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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Plaintiff states that he is a free person of col
or
the following reasons to wit
That in the spring of the year
he, plaintiff, was the slave of
the defendant in the state of
and that the said defendant did about the time
before mentioned remove and carry with him
from the state of
ritory of
said defendant continued and resided in the said
Territory of
thereof during the term of three months or more
during all of which time he, defendant, kept the
plaintiff with him and in his employ as his slave
Plaintiff further states that subsequent to his
aforesaid residence in
veyed plaintiff to the state of
claims and holds him in slavery in the said State
and that be
fore and at the commencement of this suit
he was and still is a free person and that the de
fendant held and still holds him in slavery
Plaintiff claims that by the laws of
forbid slavery therein he became free by his residence
there, and is in consequence of such residence a free per
son and as such entitled to his freedom, and there
fore prays Judgement for his freedom against the
defendant and all others
states that facts and statements herein alleged
and set forth are true to the best of his
knowledge and
Petition for freedom
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Your petitioner respectfully represents that he
is a free person of color, and as such, is entitled to
his freedom for the reasons herein after following to wit
That in the spring of the year
of a man named
and that the said Wiles did about the time before men
tioned, remove and carry with him from the state of Mis
souri to the Territory of
that the said Wiles continued and resided in the said
territory of
petitioner with him and in his employ as his slave.
Wherefore your petitioner
claims that the Territory of
and by its law forbidding slavery therein, he became free
by his residence there, and is in consequence a free person
and as such entitled to his freedom.
Your petitioner
further states that he was by the said Wiles conveyed
to the state of
ifornia, and that he is now held and claimed as a slave
by the said Wiles in the state of
also states that he is a poor person without any estate
and prays the Court for leave to sue for his freedom
as a poor person, in accordance with the statute in
such cases made and provided.
Sworn to and subscribed before me this
day of December A.
D. Eighteen hundred and fifty one.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
It is hereby ordered that the above
and within named
be allowed to sue for his freedom without
giving security for costs, and that he have
reasonable liberty to attend his counsel and
the Court as occasion may require, and that
he be not removed out of the Jurisdiction of
this Court, and that he be not subject to
any severity on account of his application or
suit for freedom
Filed
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
We command you to summon
to appear
before the Judge of our
term thereof, to be held in the
next, then and there to answer the complaint of
as set forth in the annexed petition
and have you then there this writ.
I acknowledge myself bound for all costs that may accrue in the above cause.
Executed this writ in the
by delivering to
named defendant a certified copy of this
writ and petition by the Clerk
Pet for Freedom
Demurrer filed 21 page 482,
Jugt for Deft - 21 p. 543.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
The Defendant comes
& declares to the Plaintiff's Petition
& says that the same does not
contain facts sufficient to Entitle
the Plaintiff to his freedom,
for causes of
down the following:
1. The fact as alleged in the Plaintiffs
petition, that the he was taken
into
not entitle him to a judgement
of freedom
2. This Court cannot take judicial
notice of the laws of
the general allegation therefore
that by the laws of
the Plff became & is entitled
to his freedom is insufficient.
3. The facts set out on the face of
the Plaintiffs Petition show
that the taking of the Plaintiff
by the Defendant into
was a mere transit of that
Territory & therefore gives the
Plaintiff no right of action
for his freedom.