Territory of Missouri
Northern CircuitThe United States of America to the Sheriff of the county
of St Louis Geeting-

You are commanded that You summon Michael Halter that he
be and appear before the judges of our Superior Court of our Territory of
Missouri at our said Superior Court to be held in and for the said
Territory at the town of St Louis in the Northern Circuit on the
fourth monday in March next then and there in our said court
before our judges to answer unto Sarah a free girl of color held in salvery
in a plea of trespass assault and batteryand false imprisonment
to her damage five hundred dollars-and have you then and
there this writ and certify to our said court for you
execute the same-

Witness the Honorable
residing Judge of our said court at St Louis this-
fourteenth day of december in the year of our lord one
thousand and eight hundred and eighteen and of our
Independence the forty thirdJ C Turner Clk S. C. N. C.

No 191
April Term 1821
Superior Court
March Term 1819
Summons

Michael Halter

To the clerk of the
Superior Court N.E.
This is an action of
trespass& false imp
risonment damage
$500 on which you
will issue a summons
to the sheriff
of St Louis Territory.

J. Barton & Geyer

Michael Halton not found in this Bailwick
March 20th 1819

J. K. Walker
Dshff

now costs 50

travel 100ms-5.50

$6.000

filed April 26th 1879

Superior Court
Northern Circuit

And the said Defendant by
R Pettibone his Attorney comes and defends
the wrong of injury when and as
to the assaulting beating bruising ill
treating and imprisoning and keeping
in prison the said Plaintiff as in her
said declaration mentioned the said
Defendant saith that the said Plaintiff
ought not to have or maintain her
aforesaid action thereof against him
because he says that before and at the
said time when in the said
mentioned, to wit, at the plan of within
the jurisdiction aforesaid the said Plain-
tiff was and still is the slave of him the said
Defendant whereupon the said Defendant
at the said time when he did beat
imprison & retain in prison the said
Plaintiff so being the slave of him the
said Defendant as he lawfully might
do which are the same
trespass whereof the said Plaintiff
hath above thereof complained against
him and this he is ready to verify-
whereupon he prays Judgement

R Pettibone atty
for Deft.

And the said Sarah saith she
might not to be bound and precluded
from having and maintaining
her aforesaid action by reason of
any thing by the said Michael Halton
above in his alleges because
she saith that at the said time when
in the declaration mentioned was
not the slave of the said Michael
in manner and form as he has
above in his said plea alleges
and this she prays may be en-
queried of by the county and
the said defendant doth the like

J Barton atty

Plea- replication

filed September 20th
1819

St.Louis Circuit Court

Febry Term-1822

On the trial of this cause it was
proved on the part of the plaintiff that one Winnie mothe-
er of the said plaintiff was carried into the now state
of Illinois between twenty and thirty years since by
the said defendant and her husband when and where
the said Winnie was by then in slavery during the
space of three or four years; that at the end of said
time of three or four years, the said Phebe with
her said husband removed to the now state of
missouri carrying the said Winnie with them in
which lst mentioned place the said Winnie has
been held in slavery ever since such removal
and that said plaintiff was born after such res-
idence of the said Winnie in Illinois as aforesaid
the Counsel for the defendant then required the court
to instruct the jury that a residence in the then
North west territory (now Illinois ) as above mentioned
did not render the said Winnie free under and
in virtue of the ordinance of Congress of the year
one thousand seven hundred and eighty seven
for the government of the territory of the United
States north west of the river Ohio -which instruction
the Court refused but charged the jury that

Said ordinance did in law set the said Winnie
free if it should appear to the satisfaction of the
jury that the said defendant and her then hus-
band resided in Illinois with intent to make that
territory the home of themselves and the said -
To this opinion of the court delivered to the
jury the Counsel for the defendant excepted and
Prayed the court to sign and seal a bill of excep-
tions taken thereto which is done accordingly in
open court this tenth day of march in the year
one thousand eight hundred and twenty two.

N. S. Tucker

St. Louis Circuit Court

Bill of exceptions

Pettibone & Spalding atty

Reasons for dismissing suit

Because there is no proof that
papers came from Superior
Court and there is no petition on on
file

do

do

do

do

do

eight other suits

reasons for dismissing

filed February of 1822
A Gamble

Superior Court Northern Circuit
March Term 1819.

County of St Louis to wit Sarah a
free girl held in slavery and of who
is permitted by the court to sue as a
poor person. by J Barton and Henry S
Geyer her attornees assigned by the
Court as counsels complains of Michael
Halton of a plea of trespass-for that
the said Michael Halton , heretofor
to wit on the first day of January in
the year of our lord one thousand
eight hundred and fifteenwith
force and arms at the county
aforesaid lawfully an assault
did make in and upon the said
Sarah and then and there beat
bruise and said
Sarah and then and there
imprisoned the said Sarah and kept and detained her in prisonwithout any reasonable
on probable cause whatever and

has scince kept and still
doth keep and detain her in
prison against the will of her the
said Sarah and contrary to the
law of this territory and this wrong
to the said Sarah then and
there did against the peace of
the United States of America . and
to the damage of the said Sarah
five hundred dollars and Therefore
she sues.

J. Barton
Geyer atts