Chapter 5 Seduction suits and gendered adulthood in the civil court systems of the early United States, 1820–50

Early American definitions of gendered adulthood

The identities of ‘adult’ and ‘child’ have always been strategically ascribed to some Americans and kept from others. In 1828, the same year that Elizabeth wrote her letters to Edmund, Noah Webster’s American Dictionary of the English Language defined an ‘adult’ as ‘a person grown to full size and strength, or to the years of manhood … a person between fourteen and twenty-five years of age’.⁷ Defining adult status by chronological age as well as physical traits and abilities still made sense to early Americans, even as the concept of independence firmly worked its way into newer definitions of adulthood.

Prior to the American Revolution, dependence was a fact of life for colonists. From marriage to monarchy, dependence and power were defined and balanced through mutual obligation in all relationships. For example, the relationship between the king and a male British subject was one of dependence; so was the relationship between a trades master and his apprentice. It was not until the Declaration of Independence that ‘the meaning of dependence shifted … [and] ceased to be a construct with positive connotations’. It was only over the course of the last two decades of the eighteenth century that the concept of dependence became ‘highly gendered’, ‘feminized’ and ‘imbued with a sense of powerlessness’.⁸

As American legislators redefined the cultural and social meanings of dependence, they also leaned into the use of age to define legal independence. As independence became equated with adulthood which became equated with age, it seemed Americans might solve some of the problems associated with monarchy. But it could not be so simple as ‘turning dependent subjects into republican citizens’.⁹ The reality of America’s racialised and gendered social hierarchies required thoughtful qualifiers to define who was allowed to hold full adult status and what that status meant. Although property ownership was initially required to vote, this requirement was dropped in the first decades of the nineteenth century. As a result, full legal adulthood became available to any white male over the age of twenty-one.¹⁰

Comparatively, unmarried ‘adult’ women were expected to remain socially, physically and financially dependent upon male family members. The first American legislatures did little to facilitate a change in these expectations. Historian Jacqueline Beatty notes that the law of the early United States ‘recognized women’s personhood, and, to a certain degree, their citizenship, but it also presumed their dependence, which codified them as legally vulnerable and passive’.¹¹ This expectation that women were either in a state of dependence or actively trying to move back into one served as justification for denying women the right to vote. For many women of the working or lower classes, adult status meant more risk than reward. Some scholars have even argued that ‘legal independence for young single women in the nineteenth century often meant greater vulnerability to sexual predation’.¹²

In most states, girls reached legal adulthood before their brothers. In theory, these gendered age differences reflected an expectation that girls reached puberty two to three years earlier than boys. Early American lawmakers reasoned that because girls could theoretically reproduce at younger ages than boys, this meant that they should be ready for marriage at earlier ages as well. However, as historian Nicholas L. Syrett argues, the lower age of consent for women also ‘served to move girls more smoothly as dependents between different men’s households and to ensure that a male head of household always governed their property’.¹³ American daughters were expected to marry at the age of legal adulthood and be subsumed under their husband’s identity, transformed back into dependants akin to children.

Once a woman married, her wealth and any property she owned became her husband’s and her independent legal identity ceased to exist. This was because of the English common-law practice of coverture, a legal doctrine that the United States maintained after its break from Great Britain. Coverture meant that once a woman married, her legal existence was merged with that of her husband’s. Coverture also meant that it was illegal for a married woman to enter contracts, own her own property, make a will, be sued, sue others, press charges on her own or be a witness in court. American women, regardless of race or class, were never intended to attain social and legal independence, the cornerstone concepts of full adulthood in the early United States.¹⁴

American ‘adult’ daughters were expected to remain at home as dependants (and servants) of their families until their inevitable marriage. Veiled as gendered protection, a more accurate representation of the relationship that existed between unmarried adult daughters and their families was economic and legal interdependence. This was especially true for those who came from lower- and working-class backgrounds. Elite parents might have expected deference, largely because of their continued financial and social support, but they did not depend on their children for labour or income the way that lower-class families did. The influence of gender on adulthood and legal independence can be best seen in the labour arrangements of lower-class families.¹⁵ More specifically, when a family actually lost something if they recognised a daughter’s legal adulthood, we see the clearest examples of challenges to the laws that defined independence by age.

Even as the experience and understanding of work and labour changed over the course of the nineteenth century, the traditional expectation that children’s labour would contribute to the household’s productivity continued seamlessly after the American Revolution.¹⁶ This was particularly true for families that did not rely on wage-based work arrangements in addition to many families who did work for wages but still relied on family labour to maintain the household. Legally, fathers had the right to benefit from their children’s labour, male or female, until their child turned eighteen or twenty-one.¹⁷ However, culturally, many families expected this arrangement to continue so long as their child was unmarried and dependent in some way on the household for survival. Daughters suffered this reality exponentially more than sons, indicating that gender and marital status rather than legal adulthood influenced how families defined extended dependence and servitude.

Evidence of how common it was for working- and lower-class daughters to maintain at least a façade of extended dependence can be found in seduction suits and loss-of-service cases tried and appealed in the first half of the nineteenth century. Courts allowed these cases to be heard even though the women involved were legal adults. This is significant because it demonstrates how culturally pervasive this idea of perpetual female dependence was. By looking at a small sample of appealed seduction suits, important insight is gained into how working-class families strategically ignored the significance of their female members’ legal adulthood. Additionally, these cases reveal the struggle jurors and justices experienced when faced with upholding laws that defined adult status but that also conflicted with communal expectations of perpetual female dependence.

Seduction suits in the early United States

How and why ‘seduction suits’ were filed in the early United States had evolved significantly by the nineteenth century. Over the course of the eighteenth century, rape and bastardy charges became exceedingly difficult to press and prove in American courts.¹⁸ Families living in the early United States needed a way to secure redress for the social and sexual harm done to their unmarried, and now non-virginal, female members. Over time, with the help of ‘inventive lawyering’, the seduction suit became a form of civil action that families could pursue when the criminal courts failed them.¹⁹

The five seduction suits to be discussed revolved around a presumed dependent relationship. It is important to remember that being defined as someone’s child or dependant did not make them a child, even if a family attempted to portray them as such. Based on chronological age, each woman to be discussed was a legally independent adult. But, because these women were unmarried, their families viewed and claimed them as dependants. The testimonies and rulings found in these suits shed light on how white families negotiated evolving legal definitions of adulthood against cultural realities of female dependence and marital status in the early United States.

The 1822 Pennsylvania appellate case Hornketh v. Barr offers a straightforward example of how seduction suits in the early United States generally worked.²⁰ According to trial records, sometime in 1816, with his consent, Hugh Barr’s younger daughter moved to Philadelphia to work and to live with her older, married sister. While in Philadelphia and before she turned twenty-one, ‘the seduction and confinement of [Barr’s] daughter took place’. The defence appealed the case and argued that because Barr’s daughter lived with her sister, technically her sister was her master. This meant that the sister should be the one to sue for a loss of service, not the father. However, as the initial court as well as the appeals court ruled, because the girl was a minor, ‘the father could command the services of his child at any time. Therefore, during her pregnancy and confinement, he lost, because he could not have had her services if he had required them’. Consequently, Barr won the case.

The two factors that made the ruling in Hornketh v. Barr so clear cut were that Hugh Barr’s daughter was under the age of twenty-one and that he was her ‘natural’ father. But not all seduction and loss-of-service cases were like this. This chapter concludes by analysing four additional court cases, two in Pennsylvania and two in North Carolina, to explore how some American families negotiated legal definitions of adulthood against cultural realities of female dependence in the early United States. It is important to note that this micro case study is meant to be illustrative and evocative, not reflective or representative of all American families’ experiences at the time.

Each state in the United States defined adulthood by age; and in each case to be discussed, the ‘seduced’ was a legal adult by that measure. It would seem, then, that all four cases should be straightforward; because the ‘seduced’ were legal adults, there should have been no case. And yet these four cases were all tried, indicating that early American court systems recognised adulthood as a more fluid status, one that was informed by gender, race, class and status rather than strictly chronological age.

The seduction suit Logan v. Murray, filed in 1820 Pennsylvania, first began as a rape case heard in Westmoreland County. James Murray was accused of sexually assaulting and impregnating Sarah Logan on the night of 16 September 1815. According to the testimony, Sarah ‘was above the age of twenty-one years’ when the rape occurred but she was unmarried and still resided with her parents. Her father had died on 28 November that same year, after which Sarah continued to live with her mother ‘who became the head of the family’. The baby was born on 2 June 1816, forty weeks after the rape. Margaret insisted that after the birth, Sarah ‘was never well’ again.

In January 1817, Sarah passed away, leaving behind a child that her mother was now forced to raise.²¹ It took nearly three years, but Margaret, Sarah’s mother, managed to file a seduction suit against Murray in 1820. Margaret argued that the pregnancy, caused by James Murray’s sexual assault, resulted in Sarah’s death. Because Sarah never left her parents’ household, her ‘lying in’ and death deprived Margaret of her daughter’s labour. Margaret wanted to be financially compensated for this loss.

The outcome of Logan v. Murray is not surprising: Margaret lost her case due to Sarah’s age at the time of her pregnancy. Sarah had been a legal adult, and the court was quick to point this out. Despite Sarah’s legal independence, Margaret insisted that Sarah never transitioned into social adulthood and remained a dependent daughter. More than likely, Sarah had an interdependent relationship with her parents as she continued to live and work in the family home after ageing into adulthood. The court suggested it would have considered the argument more seriously had the Logan patriarch not died. As justices explained, usually ‘the slightest evidence of service is sufficient, where the daughter resides with the parent, and has arrived at years of maturity’. That assumed dependency did not transfer to Sarah’s mother once her father died. Instead, when her mother took on Sarah’s dependence, she was already pregnant and thus, the court argued, Margaret had knowingly acquired that risk.

In September 1831, Robert Sproul filed a seduction suit in Pennsylvania against John Wilson for impregnating his sister-in-law, Polly Porter. Polly had given birth in the Sproul home in November 1826 when she was twenty-eight years old. Like Sarah, Polly was unmarried and had aged into her legal independence. However, by the time of the trial, both Polly’s parents had died, which severed her ability to claim she was a dependent daughter, still living and working at home. Instead, Polly leaned into her reality, even as she left out critical details about her life.

Under oath, Polly admitted that she had lived with the Sprouls since she was about twenty years old. Polly’s sister and her husband Robert had opened their home to her in exchange for ‘weaving’ and other work around the household. Based on these informal exchanges, Robert argued that Polly was his servant. Once Polly gave birth in the Sproul home, he argued that she also became his dependant as ‘she was nursed by his wife … for two weeks and worked but little for four weeks’.²²

Jurors found Robert Sproul’s initial argument convincing, perhaps thinking about their own family dynamics and who they considered dependants within their own households. However, John Wilson appealed the verdict and won. In the new ruling, justices agreed that biological parents were not the only family members who could sue for a loss of service. However, ‘in such cases, the child must be underage, and actually employed in the service of the plaintiff’. Neighbours had confirmed that Polly came and went from the Sproul household and that when she did stay for extended lengths of time, she paid Robert as a boarder. At one point, Robert even owed her money. Consequently, justices ultimately dismissed the suit against John Wilson because ‘the seduced was twenty-eight years of age … and was in every respect her own mistress’.²³

To the community, Polly lived and earned as an independent adult woman. And yet, Polly and Robert filed a seduction suit as if she were a dependent daughter-like figure in his household. More importantly, they had at least initially convinced others of this argument. It’s important to remember that Robert Sproul was not a father, an uncle or even a biological brother to Polly. But because he was related to her by law and she had a history of living in his household, the case moved forward despite law and logic. This is significant to note because it indicates how deeply embedded the belief that regardless of age, if a woman was unmarried, society assumed she was some household’s childlike dependant.

In the first seduction suit discussed, Hornketh v. Barr, Hugh Barr quickly won his case because he was the dependant’s father, and because the dependant was still legally a child. In comparison, Margaret Logan and Robert Sproul lost their cases because the dependants they claimed were legally independent, adult women. The fact that Logan and Sproul were not fathers further weakened their suits. However, the last two seduction suits to be discussed, Phipps v. Garland and Briggs v. Evans, were a bit more complicated. Both Phipps and Briggs were the fathers of those they filed suits for; however, in each case the daughter was a legal adult. The communities in which they each lived clearly expected unmarried women to live in perpetual dependence, deference and servitude to their families. Concluding with these cases underscores how arbitrary age and law were in defining independent adulthood in the early United States.

On an autumn day in 1837 in Yancy County, North Carolina, thirty-year-old single mother Jane Phipps testified about where she had lived and worked prior to her pregnancy.²⁴ Jane swore that ‘her father’s house was her home; her bed and furniture and all her other property, except some clothing, remained there’. However, ‘with her father’s consent’, she had worked and lived in the Garland household for the past several years as a ‘hireling’. While working for the Garland family, Jane regularly moved between the two households, and when she returned to her father’s home, she ‘performed the ordinary duties in his family of washing, cooking, and milking’.²⁵

Jane’s testimony was carefully worded; she made clear that despite being a legal adult, she deferred to her father, Jacob Phipps, for consent on life choices and considered his house as her home. Jane described herself as a dependent daughter because like Elizabeth Ruffin mentioned at the start, legal independence offered little to Jane as an unmarried woman. Had she acknowledged herself as an independent adult, Jacob Phipps’s seduction suit would have had no chance of moving forward.

Jacob Phipps filed the seduction suit against his grandchild’s father, John W. Garland, in 1837. In the original trial, the jury found in favour of Phipps; however, Garland won the appeal. Familial and legal interpretations of father–daughter relationships were clearly at odds with one another in this North Carolina community. The initial trial was ruled upon by a jury, or members of the community that Phipps and Garland lived in. Made up of similarly aged and life-staged men, jurors likely took into consideration their own family circumstances. Although their children legally became independent adults once they turned twenty-one, they often remained at least semi-dependent beyond that age. Recognising that the transition into full adulthood was more fluid and conditional on other factors besides age, jurors may have been swayed to overlook the law in favour of supporting Phipps.

However, the appeals case was ruled upon by justices who were more interested in adhering strictly to the law. Justices argued in the final case that because ‘the daughter was of full age and did not live with her father at the date of the debauchery’, there was ‘no legal obligation on the father to maintain and take care of her’. In other words, Jacob Phipps chose to take his daughter back into his household when he no longer had a legal obligation to do so. Consequently, Phipps had no right to sue John Garland for loss of service.

Lewis Briggs filed a writ of seduction in 1842 against John J. Evans for a loss of service due to the pregnancy of his daughter, Rosanna.²⁶ In September 1841, when the seduction was alleged to have occurred, Rosanna was twenty years old and living with her grandmother. One month after conception, she turned twenty-one. Jurors were meant to determine what right Lewis Briggs had to sue for a loss of service given that Rosanna was in her minority at the time of conception but an adult for most of the pregnancy and the subsequent birth.

The trial judge recognised the uniqueness of the case and broke the decision down for jurors based on the father–child relationship and the master–servant relationship. First, the judge instructed the jury to decide whether Lewis Briggs as Rosanna’s father had lost any services because of the pregnancy before she had turned twenty-one. Then, the jury was to decide whether he had lost any services as her master after Rosanna became a legal adult. Once these two aspects of the case were determined, the jury could then ‘take into their consideration the anguish and disgrace brought upon the plaintiff and his family, in order to enhance the damages’.²⁷

The jury found for Lewis Briggs. John Evans appealed the case, and it made its way to the state Supreme Court where justices upheld the original verdict. John Evans argued that Lewis Briggs could not sue for loss of services ‘without proof of an actual contract for services after the daughter became of age’. Justices disagreed, arguing that because it was clear that she lived with her family and provided services at the time of the seduction, an assumed master–servant relationship existed. Justices explained:

Before the child attains the age of twenty-one years, the law gives the father dominion over her, and, after, the law presumes the contract, when the daughter is so situated, as to render services to the father, or is under his control; and this it does for the wisest and most benevolent purposes, to preserve his domestic peace, by guarding from the spoiler, the purity and innocence of his child. If this were not so, in those cases … the unfortunate parent would be without redress if his daughter were over twenty-one years of age.²⁸

The assertion that a legally recognised master–servant relationship was not dependent on a contract was surprising. Setting the pregnancy aspect aside, had Rosanna been a man, a court would never have considered the case. The age of twenty-one meant full legal independence for sons, but, as this suit clearly shows, it only sometimes meant that for daughters.

All four cases revolved around the issue of lost service due to pregnancy; however, in none of the cases was the unmarried woman in question under the age of twenty-one or a contracted servant. Even as they were all legally recognised as independent adults due to their chronological age, the fact that these women were unmarried was precisely what caused their families and communities to view them as dependants. A murder case, The People v. Matthew Wood, provides another example of this presumption. In 1849 in New York, Matthew Wood was found guilty of murdering his wife of two years, Susan. Susan’s brother took the stand and explained how the pair met, describing Susan as a ‘girl’ who was ‘enticed away’ by Matthew. However, the court record also specified that Susan was ‘forty-two years of age’ at the time of their marriage.²⁹ Clearly, for many families and the communities they lived in, one’s marital status and gender was more important than one’s chronological age in determining a person’s status in life. Women could be well over the age of legal adulthood, yet if they were unmarried, they were still considered a childlike dependant who owed deference and service to their families.

Although each of the seduction suits discussed ultimately failed, the testimonies captured in the trial records give insight into how adulthood was defined in the early United States. Both sides often moved their definitions of adulthood away from age and towards a person’s other forms of identity, like gender or race, to win their cases. Prosecution and defence alike alternated between the terms adult and independent or dependant and child. This intentional word slippage was more than just a legal strategy; these negotiations over who was a child, who was an adult and when age mattered reflected and informed wider debates about the evolving definitions of adulthood in the early United States.

Conclusion

Edmund Ruffin never responded to Elizabeth’s ‘peculiar request’. It turns out he did not need to as just a few months later, Elizabeth slipped comfortably into the role of wife, losing her legal independence and identity altogether. No longer needing to be protected by her brother, Elizabeth lived out the rest of her life legally ‘covered’ by her husband. For many women, like Elizabeth Ruffin, dependency was so embedded into their understanding of self that age meant nothing to them. This was because white American females lived in a liminal state between childhood and adulthood. Their bodies changed and aged even as their status never truly did. Should their guardians deem it necessary, girls could be ‘adult’ enough to bear and raise children as young as ten or twelve.³⁰ Once ‘women’, they could just as easily be transformed back into symbolic children who were assumed to be perpetually dependent upon someone – whether family or husband.

And yet, so long as a woman remained unmarried, the law insisted they were legal adults, capable of business transactions and informed consent. Early Americans reconciled these opposing concepts strategically; contradictions were ignored when convenient and deeply acknowledged when it was necessary. Adulthood in the early United States, then, was not a static category of being. Just like childhood, it was a murky, sometimes age-defined status. The concept of adulthood, in general, was manipulated by early Americans to best protect themselves and their family members. However, those who were white, female and unmarried seemed to have been able to move in and out of these two life-stage statuses most easily. The filing of seduction suits offers a clear example of just that as white families increasingly used these suits to benefit their sexually wronged, unmarried, female members.

Notes

1. 1. Elizabeth Ruffin to Edmund Ruffin, 18 February 1828, ‘Edmund Ruffin Papers’, Southern Historical Collections, Richmond, Virginia, United States. The Ruffin family were members of Virginia’s planter aristocratic class; they owned large swathes of land and financially benefited from the enslavement of hundreds of Black Virginians.

2. 2. Elizabeth Ruffin to Edmund Ruffin, undated letter, ‘Edmund Ruffin Papers’, Southern Historical Collections, Richmond, Virginia, United States. The letter had to have occurred sometime shortly after the first letter written on 18 February 1828 as Elizabeth was married later that same year.

3. 3. Corinne T. Field, The Struggle for Equal Adulthood: Gender, Race, Age, and the Fight for Citizenship in Antebellum America (Chapel Hill, NC: University of North Carolina Press, 2014), 52–3. Women in the United States were not guaranteed the right to vote until the 19th Amendment was passed by Congress on 4 June 1919 and ratified on 18 August 1920.

4. 4. There is a long history of scholarship on female (in)dependence in the early United States. For two of the most recent works, see Jacqueline Beatty, In Dependence: Women and the Patriarchal State in Revolutionary America (New York: New York University Press, 2023); Mary Sarah Bilder, Female Genius: Eliza Harriot and George Washington at the Dawn of the Constitution (Charlottesville, VA: University of Virginia Press, 2022).

5. 5. See Ariela J. Gross, What Blood Won’t Tell: A History of Race on Trial in the Early United States (Cambridge, MA: Harvard University Press, 2010); Holly N.S. White, ‘Judging the Bodies of Children: Racial Science and Double Age as Legal Strategy in the Early United States’, Journal of the History of Childhood and Youth, 15, no. 3 (2022), 399–409.

6. 6. John Wood Sweet, The Sewing Girl’s Tale: A Story of Crime and Consequences in Revolutionary America (New York: Henry Holt and Company, 2022), 225.

7. 7. Noah Webster, American Dictionary of the English Language (1828): ‘Adult’.

8. 8. Beatty, In Dependence, 7.

9. 9. Field, The Struggle for Equal Adulthood, 23.

10. 10. Field, The Struggle for Equal Adulthood, 6–7.

11. 11. Beatty, In Dependence, 7.

12. 12. Lea VanderVelde, ‘The Legal Ways of Seduction’, Stanford Law Review, 48, no. 4 (1996), 871.

13. 13. Nicholas L. Syrett, American Child Bride: A History of Minors and Marriage in the United States (Chapel Hill, NC: University of North Carolina Press, 2016), 17.

14. 14. Field, The Struggle for Equal Adulthood; see also Jon Grinspan, The Virgin Vote: How Young Americans Made Democracy Social, Politics Personal, and Voting Popular in the Nineteenth Century (Chapel Hill, NC: University of North Carolina Press, 2016).

15. 15. See Anya Jabour, Scarlett’s Sisters: Young Women in the Old South (Chapel Hill, NC: The University of North Carolina Press, 2007), esp. chapter 3: Single Life.

16. 16. See Frances M. Clarke and Rebecca Jo Plant, Of Age: Boy Soldiers and Military Power in the Civil War Era (Oxford: Oxford University Press, 2023); Mary Ann Mason, From Father’s Property to Children’s Rights: A History of Child Custody (New York: Columbia University Press, 1994); Jeanne Boydston, Home and Work: Housework, Wages, and the Ideology of Labor in the Early Republic (Oxford: Oxford University Press, 1994); Holly Brewer, By Birth or Consent: Children, Law, and the Anglo-American Revolution in Authority (Chapel Hill, NC: University of North Carolina Press, 2007).

17. 17. Frances M. Clarke and Rebecca Jo Plant argue that parental rights, especially regarding their ownership of minor children’s labour, became of special concern to the American public during the War of 1812 through the American Civil War. Because of a need for soldiers, the American government lowered the age of enlistment from twenty-one to eighteen. Parents responded with an onslaught of legal challenges to enlistment contracts of their underaged sons on the grounds that they still owned their labour for three more years. Clarke and Plant argue that these military lawsuits demonstrate ‘the endurance of a communal vision of the household’ and expose ‘parents’ economic reliance on minor children’. Clarke and Plant, Of Age, 19.

18. 18. For changes to bastardy laws in colonial British North America, see John Ruston Pagan, Anne Orthwood’s Bastard: Sex and Law in Early Virginia (Oxford: Oxford University Press, 2001). For changes to rape laws in colonial British North America, see Sharon Block, Rape and Sexual Power in Early America (Chapel Hill, NC: University of North Carolina Press, 2012) and Alexander Smyth, A Rape in the Early Republic: Gender and Legal Culture in an 1806 Virginia Trial (Lexington, KY: University of Kentucky, 2017).

19. 19. For the most recent scholarship on early American seduction suits, see Sweet, The Sewing Girl’s Tale (quote: p. 225). For a thorough legal explanation of seduction suits in the nineteenth century, see VanderVelde, ‘The Legal Ways of Seduction’.

20. 20. Hornketh v. Barr, 8 Serg. & Rawle 36 (1822).

21. 21. Logan v. Murray, 9 A.M. Dec. 422 (1820).

22. 22. Wilson v. Sproul, 3 Pen. & W. 49 (1831). This case is also mentioned in M.B.W. Sinclair, ‘Seduction and the Myth of the Ideal Woman’, Minnesota Journal of Law & Inequality, 5, no. 1 (March 1987), as well as VanderVelde, ‘The Legal Ways of Seduction’.

23. 23. Wilson v. Sproul, 3 Pen. & W. 49 (1831).

24. 24. Trial records do not name Phipps’s daughter. However, based on ancestral records, Phipps’s eldest daughter was born in 1806 and was named Jane. That would have made her about thirty or thirty-one at the time of the trial. Phipps’s next daughter was not born until 1817, making her too young.

25. 25. Jacob Phipps v. John W. Garland, 20 N.C. 38 (1838).

26. 26. Lewis Briggs v. John J. Evans, 27 N.C. 16 (1844). Trial records do not name Briggs’s daughter. However, based on ancestral records, Briggs had a daughter born in 1820 named Rosanna.

27. 27. Lewis Briggs v. John J. Evans, 27 N.C. 16 (1844).

28. 28. Lewis Briggs v. John J. Evans, 27 N.C. 16 (1844).

29. 29. The People v. Matthew Wood, 2 Edm. Sel. Cas. 71 (1849).

30. 30. Syrett, American Child Bride.

References