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The Paradigm

<em>State v. Mann</em> (1829)

The dichotomy of the master his slave along with the slave’s relationship with the law has been well documented throughout history. It has been long understood that a slave – or even a free person of color – does not have the same protection as a white man under the law. This sentiment is reflected in certain cases, like the case of State vs. Mann in 1829, where the slave in question is granted no rights of self defense or self preservation. We accept this paradigm of the harsh slave law under given circumstances, with evidence provided by a certain case; State vs. Mann. This case will demonstrate the ideals of slave law in Antebellum North Carolina with respect to a specific judge on the state supreme court.

            Initially, judgment was found against the defendant – John Mann – for the assault and battery of the slave, Lydia. Lydia was a slave of another woman who rented her to the defendant for one year. Because of the chastisement of the defendant for a minor offense, Lydia fled and was wounded in the act of fleeing.(Item 44) It was found that “the punishment inflicted by the Defendant was cruel and unwarrantable, and disproportionate,” as stated by Judge Daniels.(Item 44)  In essence, due to the fact that the renter, John Mann, had only a ‘special’ ownership over Lydia, he was guilty of doling punishment disproportionate to the offense. It is interesting to note that the judgment of assault and battery was not made on account of the harsh punishment made against another person, but that the punishment was unjustified because of the relationship between the temporary owner and the rented slave. This dehumanizing mindset was prevalent among most slave holders and proponents of slavery.(Item 44) 

            John Mann appealed the decision and won, but the story does not end at his victory; but at the decisions that was reached. In the appeal, one of the most influential arguments for the subjugation of slaves was presented by the Chief Justice, Thomas Ruffin. Ruffin argues in his decision that the will of the master, in dealing with the slave, is absolute. This will is unlimited and unconditional within the limits of existing statutes.(Item 44)  The argument made by Judge Daniels that the special ownership of the slave, Lydia, was the cause of the judgment against the defendant. Because the ownership was not outright, the charge of battery was justified. Ruffin disagrees, saying that there exists no precedent for such a conclusion. The arguments used by Daniels was based off the statutes governing the relationship and appropriate forced used against a master and apprentice or parent and child. As Ruffin describes, “The Court does not recognize their application [to this case]. There is no likeness between the cases. They are in opposition to each other, and there is an impassable gulf between them.” (Item 44) 

Thomas Ruffin’s recognition of this dichotomy is interesting; it is almost Hegelian in his approach.(Item 44)  Ruffin notes that the ultimate result of slavery is the profit of the owner. As such, whatever punishment (however cruel or harsh) that is deemed necessary by the owner was justifiable under the nature of slavery. Slavery requires complete dominance of the master over the slave. For Ruffin it was a public safety issue and a logical conclusion to a strict interpretation of the law. Ruffin states that “Moderate force is superadded, only to make the others [pupil, student, child, etc.] effectual. If that fail, it is better to leave the party to his own headstrong passions, and the ultimate correction of the law, than to allow it to be immoderately inflicted by a private person. With slavery it is far otherwise.”(Item 44)  Ruffin’s reasoning for such a hard line approach to slave law was his uncertainty on when the courts may interfere in cases of “Cruelty and deliberate barbarity.”(Item 44)  Ruffin concluded that if the actions are in accordance with the laws of man, the courts have no justification in calling the actions of the master into question.(Item 44) As a result, Ruffin ultimately concludes that

the Court is compelled to declare, that while slavery exists amongst us in its present state, or until it shall seem fit to the Legislature to interpose express enactments to the contrary, it will be the imperative duty of the Judges to recognize the full dominion of the owner over the slave, except where the exercise of it is forbidden by statute. 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 tranquillity, greatly dependent upon their subordination; and in fine, as most effectually securing the general protection and comfort of the slaves themselves.(Item 44)