State v. John Hoover
North Carolina Supreme Court
20 N.C. 500 (1839)
- Written by Jenny Perry, JD
Facts
John Hoover (defendant) killed his slave Mira. Witnesses at Hoover’s trial testified to a series of brutal whippings and privations inflicted by Hoover over a period of four months during which Mira was in the latter stages of pregnancy and recovering from childbirth. A physician who examined Mira’s body testified that there were five wounds on her head, four of which were inflicted a week or more before she died. The last wound was fresh, and there were multiple injuries to Mira’s body that were sufficient to have caused her death independent of the head trauma. Hoover claimed to those who witnessed his barbarous treatment of Mira that she had stolen his turnips and sold them to worthless people in the neighborhood, had attempted to burn his barn, and was disobedient to her mistress. Hoover also claimed that Mira attempted to burn his still house and tried to poison his family. However, the only evidence of any such conduct was Mira’s confession, which Hoover had extorted by whipping her. Witnesses testified that Mira did her best to obey the commands of her master. The trial judge instructed the jury that to convict Hoover it must be satisfied that Hoover intended to kill Mira and had no legal provocation at the time he killed her. The judge also instructed the jury that attempting to burn Hoover’s barn or disobeying him would constitute an act of legal provocation that would extenuate the offense from murder to manslaughter. The jury convicted Hoover of murder, and Hoover was sentenced to death. He appealed the conviction.
Rule of Law
Issue
Holding and Reasoning (Ruffin, C.J.)
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