
Thomas Ruffin. Photograph by Matthew Benjamin Brady (1822-1896), located in the National Archives and Records Administration. It is in the public domain.
Opening

Your Honors, may it please the Court.
I appear on behalf of the State of North Carolina to address one part of this case: the historical context for a master's authority over a person he has hired for a year.
Slavery has never gone entirely unregulated by law
Slavery is not a new institution.
- Nearly four thousand years ago, the Code of Hammurabi in Mesopotamia treated slaves as property, but it still held an owner accountable if a slave was harmed by someone else.
Ancient Egypt relied heavily on enslaved labor, including war captives and debtors bound to work they had not chosen, often for life.
Slave brick-makers,
depicted in the tomb of the
vizier Rekmire,c. 1450 BCEGreece and Rome built major parts of their economies on slavery as well.
In each of these systems, the law still recognized the enslaved person as someone it had to account for, even while denying them freedom and treating them as property.
What happened to Lydia falls outside even that history
She was whipped for a minor offense.
When she tried to escape the whipping, she was shot and seriously wounded, by a man who had rented her services for a single year and did not even own her.
Answering the defense's argument
The defense will argue that a master's power must be absolute for slavery to function, and that any limit on that power undermines the institution itself.
The historical record does not support that claim.
Slave systems going back thousands of years — in Mesopotamia, Egypt, Greece, and Rome, and later the plantation economies of the Americas — treated enslaved people as property with very few rights.
Even so, most of these systems still drew some line between disciplining a slave and endangering that slave's life.
Closing and request to the Court
The jury in Chowan County reviewed the facts and found Mr. Mann's conduct cruel, unwarranted, and disproportionate to Lydia's offense.
That finding was reasonable, and it was consistent with how the law has treated this question elsewhere.
This Court is not being asked to change the underlying law of slavery in North Carolina.
It is being asked whether any limit exists on what a person holding another in servitude may do to that person.
1767, Chowan County Courthouse: A National Historic Landmark The State submits that such a limit must exist, and respectfully asks this Court to affirm the verdict below.
Thank you, Your Honors.
Sources
NC Department of Natural and Cultural Resources, "State v. Mann (A-94)"
NCpedia, "State v. John Mann"
North Carolina History Project, "State v. Mann"
Wikipedia, "North Carolina v. Mann"
Study.com, "History of Slavery in Ancient Times"
Wikipedia, "Slavery in ancient Egypt"
Equal Justice Initiative, "The Transatlantic Slave Trade — Origins"
Encyclopedia Virginia, "The Transatlantic Slave Trade and the Middle Passage"

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