Ruffin's Decision in State v. Mann
North Carolina Supreme Court Justice Thomas Ruffin ruled in the 1830 State v. Mann decision that “The power of the master must be absolute to render the submission of the slave perfect.” (Item 44) After looking closely at Ruffin’s decision, it is apparent that he was protecting the institution of slavery. Ruffin’s decision shows several flaws that lead to this conclusion, and show “that his decision was one more of judicial choice than judicial duty.” (Wynn 2009, 992)
In the Mann decision, Ruffin stated, “we are forbidden to enter upon a train of general reasoning on the subject. We cannot allow the right of the master to be rought into discussion in the courts of justice.” (Item 44). This reasoning ignores the ruling in the previously mentioned State v. Hale decision in 1823, in which the court “upheld battery by a stranger against a slave as an indictable offense.” (Wynn 2009, 995) According to James Wynn, Ruffin could have used the Hale case’s precedent “by focusing on the behavior of the perpetrator, rather than the identity of the victim.” (Wynn 2009, 995) The Hale decision stated:
The common law has often been called into efficient operation for the punishment of public cruelty inflicted upon animals for needless and wanton barbarity exercised even by masters upon their slaves, and for various violations of decency, morals, and comfort. Reason and analogy seem to require that a human being, although the subject of property, should be so far protected as the public might be injured through him. (Wynn 2009, 995)
This decision acknowledges the slave’s status as property, yet also gives the slaves the right to be protected by the law. Using this case would have allowed Ruffin to uphold the conviction of Mann that was given in the trial court.
Ruffin stated in the Mann decision 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 slaves, except where the exercise of it is forbidden by statute.” (Item 44) This opinion was not held in the Hale precedent, as Chief Judge Taylor offered that the rights of slaveowners could be held through common law. Taylor stated, “a solution of it must be deduced from general principles, from reasoning founded on the common law, adapted to the existing condition and circumstances of our society, and indicating that result, which is best adapted to general expedience.” (Muller 2009, 773) By ignoring the State v. Hale decision and claiming that common law could not be used to limit the power of masters over their slaves, Ruffin was able to protect the rights of slaveholders and the institution of slavery in North Carolina.
Thomas Ruffin wrote two rough drafts of the State v. Mann decision that shed light on his logic regarding the ruling. The second draft in particular shows that Ruffin considered ruling in Mann’s favor on procedural grounds. This would have resulted in the same court decision, without the controversial ruling. Ruffin could have “ordered entry of the judgement for the defendant” because “neither the jury instruction nor the indictment framed the issue in a way that acknowledged that Lydia was, for the purposes of the criminal chargers, the ‘defendant’s own slave.’” (Greene 2009, 743) He nearly ruled this way, as the second draft of the Mann decision states: “Let there be new trial.” (Item 610) Had Ruffin taken this course, he would not have had to face “the reluctance” of presiding over the case and could have sent it back to the trial courts due to a mistrial. Yet, Ruffin took the opportunity to rule in Mann’s favor in a way that was controversial and protected slaveholders’ rights.
Justice Ruffin also ignored the difference between the owner and hirer of a slave in the State v. Mann decision. Ruffin stated in the decision, “Our laws uniformly treat the master or other person having the possession and command of the slave as entitles to the same extent of authority. The object is the same-the services of the slave; and the same powers must be confided.” (Item 44) Ruffin granted the hirer of a slave the same rights as the true owner, despite that they are treated differently within civil trials. Ruffin noted that hirers are civilly liable to the true owner. Ruffin did not want to affect this, and stated in the Mann opinion, “With the liabilities of the hirer to the general owner for an injury permanently impairing the value of the slave no rule now laid down is intended to interfere.” (Item 44) Ruffin’s ignorance of owner versus hirer, according to Sally Greene, “was a crucial strategic and rhetorical move that enabled him to avoid nuance, to expound upon the issue of the master’s authority in broad, firm strokes.” (Greene 2009, 748). Had Ruffin made a distinction between owner and hirer, the case would have only dealt with the rights of a hirer that assaults a slave. Ruffin instead presented a different question, which was “whether a slave owner--temporary or permanent--could be indicted for the common-law crime of battery for using excessive physical force against his slave.” (Muller 2009, 763) According to Greene:
Ruffin’s rhetoric did not just arises within a certain historical moment; he took an active part in defining the moment, making decisions about what mattered and what did not. He chose to elevate the salve hirer John Mann to the status of master. What that act, he created the urgent situation for which his judicial response became the commanding solution. (Greene 2009, 751)
Ruffin took advantage of his opportunity to personally affect slave law in the South. He used his position as a justice on the bench of the North Carolina Supreme court to promote the interests of slaveholders. This is apparent in his reasonings and decision making in the State v. Mann decision.