Virginia Laws and the Rise of Race-Based Slavery

Context: Before Virginia formally legalized slavery, the language in a petition regarding Elizabeth Key, a mixed-race woman, indicated that some individuals were considered enslaved.
Court Case: Her father sought better treatment for her than a "common servant slave" over a nine-year period, implying abuse and exploitation. The General Assembly sided with Elizabeth Key.
Outcome: Elizabeth Key was declared free.
"Freedom Dues": The General Assembly ordered her last master to provide her with "corn and clothes" and "satisfaction for the time she has served longer" as if she were a servant, not a slave. These provisions (corn, clothes, leather, tobacco) were typical entitlements for indentured servants upon completion of their service.
Significance: This ruling in $1656$ shows that at this early stage, the legal status of mixed-race individuals and the concept of permanent, inheritable slavery were not yet firmly established, allowing for arguments based on mistreatment and length of service.