By Karla Méndez

*Content Warning: rape, sexual assault, police violence

Examining the case of Joan Little, the first woman to be acquitted of murder due to self-defense against sexual violence.

In Defense of Our Lives: The Self-Determination of Joan Little

Clip from Ann Arbor Sun Newspaper titled, Support Joanne Little. February 28, 1975. Source: Ann Arbor District Library.
The text reads: Joanne Little is a 20-year-old black woman, NEWSWEEK says, "small, shy and black." She sits in a cell at the North Carolina women's prison in Raleigh, charged with the first degree murder of Clarence Alligood, a white jailer who tried to rape her.
Joanne's defense has developed into a national effort, lead by women's and civilrights organizations. Last Week, in Washington D.C., singer Gil Scott-Heron headlined a Joanne Little benefit concert, a group of citizens in the University of North Carolina community at Chapel Hill have pledged their property to free her on bond. The Southern Poverty Law Center, headed by State Senator Julian Bond has begun a big direct-mail campaign seeking money needed to hire defense criminologist and jury-selection experts.
Joanne admits to fatally stabbing the jailer, but only after he threatened her with an ice piek and tried to rape her. The dead jailer Alligood was found in Joanne's cell, naked from the waste down. The autopsy report showed signs of sexual activity just before the jailer's death. It also determined that a wound on his thigh indicated that he was not wearing his trousers during the struggle. Strangely, the autopsy report was not made known to the grand jury that indicted Joanne.
*Locally, a Joanne Little Defense Committee is being organized. You can get further information by writing 1409 Beechwood, Ann Arbor, Mich,.-48103*

Poor, uneducated, and typical of the prison population. These were the metaphorical and stereotypical scarlet letters that Joan Little (pronounced "Jo Ann") was forced to endure when tried and charged for the murder of White prison guard Clarence Alligood. On August 15th, 1975, Little was acquitted of the murder of Alligood, a prison guard at the Beaufort County Jail in Washington, North Carolina who had raped her in her cell. Her acquittal came after a five-week trial during which Little recounted to a jury of six Black Americans and six White Americans the horrors of the treatment Alligood had subjected her. Little was the first woman to be acquitted of murder due to self-defense against sexual violence. The trial led to a nationwide examination of prisoners’ rights, specifically Black women prisoners, the death penalty, the criminal justice system, and a woman’s right to self-defense against rape and sexual assault.

“Escape Artist”

Little was born in 1953 in Washington, North Carolina. The oldest of six children, with four half-siblings, she often had to take care of her younger siblings, a responsibility that led to a habit of running away. She began to hang out with an older group and it was her association with them that led to additional dissent. Little took on odd jobs as a teenager, including working as a waitress and in the tobacco industry. It was in 1968 after her mother asked a judge to formally classify her as a truant and commit her to the Dobbs Farm Training School in Kinston, North Carolina, when Little began to have run-ins with the law. She ran away and hitchhiked back to Washington. Her mother then sent her to live in Philadelphia with relatives.

Between December 1973 and January 1974, Little was arrested multiple times, each time leading to more severe legal consequences. It was after her last arrest for which she was charged with three separate counts of breaking and entering and larceny that she was imprisoned and a trial set. After she was convicted on June 4th, 1974, Little asked if she could remain in the county jail, where Alligood was the jailer, instead of being transferred to the Correctional Facility for Women in Raleigh. For the next three months, Little was held there, where she waited for her trial and worked on raising her bond. On August 27th, 1974, a police officer arrived at the county jail with a prisoner and happened upon Alligood, who had multiple stab wounds. Missing was Little.

Relying on Tired Stereotypes

During the trial, prosecutors relied on the tried and true practice of stereotyping and sexualizing Black women, with Prosecutor William Griffin alleging that Little had seduced Alligood with the promise of sex and once inside, she killed him so she could escape. Griffin’s claim reflects the belief of many townspeople in Beaufort and Pitt counties, that Black women were more vulgar than White women, and Black people more violent than White. Furthermore, utilizing this argument highlights how the continued sexualization of Black women is rooted in racism that began when Europeans first traveled to Africa. In their interactions with Africans, they were both engrossed and horrified by how they dressed, the minimal amount of clothing they wore, their practice of polygamy, and their “suggestive” tribal dances. This led Europeans to proclaim that they were sexually lewd, solely based on their incomprehension of traditional African culture. From these initial exchanges and the writings of William Smith, who wrote that “African women were “hot constitution' d Ladies” who “are continually contriving stratagems how to gain a lover”, grew the stereotype of Black women being inherently deviant and sexually promiscuous.

These stereotypes continued into enslavement and shaped society’s perception and treatment of Black women’s sexuality. The erroneous idea that Black women had an insatiable appetite for sex was used as justification for the rape of enslaved Black women and as a result were consistently pregnant. Further, it had the added effect of producing additional people to enslave and contribute to a terrorizing labor system. Because of these institutional beliefs, until the 1960s, it was rare for Southern White men to be convicted of rape, despite the fact that it was a common crime. However, by categorizing it as a crime committed against Black women, there’s an insinuation that they were afforded the same protection as White women, particularly because for so long enslaved people were considered property.

"He said he had been nice to me, and it was time I was nice to him. I told him I didn't feel like I should be nice to him that way”, Little recalled in her witness testimony. Her statement foregrounds the expectation that any seemingly kind gesture by a man, particularly a White man, expressed to Black women entitles them to the bodies of Black women. It highlights the deep-seated belief in American society that the bodies of Black women do not belong to them and are in fact, not bodies but receptacles used for the needs and wants of others.

Joan Little is shown in the Wake County Courthouse August 2, 1975 getting off an elevator where Little was on trial for the 1974 stabbing death of one of her jailers. Photo Source: Washington Area Spark.

“Joan Little was the first woman to be acquitted of murder due to self-defense against sexual violence. The trial led to a nationwide examination of prisoners’ rights, specifically Black women prisoners, the death penalty, the criminal justice system, and a woman’s right to self-defense against rape and sexual assault.”

Using Respectability Politics to Attack Black Women

By continuously attacking Little’s respectability and credibility, Griffith points to the concept of respectability politics to which Black women are firmly, and unfairly, held. Respectability politics, coined by Evelyn Brooks Higginbotham in her 1993 book, Righteous Discontent: The Women’s Movement in the Black Baptist Church, 1880–1920, refers to the idea that the closer in proximity to Whiteness, that is the more they behave or appear to be like the dominant group in society, the more respected and valued they will be. Growing up, Little was labeled as unruly and a delinquent, characterizations that followed her into young adulthood. Utilizing respectability politics to justify Little’s arrests and trial also placed her in comparison to Black American women who were viewed as reputable and respectable, like Rosa Parks. In a similar way to young women like Claudette Colvin and Mary Louise Smith who refused to give up their seats on buses before Parks, yet were pushed to the side because they and their experiences were viewed as indecent and because they were dark-skinned, which points to colorism that pervades in Black communities.

These types of expectations place the blame on the victims, absolving the systems that uphold these ideologies. In the case against Little, this was exemplified by those who were not in support of her suggesting that no respectable woman would have been in jail in the first place, ignoring that Black women are overwhelmingly policed and punished. Though they make-up 13 percent of the U.S. population, they represent 30% of the women’s prison population and 44% of women in jail.

A black-and-white paper poster created by the Joanne Little Defense Fund in support of Joan (Jo-Ann) Little. 1974-1975. Durham, North Carolina. Collection of the Smithsonian National Museum of African American History and Culture.

Do Incarcerated Persons Have Rights?

Little’s time in the Beaufort County Jail also brings up concerns and questions regarding the lack of rights afforded to women prisoners. Imprisoned in a jail that had no women’s facilities, Little was also the only woman in a cell block that had TV monitors in the cells of women, limiting the little privacy they would otherwise be permitted. This kind of unlimited access to women in jail was further compounded by and aided in the sexual advances and assaults inflicted on them by White male prison guards. They would leverage the promise of special privileges in exchange for sexual services. The night that Alligood was killed, he had come into Little’s cell to “collect his debt.”

Like Angela Davis’ trial two years prior in 1972 for kidnapping, homicide, and accomplice to conspiracy during which she received support from Black writers who organized the Black People In Defense of Angela Davis committee, Little’s case and trial were met with support from Davis, Rosa Parks, Bernice Johnson Reagon, Katherine Galloway, and the Black Panther Party. Parks was a co-founder of the Joanne Little Defense Committee in Detroit, Michigan, whose mission statement asserted the right of women to defend themselves against sexual assault and was also concerned with addressing the interlinked issues of poverty and criminal defense. Previously, Parks spearheaded the investigation of the rape of Recy Taylor, a 24-year-old Black mother and sharecropper, who, while walking home from church, was abducted and gang-raped by six White men in Abbeville, Alabama in 1944.

Davis spoke out in support of Little, writing an essay The Dialectics of Rape, which recounted Little’s assault, connecting her experience to that of Cordella Stevenson, a Black American woman sexually assaulted and lynched by a mob of White men in Columbus Mississippi in 1915. She wrote that in our white superiority and male supremacy-obsessed society, being a Black woman means being raped and murdered with absolute impunity. Little’s case was one in a long history of a court system that punishes its victims and was sentencing more political activists than any other state. In her article, Davis points out that as she was writing it, in North Carolina, where Little was being tried, there were 71 prisoners on death row, making the state the number one in convicting people to legal death. Had Little been found guilty, she would have been the third woman in the U.S. sentenced to death since the Supreme Court decided in their 1972 Furman v. Georgia ruling that the death penalty in three previous cases was unconstitutional.

“In today’s context, Little’s case can be placed at the intersections of the #MeToo movement, #SayHerName, and Black Lives Matter, calling attention to the correlation between protection from sexual assault and other societal issues that significantly impact Black women, including healthcare, reproductive justice, a living wage, and racially biased policing and imprisonment.”

Systems and Structures

Davis also wrote that the other two women who were on death row at the same time as Little were also in North Carolina, a Black woman, and an Indigenous woman. This is crucial to note as it highlights how Black women and women and women of color were more likely to not only be arrested but face the death penalty for a crime that was committed in self-defense. In her testimony, Little challenged Griffin’s assertion that she had lured Alligood into her cell with sex in order to kill him and escape. She maintained that on the night of his death between 10 pm and 3 am, Alligood had come to her cell three times, bringing cigarettes and sandwiches after being turned down the first time. When Little once again rebuffed him, he returned a third time, intent on receiving sexual favors for the “gifts” he had brought her earlier.

Little testified about the acts that he forced her to participate in and it was during this that she noticed Alligood had been clutching an ice pick. It is crucial to question why Alligood, a man who weighed 200 pounds, making him twice the size of Little, had brought an ice pick with him. Either he feared for his safety, which if he had, why was he entering her cell or he was intending to use it to threaten her. Testimony accounts indicate that once she had seized the ice pick, she fought for her safety. After fatally stabbing the jailer in the temple and heart, she ran and went into hiding for a week, turning herself in after learning that police had been instructed to kill her on-site. When asked why she ran, Little said, “I ran because it was self-defense…[I]f the authorities there [in Beaufort County] had gotten to me before any other body, … I never would have been here to tell what really happened.”

Not only was the prosecution attempting to paint Little as a promiscuous woman and calculated woman, but from the start the state’s handling of the crime scene and trial sought to discredit her and any potential testimonial in her defense. A grand jury indicted her with a first-degree murder charge despite the lack of a medical examiner’s report and testimony from the medical examiner who would be able to testify that when he was killed, Alligood was sexually assaulting Little. By charging her with first-degree murder, the grand jury was almost certainly co-signing her to the gas chamber were she to be found guilty. Furthermore, any evidence that was present in the cell was cleaned up before the arrival of the State Bureau of Investigation. Speaking about her case, Little stated, “My life is not in the hands of the courts. My life is in the hands of the people.”

Left: Joan Little on the cover of Jet magazine, with the title that reads, “Joan Little Fights To Avoid Death Sentence.” May 8, 1975. Photo Source: Wolfgangs. Right: Free Joanne Little poster. Wilfred Owen Brigade, 1975. Library of Congress Prints and Photographs Division.

Free Joan Little in Today’s Context

In today’s context, Little’s case can be placed at the intersections of the #MeToo movement, #SayHerName, and Black Lives Matter, calling attention to the correlation between protection from sexual assault and other societal issues that significantly impact Black women, including healthcare, reproductive justice, a living wage, and racially biased policing and imprisonment.

In the time that has passed since Little’s case 48 years ago, young Black girls and women who are victims and survivors of sexual assault are still treated as criminals and dehumanized when they attempt to defend themselves. Not only is their youth taken from them when they are assaulted, but they are put through an adultification process during trials that foreground juvenile indiscretions, their “non-traditional” upbringing, and utilizes their gender to discredit them in their attempt to hold their perpetrators responsible. With Black women still being disproportionately incarcerated, there needs to be a continued effort at dismantling the structures and systems that place them on this conveyor belt that leads to prison.

If there is anything we can learn from Little’s case, it is that prison abolition needs to be at the forefront of these efforts as it goes beyond blaming the victim and placing a band-aid on the deep-seated issues of society. Abolition is concerned with and places a value on the people whom our society seeks to put away, if only because it is easier. We need to question why we have for so long been complacent with the idea of tossing people away instead of providing them with the help, mental and physical, that they deserve.

About the author: Karla Méndez is an arts and culture writer. She is a lead columnist for Black Women Radicals, a contributing writer for Elephant Magazine, and has written for Burnaway, Polyester Zine, and Ampersand: An American Studies Journal. She writes about the histories of Black and Latin American women and their representation in visual art, performance, and poetry. She holds a master’s in American Studies from Brown University and a BA with honors in Interdisciplinary Studies from the University of Central Florida.

In Defense of Black Women: The Case of Joan Little