To the Honorable William C. Carr Judge
of the circuit court of the country of
St. Louis .

The Petition of John Singleton , a man
of colour, represents to your honor, that he
is a free man, according to & by the laws of
the land, having been born of a free mother in the state of Illinois and having
been reared there from his birth to manhood
that his mother, Phillis Singleton, before
the birth of your petitioner, was the slave of
one Ogle, now an inhabitant of St. Clair
county of Illinois , and was emancipated by
said Ogle before the birth of your petitioner,
which happened some time in the year...

And your petitioner further represents, that he
always, from his birth, enjoyed and exercise his
natural freedom, in the state of Illinois until about six years ago, which your petitioner
was stolen and kidnapped by one
J... Lamkins, and was taken by him as
a slave to the now state of Alabama , where
said Lamkims sold your petitioner as a slave,
to one Zachariah Neal, against whom your
petitioner brought suit for his freedom, but the forsaid suit could be decided, you petitioner
was taken from there to New Orleans , by one
Henry Byron, who sold your petitioner there
as a slave, & your petitioner, soon after came
into the hands and possession of our Robert
Lewis , who claims your petitioner to be his slave,
but by what means or by what authority your
petitioner does not know. That your petitioner
knowing his rights to freedom, attempted to regain
it, and went an board the steam boat America
of St. Louis . commanded by Mr. Alexander Scott
and came to the City of St. Louis in the state of
Missouri , some time in august, of the present year
where your petitioner was arrested and cart into
the common jail of the county of St. Louis ,
where he now is, by the authority and order,
as your petitioner is informed & believes, by of
Alexander Scott . as a run away slave, the property
of said Robert Lewis with the avowed intention
of sending or carrying your petitioner to New
Orleans , and returning him to the custody
& possession of said Lewis . And your petitioner
is informed and believes, that your petitioner was
arrested & imprisoned as aforesaid, by said Scott -
as the agent or attorney, of said Lewis , and by
& under his authority. Your petitioner therefore
prays that your honor will permit & order that
he shall be allowed to institute his suit against
said Scott and Lewis for the recovery of his
freedom, and that he may be permitted to
sue as a poor person. And your petitioner
further prays that your honorissue your writ of
Habeas Corpus, directed to said Scott , and to the
Sheriff of St. Louis county, in whose custody your
petitioner now is for the body of your petitioner,
and that your honor will therefore take such
order in behalf of your petitioner as shall

sum met and proper your petitioner not being detained for any criminal or supposed criminal charge and your petitioner will
ever pray

John his mark XSingleton

State of Missouri
County of St. Louis

Personally appeared before me
the undersigned a Justice of the peace within and
for the County of St. Louis John Singleton the
person whose name is subscribed to the fore
going petition, who being by me Sworn upon
his corporal oath, saith, that the facts set forth
in said petition as stated upon his aver know-
ledge are true, and those stated are heresay of
others he believes to be true.

St. Louis august 30th 1829
Sworn to and subscribed before me
Peter Ferguson Justice of the Peace
County St. Louis John his mark XSingleton

State of Missouri Third judicial Circuit
County of St. Louis sct.

It is hereby ordered that the above named
John Singleton the petitioner be permitted to
institute a suit as a poor person to by his claim to freedom
agreeable to the statute of such case made
and provided by Issac C. McGirk Esquire
is assigned to him as counsel. It is moreover
ordered that the petitioner have reasonable liberty to allowed his counsel and the court when occasion
may require and that he shall
not be taken or removed out of the jurisdiction of
of the court nor be subject to any severity because
of his application for freedom given under my hand at chambers
this 31st of August 1827.

Will C. Carr Judge of the Circuit
aforesaid

Petition to be permitted
to the sue for his
freedom.

State of Missouri
County of St. Louis
In the Circuit court of
St. Louis County, November Term 1827

John Singleton , a free man of colour
complains of Alinander Scott and Robert Lewis
of a plea of Trespass; For that the said Alinander
Scott & Robert Lewis , on the twenty seventh day of
august, in the year of our Lord eighteen hundred
and twenty seven, with force and arms, made an
assault in and upon the body of him the said John
Singleton , to wit, at the County of St. Louis in the
state of Missouri , and then and there beat, bruised
and ill treated him the said John, and then &
there imprisoned him the said John and Kept
and detained him in prison there, for a long time, to wit for the space and term ofeight days, then following and
still keep and detain him in prison, without
any reasonable or probable cause whatsoever,
contrary to the laws of the land, and against
the will of the said John; and other wrongs to
the said John then and there did against the
peace and dignity of said state, and to the
damage of the said John of five hundred dollars,
and therefore he brings his suit, &c.

Issac C. McGirk Atty
for Pltff, assigned

No 23
St Louis Circt Court
Nov. Term, 1827.

To the Clerk. This is an action of assault &
Battery & false imprisonment
to try pltffs right to freedom.

Issue a Summons
for defendants.

I. C. McGirk atty P.Q. Filed 3rd September 1827 Arch Gamble Clerk

Executed this writ on Alexander Scott . September 5th 1827
by delivering a certified copy of the declaration, order of
the judge, and the summons. Robert Lewis not found in my county

R Simpson Sheriff

Service$1.00non Est.50

And the said defendant comes and defends the force and injury whereas and say they are not guilty of the
Trespasses andimprisonments in the
declaration mentioned in manner
& form as the plaintiff hath above
thereof complained against himand of this he puts himself upon the county &

And the said plaintiff
doth the like. .
I.C. McGirk for Pltff

Plea

In st.Louis

Plea
Robert Lewis

filed January 8th
1829

A Gambled Clerk.

County Of St. Louis , Sct.The State of Missouri ,To The Sheriff Of Saint Louis County--Greeting:

You are hereby commanded to summon Clayton Tiffin - William Cox
William Hopkins Samuel Wiggin
that, setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit Court , on the Third day of April, at the city of St. Louis ,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein John Singleton is plaintiff,
and Alexander Scott is defendant,
on the part of the plaintiff; and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the city of St. Louis , this 12th day of
March in the year of our Lord one thousand eight
hundred and twenty eight Archibald Gamble Clerk C.C.

Executed this writ on Clayton Tiffin and
William Hopkins and William Cox by reading to the same this18th day
of March 1828. Samuel Wiggin not found

Service 1.50

March 1828

for Clayton Tiffin , William Cox, William Hopkins
Samuel Wiggin
for plaintiff
3rd April

State of Missouri
County of St. Louis In the circuit court
of St. Louis county, Novr. Term
1827

John Singleton , a freeman of color,
complains of Alinander Scott and Robert
Lewis of a plea of Trespass; For that the
said Alinander Scott and Robert Lewis , on
the twenty seventh day of august, in the year
of our Lord Eighteen hundred and twenty seven,
with force and arms, made an assault
in and upon the body of him the said
John Singleton , to wit, at the county of St .
Louis in the state of Missouri , and then &
there beat, bruised and ill treated him the said
John, and then and there imprisoned him the
said John, and Kept and detained him in
in prison for a long time, to wit, for the
span and term of eight days then next following,
and still detains him in
person, without any reasonable or probable
cause whatsoever, contrary to the
laws of the land, and against the will of
the said John, and other wrongs to the said
John then and there did, against the peace
and dignity of the state; And the said plaintiff
avers, that before and at the time of the committing
the said grievances he was and still
is a free person, and that the said defendants
then & there held and detained him, the plaintiff, &
still hold & detain him in slavery
the said plaintiff saith he is injured and
hath sustained damages in the sum of
five hundred dollars, and therefore he brings his suit, &c.

I C. McGirk Atty
for pltff

March Term 1828
Amended declaration
I. C. Mc Girk for
plff

filed April 22nd
1828Agamble Clerk