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Slaves were legally considered non-persons unless they committed a crime. An Alabama court ruled that slaves “are rational beings, they are capable of committing crimes; and in reference to acts which are crimes, are regarded as persons. Because they are slaves, they are incapable of performing civil acts, and, in reference to all such, they are things, not persons.

https://en.wikipedia.org/wiki/Treatment_of_slaves_in_the_United_States

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