In Brazilian historiography, still very poor regarding enslaved women, there are many examples of, and even a certain preference for, studies that refer to enslaved women’s ability to get favors from their masters, by having sexual relations with them. The most well-known example here is Chica da Silva, who has been the theme of academic works, novels, telenovelas, samba school’s parades during Carnaval, etc. But still, Chica and Sally are different because when Chica became the “mistress” of her owner, after purchasing her, he immediately freed her.
I checked Gordon-Reed’s book and she effectively uses the term “mistress” 37 times when referring to Sally. Also, Sally was referred by Jefferson’s contemporaries as a “mistress”. Gordon-Reed then widely used this term, perhaps because this was the term used by that time. Yet, almost a decade after the publication of her book it is pertinent to question the use of word “mistress” in the context of slavery. Gordon-Reed’s is the one who has brought Sally’s story to light and certainly the greatest authority on the study of slavery in Monticello. But there are always new findings emerging, and a growing scholarship on enslaved black women has questioned the use of certain terms, and even how historians have been using the archives where the presence of enslaved women is usually marked by silences.