State of Missouri St. Louis County ssIn the St. Louis Circuit Court
November Term 1844
Stephen Brown who sues by his next friend
Jenny Brown complains of William Head
of a plea of trespass and false imprisonment
for that whom the said defendante and the tenth day of September
in year eighteen hundre and fifty four made on assault upon the said plaintiff county aforesaid
and then and there imprisoned beat Bruised and
illtreated him the said aforesaid plantiff and kept and
detained her in prison that and then without any
reasonable or probable cause whatever for a a long
span of time towit for the span of tweleve hours
then and following contrary to the law of the
state and against the will of the said plaintiff
and the said plaintiff further owns that she the
said plantiff before and at the time of the committing
of the said grievance was and still is a free
person and that the said defendant then
and there held and still holds the said plaintiff
in slavery and wrongs to the said
plaintiff the said defendant then and
there did Contrary to the peace and dignity
of the said state and to the damages
of the said plaintiff of Five Hundred dollars
therefore the said plaintiff brings suit.
Elias B. Smith .
p.q.
State of Missouri
St. Louis CountySSThe Circuit Court of St. Louis County
Your petitioner purposefully states to St. Louis
Court your Honor that the person mentioned in the declaration above held
in slavery by by William Head in the County and that the now
Stephen Brown is entitled to his freedom in Consequence
of a certain grounding had in the the state of Virginia to wit
Jenny Brown the Master of said Stephen was brought by her
then North into the state of Virginia Contrary to the laws of the
said state of Virginia by reason of which she was then and is now a free person and was afterwards brought
to the state of Missouri and in said state of Missouri kept in slavery against him with for more than
twenty years during which time the said Stephen was
born and is now at the age of Seventeen years
Your petitioner prays this court
a permit and allow him the said Stephen to sue as a free
person to establish his right to freedom and as in duty
Sworn to and subscribed before the 14th day of oct 1844
James J Purely A Justice of the
County Court for St. Louis CountyX Jenny Brown her mark
In the St. Louis Cir. Court
November Term 1844
Smith p.q.
State of Missouri
St. Louis County
On reading the above
afore going petition
This ordered that the petitioner
Stephen Brown have him and
hereby an his counsel and
ordered that said petitioner have reasonable liberty
of attorny his counsel and that court as occurence
may require and that he be no removed
from the jurisdiction of this court and that
he not subjected to any severity on account of
his application to sue for his freedom
John M Krum
Judge 8
the St. Louis Circuit Court
Nov Term 1844
Stephen Brown
his next friend
vs Trespass to
Wm Head
Elias R. Smith
p.q.
County of St. Louis , Ss.The State Of Missouri ,To the Sheriff of St. Louis CountyGreeting:
We command you to summon Stephen Br William Head
if he be found in your county that he be and appear
before the Judge of our Circuit Court , on the first day of the next term thereof, to be
held at the City of St. Louis , within and for the county of St. Louis , on the third Mon-
day of November next, then and there to answer unto Stephen
Brown by his next friend Jenny Brown of a
plea of trespass & false imprisonment
to the damage of said plaintiff five hundred
dollars: And have you then there this writ.
Witness, John Ruland , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
city of St. Louis , this twenty fourth day of
October in the year of our Lord eighteen
hundred and forty four John Ruland Clerk.
I acknowledge myself bound for all costs that may accrue in the above cause.
Witness my hand and seal, at St. Louis , this day of 184
plea filed15 P 290.Dismissed feby v.1846 87/72
No231
St. Louis Circuit Court
November term 1844.
by his next friend Jenny
Brown
v summons
William Head
Trespass & false imprisonment
Damt . $ 500.
Smith p. q.FiledOctober 24th 1844 John Ruland Clerk
This ordered that the petitioner have a
reasonable liberty to sue as a poor person
and Elias B. Smith assigned her as counsel
it is further ordered that he have reasonable
liberty to attend the Court and her counsel as ses=
-sion may require, and that she be not removed
out of the jurisdiction of this court and that
she be not subject to any severity on account
of her application for freedom.
Free ✓(138)
Executed this writ in the County
of St. Louis on the 2nd day of November 1844
by reading it, and the declaration to William
Head the defendant, and also by reading to
the said William Head the orders of the
Judge endorsed upon this writ
Fee $2.00
William Milburn Shff By R. Dowling Deputy
next friend Jenny Brown
v.
William Head
In the St. Louis Circuit Court Nov. Term 1844
And the said defendant by Leslie Lord
his attorney, cause and defends the force
and injury when Lc. & says that he is
not guilty of the said supposed Trespass
above laid to his charge in any part thereof.
in manner and force as the said plaintiff
hath above thereof complained against
him for this he puts himself upon
the country Lc ..
Leslie & Lord
for Deft..
by his next friend
v.
William Head
Plea Seu. Issue
Leslie & Lord
for Deft..
FiledNov 18th 1844 John Ruland Clerk