North Carolina v. Mann

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North Carolina v. Mann, 13 N.C. 167 (N.C. 1830) (or State v. Mann, as it would have been identified within North Carolina), is a decision in which the Supreme Court of North Carolina ruled that slaveowners could not be convicted for killing their slaves even from a beating. Mann had shot and wounded one of his slaves named Lydia when she struggled to escape a whipping. Mann was found guilty of battery by a jury of twelve white men drawn from his community and the court imposed a five dollar fine. The North Carolina Supreme Court overruled the conviction on the grounds that slaves were the absolute property of their owners who could not be punished at common law unless the legislature authorized such punishment.

The judgment of the state supreme court was written by Judge Thomas Ruffin, who stated that "the power of the master must be absolute, to render the submission of the slave perfect", but noted that slaves did have legal right of protection from persons other than their owners. Ruffin, however, made it clear that his opinion was a legal one, and that his sympathy lay with Lydia. He wrote that "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 temptation to put aside such questions, if it be possible. It is useless however, to complain of things inherent in our political state. And it is criminal in a Court to avoid any responsibility which the laws impose."