I ran across this interesting tidbit a few weeks ago while indexing Superior Court Minutes 1869 – 1872 (Macon Co., NC). From page 46:
Warrant Issued 7th day April 1870 Returned 7th April 1870 with the defendant [J. M. Dills] arrested by W. A. Shepherd. She [Mary E. Payne] come up on evidence of the prosecuter that the said child was born in the State of Georgia where its mother was at the time domiciled.
The child’s name is not mentioned, and repeated attempts to find Mary Payne in the 1870 US Census in both Macon County and nearby Rabun Co., GA, have proved fruitless.