State v. Mann: Lydia’s Journey

Naturally, we don’t know her full name. That we know her at all is only because of a gun aimed at her by a man who aimed to control her. The shot John Mann fired at the fleeing Lydia, in Edenton in 1829, was not heard ’round the world, at least not immediately. Among all the acts of violence great and small routinely inflicted on enslaved people, this one might never have been remembered. But John Mann was called to account in criminal court. And so the repercussions of his deed spiraled, at first locally when a jury found him guilty of assault, then broadly when the North Carolina Supreme Court reversed the conviction and absolved him of responsibility. In upholding the right of John Mann to punish the disobedient Lydia with gunfire, Judge Thomas Ruffin wrote in State v. Mann (1829), “the power of the master must be absolute, to render the submission of the slave perfect.” Legal historians consider State v. Mann, 13 N.C. 263 (1829), to be the law’s starkest, most cruel justification of the violence at the heart of the slave labor system. This essay relies on archival research that brought the facts of the case to light. With one exception, noted below, all facts cited in this essay are documented here.

Mann suffered no consequence for firing a bullet from his porch at a woman whom he did not own, but had only hired for a time. The import of State v. Mann spread from the pages of the North Carolina case reporters to widely distributed manuals instructing enslavers just how far they could go: perhaps a better way to say it would be that Ruffin’s language eased their minds, relieving them of any pang of guilt for their regular acts of abuse.  

But let us return to Lydia. Let us start where we first find her. She is listed as an asset of the estate of one Thomas Jones, a Chowan County farmer. He died in November 1822 without a will, leaving a wife, eight children, and some 640 acres of land. He also left twenty-one slaves, among them the sixteen-year-old Lydia. Lydia stayed on at the Jones homestead to work for Thomas’ widow, but two years later, when Temperance Jones died, everything changed. The minor children went to live with guardians. A girl of about fifteen named Elizabeth, with two brothers, went to live with their older sister Matilda, whose husband Josiah Small became their legal guardians. 

For Lydia, the consequences were far worse. What remained of the home she knew was broken up so that the assets of the estate could be divided among the heirs. Lydia and a boy named Jerry were given to Elizabeth. But in the ruthless accounting necessary to make sure that the bequests were of equal value, one of Elizabeth’s assets had to be liquidated: Jerry was sold off. (We know no more of Jerry.) 

Living in her sister’s home, Elizabeth would not have needed her own slave. So Josiah Small did his duty as her guardian and kept Lydia hired out: as an asset of Elizabeth’s estate, she had earnings potential that must not be wasted. In Chowan County, as across the South, hiring-day was a ritualized and much anticipated affair that took place every January 1. Candidates for hire were put up for public auction. The highest bidder would secure a one-year contract, and in addition to the price paid, the bidder would agree to provide them board and clothing. 

Although we don’t know the names of her first several hirers, we do know that Lydia was hired out in 1825, 1826, and 1827, and that she was able to command a market rate even for the year 1827–a year during which Small’s guardianship records list expenses for a midwife and a coffin. Behind those ledger entries lies a story painful to imagine: at age 20 or 21, Lydia had given birth to, and buried, a child.  And there was no relief from the hiring market. In 1828, Lydia was hired out as a domestic to an Edenton man. John Mann was an old, recently widowed sea captain, left to raise two daughters and two sons. He was destitute. He had spent time in debtors’ prison. His house had been forfeited to creditors a couple of times, although thanks to friends willing to pull off questionable legal moves, he was able to remain there. In short, he could not afford to buy a slave, but he did manage to lease Lydia for the year 1828.

The year 1829 found Lydia still in Mann’s employment, and it was on Sunday, March 1 that things came to a head. Frustrated with her resistance to his punishment over what the trial court concluded was “a small offence,” Mann called to one of his daughters to fetch his gun as Lydia ran from him. 

Like most slave hirers, Mann would have assumed that he had complete authority over her. Hired slaves, on the other hand, were well aware that their hirers were not their owners. Lydia’s choice to run was a brave act of self-help. Mann’s abuse was something she decided not to tolerate, and she trusted that Josiah Small would not stand for it either. 

In choosing to flee from her hirer’s cruelty–in putting herself in further jeopardy, with no assurance of safety–Lydia wrested a measure of control over her own fate. We don’t know how badly she was wounded. (The guardianship account for 1829 shows no medical expense.) Perhaps she found cover in the nearby swamps, where maroons–fugitive slaves who had long populated that uninhabitable land–would have helped her evade capture. One way or another, we’re left to presume, she did make her way back to the Small family farm. 

Small persuaded the solicitor (the district attorney) to take the case to a grand jury upon a charge of assault and battery, and a true bill was returned. In pursuing criminal charges, Small was interested not in private damages but in public vindication on behalf of his young ward Elizabeth Jones. John Mann stood for trial before a jury of twelve slave-owning Chowan County men, and they found him guilty. Their reasoning was that as Lydia’s hirer as opposed to her owner, Mann had only limited powers over her, and that he had exceeded his authority.

Mann’s request for a new trial was denied. The theory his lawyer had proposed, though, became the very theory that Thomas Ruffin would adopt in reversing the conviction: “that it was not indictable for the defendant to punish the negro however cruel that punishment might be” because the man who hired Lydia “was her master for the time being.” 

And so it was that Thomas Ruffin, writing for a three-member Supreme Court very early in his tenure on the Court, held it immaterial whether the person exercising authority over the enslaved was that person’s owner, or hirer, or any “other person having possession and command of the slave.” Such broad authority was necessary because of the unique nature of slavery. It was nothing like, for example, the relation of child to parent. The slave labor system, Ruffin’s holding recognized, was rooted in capitalism: “The end is the profit of the master, his security and the public safety.” 

Ruffin understood that no one would voluntarily submit to slavery, that there was no rational argument for it. Nothing short of  “uncontrolled authority over the body” could ensure “total obedience.” Thus, the enslaved person “must be made sensible that there is no appeal from his master; that his power is in no instance usurped; but is conferred by the laws of man at least, if not by the law of God.”

News of State v. Mann spread quickly across the South, emboldening enslavers and enlisting their slaves’ quiet submission. But Ruffin overplayed his hand. In the North, his shockingly frank depiction of slavery’s dependency on the enslaver’s “absolute” physical power became a rallying point against the institution, clear proof of its immorality. Harriet Beecher Stowe condemned the opinion as she made it the centerpiece of her 1856 novel Dred. As the abolitionist movement gained traction, State v. Mann became one of the most potent arrows in its advocates’ quiver.

What a paradox: that a legal opinion intended to solidify the system of slavery came to stand for the moral necessity of freeing the slaves! 

After State v. Mann, Lydia’s trail runs cold. With Elizabeth having aged out of guardianship, the annual court filings of her income and expenses come to an end. Elizabeth subsequently married a man from nearby Gates County. Did she take Lydia with her to her new home? We don’t know. 

Lydia would have surely heard that Mann’s conviction had been overturned. But lacking evidence that she was literate or that she traveled in circles where such explosive subjects were discussed, it seems inconceivable that she would have known about State v. Mann’s afterlife. She would not have known that her bold and determined act of rebellion on a Sunday in March of 1829 would play a part in the ultimate undoing of the cruel system of bondage that had so circumscribed her life.