## Facts

- John Hoover, a slaveholder in North Carolina, was indicted for murdering Mira, an enslaved woman he owned.
- Evidence showed a prolonged course of extreme physical abuse and harsh deprivation, including repeated beatings and whippings and privations of food, clothing, and rest.
- The punishment was described as barbarously excessive in degree, duration, and the means used, and as exceeding any legitimate domestic correction.
- Hoover asserted that Mira had committed serious misconduct (including theft, arson attempts, and attempted poisoning), but the accusations were largely based on a confession extracted under whipping and were not independently substantiated.
- A jury in the Superior Court of Iredell County convicted Hoover of murder; he was sentenced to death and appealed.

## Issues

1. Whether a slaveholder’s killing of an enslaved person through excessive “correction” can constitute murder under North Carolina law.
2. Whether murder required a specific intent to kill, or whether intent to inflict great bodily harm, inferred from the nature and extent of the punishment, sufficed when death resulted.

## Decision

- The Supreme Court of North Carolina affirmed the murder conviction and left the death sentence in place.
- The court held that a master’s disciplinary authority over an enslaved person was not unlimited and did not permit killing.
- The court concluded that when punishment is barbarously excessive and accompanied by severe privations, the law infers malice and a contemplated fatal outcome; if death ensues, the offense is murder.
- The court held that a specific intent to kill is not always required for murder; intent to inflict great bodily harm, inferred from the means and surrounding circumstances, can be sufficient when death results.
- The court did not disturb the trial judge’s instructions on provocation and manslaughter, and treated the jury’s murder verdict as supported by the evidence and the charge.

## Legal Principles

- A master may lawfully punish an enslaved person, but the authority to chastise does not extend to killing; homicide of an enslaved person can constitute murder, including when committed by the owner.
- Death resulting from chastisement administered with an apparent good-faith reformative purpose and without a purpose to endanger life may warrant mitigation depending on the circumstances.
- Where punishment is barbarously immoderate and unreasonable in measure, duration, and instruments, and is accompanied by painful privations, it loses the character of lawful correction; if death follows, the killing is murder.
- Murder can be proved without a specific intent to kill when the defendant intended great bodily harm, as inferred from the nature of the means used and other circumstances, and death ensues.
- When the jury is instructed on provocation and cooling time, a murder verdict may stand where the evidence supports malice and the jury rejects or finds insufficient the alleged provocation.

## Conclusion

The court affirmed Hoover’s murder conviction, holding that a slaveholder’s prolonged, barbarously excessive punishment and deprivation leading to an enslaved person’s death supports an inference of malice and satisfies the mens rea for murder even without proof of a specific intent to kill.


State v. Hoover, 20 N.C. 500 (N.C. 1839)