State vs Mann

In 1929 a slave named Lydia owned by Elizabeth Jones was rented to a man named John Mann of Chowan County. While in the possession of John Mann, Lydia was shot in the back while escaping chastisement. The state of North Carolina charged Mann with assault. During the jury trial, the jury believed the punishment inflicted by the Defendant was cruel, unwarrantable, and disproportionate to the offense committed by the slave, so therefore in law the Defendant was guilty, as he was not the primary owner of the slave. It was such an unusual case; Mann was fined $10 for his crime but appealed to the supreme court of North Carolina. 

The state of North Carolina was a southern state known to have significantly fewer slaves than other states in the south, but this case produced one of the most pro-slavery opinions in all of American history. This decision enhanced slavery in the south but also opened slavery to northern attack. 

The issue of this case was whether Mann/slaveowners are liable for battery committed against their slaves. While the state of North Carolina found John Mann guilty of assault, the supreme court reversed the decision and ruled that "The Master is not liable to an indictment for a battery committed upon his slave. 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. But this rule does not interfere with the owner's right to damages for an injury affecting the value of the slave, which is regulated by the law of bailment." This meant that John Mann did not have to pay the $10 fine, and slaveowners were lawfully permitted to physically harm their slaves as punishment. 

Thomas Ruffin was the chief justice of the court and was presented with a difficult decision. The appeal made him feel like he had to side with the law, which in this case in the state of North Carolina slavery was completely legal at the time. Although Ruffin believed that this was immoral and wrong, he believed that he had the duty to uphold the law. Ruffin's opinion was one of the most notorious arguments defending slavery; he ruled that although Lydia was not owned by Mann himself she was still legally under his control therefore he had the right to use as much force to control Lydia as Elizabeth Jones herself would have. This means that Jones is able to sue Mann for damaging her property.