William J. Gaston (for whom Gaston County, North Carolina was named) was a distinguished jurist, state legislator and US Congressman from North Carolina. Gaston served on the Supreme Court of North Carolina from 1883 until his death in 1884.
In the decision of the NC Supreme Court in State v. Manuel, 4 Devereaux & Battle 25-26 (N.C., 1838), Gaston concluded that free blacks were citizens saying:
All free persons born within the state are citizens of the state….
The term “citizen” as understood in our law, is precisely analogous to the term subject in common law, and the change of phrase has entirely resulted from the change of government. The sovereignty has been transferred from one man to the collective body of the people–and he who before was a “subject of the king” is now “a citizen of the state.”
This is important both in the invocation of the common law in the decision of a citizenship issue as well as the affirmation of the equivalence of “citizen” and “subject”.
Thus in North Carolina was affirmed the same principle that 6 years later appeared in the decision of Lynch v. Clarke in New York.