In 1806, the Virginia Supreme Court of Appeals ruled, “In the case of a person visibly appearing to be a negro, the presumption is that he is a slave.” The burden of proof was on them to prove otherwise.19 And that very burden meant that there was nothing they could do, no level of patriotism, no amount of God-fearing godliness, no depth of bravery, no proof of being born in the sweet land of liberty, and no “evidence of time-in-residence … [that] could alter their natural-born state of unfitness.”