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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
is a free person and that she is in
and held as a
states that she became entitled to her freedom
and is a free person because she was taken from
the state of
her then owner and master John MC
tory belonging to the
Territory north of
north latitude in which
that she remained in the aforesaid territory near Fort
and performed labour for said MC
claiming her as his slave until about the month
of september 1850. Plaintiff
territory his home and kept plaintiff in his
during
september 1850 and then bought her back to
the state of
she claims to be a free person. Plaintiff states that
before and at the time of commencing this
she was a free person and was held and is still held
slave by defendant and she
her freedom and release from the claim of defendant and
all others to her as a
foregoing petition are true.
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
, a woman of colour, states that she is a free
person and as such is entitled to her freedom. But
that she is held as a slave and is in possess
ion of
entitled to her freedom because she was taken
in
John MC
to the
near Fort Scott. In which Territory slavery is
prohibited said territory being north of thirty six, 36, degrees
thirty (30) minutes, north latitude. she states further that
said MC
aforesaid territory from the time above mentioned
until about
petitioner remained with and performed labour for
said MC
time heretofore stated and therfore she claims
to be free. Your petitioiner also states that she
is a poor person without any estate and prays
that she have leave to sue as a poor person
according to the statute in such cases
provided.
matters & things as stated in her petition are true.
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 within named petitioner
colour be allowed to sue for her freedom as
a poor person without giving security for costs
and that she
to attend her Counsel and the Court as occasion
may require and that she be not removed out of
the Jurisdiction of this Court and that she be not
subjected to any severity on account of her suit
for freedom.
Given under my hand as Judge of
the Circuit Court of the
and state of
A.
D. 1852
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
before the Judge of our
term thereof, to be held in the
and have you then there this writ.
I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal, at
185
Executed this writ on the
By delivering to H B Belt a true copy of the
writ and
vs Summons
a person of Color be allowed to sue for her freedom as a
poor person without giving security for Costs and that
she have reasonable liberty to attend her Counsel
and the Court as occasion may require and that
she be not removed out of the Jurisdiction of
the Court and that she be not subjected to any
severity on account of her suit for freedom.
Given under my hand as Judge of the Circuit Court
of the
1852.
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.
for the plaintiff in the above entitled
cause
suit and service
he the said defendant sold the plaintiff and
that
the purchasers of said plaintiff and that
on the
did decoy the said plaintiff from the place
at which she had been confined
jail of
for and by
her to go and see her attorney and that
instead of taking her to see an attorney that
the said
sons to this affiant unknown did by force & threats
compel her the said plaintiff to go
on board of the steam Boat "
at that time at the port of
state aforesaid and that the defendant and the
said Christy & Curtis shipped or caused the said plain
tiff to be shipped on board of said steamBoat
the state of
out of the jurisdiction of this court for
the purpose of selling her as a slave the said
boat being at the time spoken of bound for New
Affiant states that the aforesaid
aforesaid city of
the said
affiant unknown did force and compel by threats
and violence the said plaintiff to go
on board of said steam Boat
she plff had informed them, the said
others, that she was a free person and
affiant is informed and believes that the said
forcing said plff on said boat were aided
and abetted by the said
all that was done to decoy and force
the said plaintiff in the manner and
form heretofore mentioned and that the said
caused the said plaintiff to be carried
out of the Jurisdiction of the Court.
Affiant also states that it was well known
to the said
cause had brought suit for her freedom as
he was the person who bid for the said plaintiff
when she was sold by defendant and that he
the said
James M Riley & James Christy
said Riley & Christy were told
at the time plaintiff was sold as afsd
of her suit for freedom
bid for and bought the plaintiff. Affiant
also states that he informed the said
day on which plaintiff was sold as aforesaid
that she had sued for her freedom. Affiant
states that he has called upon the defendant
in this cause and upon the said
plff for some information of the whereabouts
of said plaintiff and that they have all failed or refused
to give him any information on the subject
Affiant states that the said plff was confined
the defendant which was about the
last until the time she was taken away by the
said
said
was carried too and taken from said jail or
negro yard by the aforesaid
states that it was not known to him until the
of this month Febr 1852
been carried off in the manner spoken of when
he received a letter from a passenger on said steamboat
purports himself to have been such at the time said
plaintiff was taken on board of and carried off
on said steamer
Memphis
the within & foregoing cause makes oath
and says that the statements contained in the foregoing affidavit are true as he
verily believes.
Sworn to and subscribed before
me, this twenty fourth day of
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.
woman of colour
suit 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.
In obedience to an order
of this Hon Court made at the present
Term 1851
and by which order
Court on the
an attachment should not issue against them
for a comtempt of the order of said Court. And
now the said
it is not true that he with said E. Curtis on
the
the said
confined & from the Jurisdiction of this Hon Court
and the said
at said time had any knowledge whatever that
this Hon court had ever made any such order
as the one referred to in the order a copy of which
is hereto annexed. And the said
presently denies that he ever removed or decoyed
said
fined and beyond the jurisdiction of this Court
after he had any knowledge that she was prose
cuting her suit for freedom.
The said
here to be informed that he the said
information that the said
instituted any suit for freedom until
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 sheriff of said County served upon him
the Copy of the order of this Hon Court hereto
attached. This respondent denies that he
violated any order of this Hon court after
having due notice of the existence of said
order and he denies that he has at any
time done any act or thing in contempt of
any order of this Hon Court and denies
all and each of the statements contained
in the order (a copy of which is herewith filed)
in which this respondent is charged with having
decoyed and moved from the place where she
was confined the said
ction of this Court after having noted that
said
dom and in violation of the order of this
Hon Court. The said
protests that he has not committed any
contempt or knowingly violated any order
of this Hon Court Wherefore he prays to be
hence discharged with this costs
answer and the matters therein as stated
are true.
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.
Whereas
plaintiff in this cause has filed his affidavit in
the court alleging among other things
That one
on the
said plaintiff
fined & from the jurisdiction of the court during
the pendency of her suit for freedom and with
full knowledge by the said
the said
out of the jurisdiction of the court during the
pendancy of said suit and with full knowl
edge that said
suit for freedom. Therefore it is ordered by
the Court that the said
show cause to said court on Tuesday next the
of March 1852
House of the city of
should not issue against them for a con
tempt of the order of said Court in the
I
a true copy of the order made by said Court in said cause
the seal of said court at
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.
In the
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.
You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our
March 1852
to testify, and the truth to say in a certian matter of controversy now pending in our said
Court, wherein
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.
suit for freedom
Executed (Except Feby 27)
W B Miller Wm Hopkins
& L.
Fees $2.30 E. English -
Coroner
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.
You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our
March
tify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein
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.
suit for freedom
Executed the within
by summoning the with
in named witnesses as directed on the
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.
In obedience to an
order of this Hon Court made at the present
the above entitled cause, requiring this
respondent to show cause why an
attachment should not issue against
him for a contempt of an order of
this Hon Court Cause and shown the
following to act, respondent states that
no order was ever served on him
in the above cause nor did he know
that any order ever had been
made in the above entitled cause
This respondent states that he did
hear that said
suit for her freedom but that this
respondent was no party to the
issue and did not consider that
he had any thing to do with said
suit, he states that said
by the sheriff of said county and
as the agent for Riley & Christy he
bid for and purchased said
purchased said
Mr. Hughes an attorney of the
Bar to look into the matter
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.
and advise what ought to be done
in the premises, and this respondent
states that said Hughes advised
that said
This respondent states he gave no
further attention to the matter as he
relied on the
said attorney.
This respondent denies
that he decoyed said slave from the
place where she was confined and
he denies that he removed said
of this Hon Court, Knowing that
he was violating any order of this
Court, he states that all that he
did in the premises was as agent
for other and without any knowledge
on his part that he was violating
any law or any order of this Court &
he denies that he has committed any
contempt of any order made by this
Hon Court Wherefore he prays
to be hence discharged .
Edward Curtis on his oath says he
believes the above & the matters therein as
stated are true.
Sworn to & subscribed
2nd 1852
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.
Answer of
Edwd Curtis
Whereas
the plaintiff in this cause has filed
his affidavit in this Court alledging among
other things that one
1852
from the place at which she was
confined & from the Jurisdiction of this
Court during the pendency of her suit for
freedom and with full knowledge by the
said
of this Court, That she the said
should not be removed out of the juris
diction of this Court during the penden
cy of said suit and with full knowledge
that said
for freedom. Therefore it is ordered
by the Court that the said
show cause to said Court on Tuesday next
the
o'clock A
M at the Court House of the
not issue against them for a contempt of
the orders of said Court in the premises
I,
a true Copy of the order made by said Court in said cause
Witness whereof I hereto set my hand and affix the
seal of said Court at office, in the city of
Executed this writ on the
the within and offered to read the same which they refused
to
Filed
suit for freedom
Plaintiff by her Attorney
by way of reply to the answer of
to the order of this Court in the above entitled
for him, the said
day of March 1852
not issue against him the said
contempt of this Court in the above entitled
Cause and plaintiff states that he the said
did have full and complete notice and knowledge of
all the orders made by the Court in the above
entitled cause in the suit of plaintiff for her freedom and
that he the said
by the plaintiff
Plaintiff states that the said
of February 1852
from her place of confinement and did remove her
the said plaintiff from out the jurisdiction of
this Court having a full knowledge that he was viola
ting the orders of the Court made in the suit of
plaintiff for freedom. Plaintiff states all that has
been done by the said
touching the said plaintiff since the commence
of her suit for freedom has been done with a full
knowledge that he was violating the orders of
the Court made in the aforesaid suit of the
plaintiff for freedom. Plaintiff by way of
demurrer to the answer of the said
aforesaid order of this Court made in this cause
states that said answer is no defence to the motion
the said
should not be issued against him the said
made in regard to Causes therein pending is
no excuse for violations of such orders.
says that the matters and things as stated in the
foregoing answer are true as he verily believes.
Sworn to and Subscribed
before me this
suit for freedom
Answer of plff to
motion for attachment
suit for freedom
Plaintiff by her attorney
way of answer to the response of
made to the order of this Court in this cause that
he the said
of March 1852
ment should not issue against him the said
states that he the said
form as stated in said order force decoy and
take from her place of confinement
the plaintiff and that he the said
and assistance of one
day of February 1852
the said
of the jurisdiction of this Court after suit
had been brought by plaintiff for her freedom
and process served on the defendant
Plaintiff states that at the time she was removed
as aforesaid by the said
of the Jurisdiction of the Court that the said
and
orders of the Court made in this cause and among
said orders is that which directs that the plaintiff
be not removed out of the Jurisdiction of this Court
during the prudency of her suit for freedom
Plaintiff denies that said
vised at the time he removed plaintiff as aforesaid
that she the plaintiff had commenced a suit for her
freedom but states he the said
time have an entire and full knowledge that said suit
had been commenced for the freedom of plaintiff.
Plaintiff
violate that order of this Court which directs that
plaintiff should not be removed out of the ju
risdiction of this Court during the pendency
of her suit for freedom after he had received due notice
of the same and that he the said
did remove plaintiff out of the Jurisdiction of this
Court after suit had been commenced for her free
dom and process served on the defendant
Belt all of which appears of record in this cause.
Plaintiff by way of demurrer to the answer
of the aforesaid
made on him in this Court states that said answer is
no defence to the motion for an attachment
against him the said
the orders of this Court in cases therein pending is no excuse
for a violation of the same.
oath and says that all the matters and things as stated
in the foregoing answer are true as he verily
believes.
Sworn to and subscribed
before me this
suit for freedom
Answer of plff to
the response of
on motion for attachment