fell into a gold shaft and died and noting how the boy was capable of avoiding his untimely death, based on the evidence, Ruffin stated, “So, a slave, being a moral and intelligent being, is usually as capable of self preservation as other persons.”(Devereux 1896, 643)

These subsequent N.C. Supreme Court cases ruled by Ruffin become juxtaposed with his infamous ruling in Mann. Undoubtedly, Ruffin’s moral, religious, and paternalistic considerations evidenced whenever slave rulings were not specified by common law or conferred by public sentiment. Giving the context of Mann, of which Ruffin publicly admitted in the rulling his personal distaste for such slave cases, he nonetheless made concessions for slaves albeit seemingly minor. Despite the “absolute” servitude slaves were prescribed, Justice Ruffin created situations in which slaves were protected by wanton murder, allowed slaves to celebrate and rejoice certain holidays with a master’s permission, allowed slaves meager ownership of crops for potential material liberties, and most importantly identified the slaves as more than just human property, rather human beings with a moral and intelligent mind.