Opening (0:00–0:30)
"Your Honors, the question before this Court is narrow and purely legal: does North Carolina law permit a criminal indictment for battery against a person who has lawfully hired a slave's labor, for conduct occurring during that hiring? The trial court answered yes. We ask this Court to reverse, on four independent legal grounds."
Point 1 — Precedent doesn't support the conviction (0:30–1:15)
"First, precedent. The trial court relied on State v. Hall, 9 N.C. 582 (1823), but Hall addressed a stranger — someone with no legal relationship to the slave at all. My client is not a stranger. He is the lawful hirer, holding a possessory interest transferred to him by contract. Hall is distinguishable, not controlling. No existing North Carolina precedent extends criminal liability to a hirer acting within the scope of that hire."
Point 2 — Property and bailment law govern this case (1:15–2:00)
"Second, this is fundamentally a property-law question. A contract of hire transfers the right to a slave's labor. The right to compel that labor — the right of control — necessarily transfers with it. This is basic bailment doctrine: whoever lawfully possesses property for a term holds the same rights of control as the owner, for that term. The trial court's jury instruction, asking the jury to weigh a 'special property' interest as somehow lesser, has no basis in existing property law. There's no such intermediate category recognized by this Court."
Point 3 — No statute criminalizes this conduct (2:00–2:45)
"Third — and this is the most important point — the General Assembly has never criminalized this conduct. The legislature has comprehensively regulated slavery in this state: passes for movement, licenses for firearms, procedures for capture of runaways, even a summary whipping procedure for magistrates. It has specifically criminalized one thing beyond question: the killing of a slave. That is the only statutory limit on a master's or hirer's authority. Where the legislature regulates extensively and stops at a specific line, that stopping point is deliberate, not an invitation for courts to draw a new one. This Court is not a legislature. It cannot create a new criminal offense that the General Assembly chose not to enact."
Point 4 — The trial court's jury instruction was legal error (2:45–3:30)
"Fourth, the instruction given below asked the jury to determine whether the punishment was 'proportionate' to the offense. That standard doesn't exist anywhere in this state's statutes or case law. It was invented for this trial. Asking twelve jurors to retroactively judge reasonableness, with no defined standard, is void for vagueness as applied here — the defendant had no way to know in advance what 'proportionate' meant, or how a jury would later measure it. A criminal conviction cannot rest on a standard that didn't exist until the moment it was applied against my client."
Closing (3:30–4:00)
"To summarize: no controlling precedent, correct application of settled bailment doctrine, no statute defines this as a crime, and the jury instruction below was legally unsound. This Court should reverse the conviction and vacate the ten-dollar fine. The remedy for any dispute over Mann's conduct toward Lydia, if one exists, lies in a civil action by her owner for damage to her value — not in a criminal indictment unsupported by any existing law. We ask this Court to reverse."
Delivery tip: Practice this once aloud with a timer — legal argument reads faster than casual speech, so you may find you have 15–20 seconds of slack per section to add a supporting citation (e.g., naming 13 N.C. 263 or the "must stop short of taking life" line) if your professor wants pin cites spoken aloud.
