## Facts

- John Mann hired Lydia, an enslaved woman owned by Elizabeth Jones, for a one-year term in Chowan County, North Carolina.
- During the hiring period, Mann attempted to punish Lydia for a minor offense.
- Lydia fled; when she did not stop after being called back, Mann shot and wounded her.
- Mann was indicted for assault and battery on Lydia and was found guilty by a jury.
- The trial judge instructed that Mann could be guilty if the punishment was cruel, unwarranted, or disproportionate, emphasizing Mann’s status as hirer rather than owner.
- Mann appealed to the Supreme Court of North Carolina.

## Issues

1. Whether a hirer of an enslaved person may be criminally prosecuted for assault and battery based on allegedly cruel or disproportionate discipline during the hiring term.
2. Whether the common-law immunity from indictment for battery on an enslaved person applied to a hirer with a right to the enslaved person’s labor.

## Decision

- The Supreme Court of North Carolina reversed the conviction and entered judgment for Mann.
- The court held that a master was not indictable for a battery committed upon an enslaved person.
- The court further held that a hirer with the right to the enslaved person’s labor had the same means of control as the owner and therefore was not indictable for battery committed during the hiring term.
- The court stated that any remedy for injury affecting the enslaved person’s value lay in the owner’s civil action for damages, not a criminal prosecution by the State.

## Legal Principles

- At common law, criminal indictment for battery did not lie against a master for violence against an enslaved person, except as limited by statute.
- A hirer entitled to an enslaved person’s labor possessed the same authority to control the enslaved person’s conduct as the owner during the term of hire.
- Courts would not submit the measure of a master’s disciplinary authority to criminal adjudication based on proportionality or cruelty, absent legislative restriction.
- Injuries to an enslaved person that diminished market value could support a civil damages claim by the owner against the hirer under bailment principles, but this did not create criminal liability.

## Conclusion

The court treated the disciplining authority over an enslaved person as legally absolute for criminal-law purposes, extending immunity from assault-and-battery indictment to both owners and hirers during a term of hire, while leaving only limited statutory constraints and the owner’s civil damages remedy for loss of value.


State v. Mann, 13 N.C. 263 (N.C. 1829)