To the Honorable Luke E. Lawless judge of the cir-
cuit court of St Louis county : the petition of Andrew
by Celeste his mother and next friend respectfully
represents. That in the month of october 1799 on
certain. Robert Bunton (then and for many years
subsequent a resident of Vincennes in the north
western terretory) purchased of a certain William
Jullian in the town of Louisville and state of
Kentucky . Judy the grand mother of your petition-
er as a slave for life and immediately thereaf-
ter brought the said Judy to Vincennes aforesaid
the place of his residence where she was kept
and used as a slave by the said Bunton and
family untill th about the month of april
1800, at which time she was delivered to a
certain Touisant Dubois who brought her to
Kaskaskia in the territory aforesaid, when she
was deliverd to a certain Peter Menard who
brought her to St Louis in the territory of upper
Louisiana and sold her in the month of aug-
ust 1800 to a certain Wm. H. Lecompte.

Your petitioner further represents that the
said Judy remained in slavery until a short
time since, when she and several of her children
with the said Celeste werepronounced to be
free by the verdict & judgment of the
circuit court of St. Louis & St Charles county. Your petitioner
further represents that he is now held in
slavery by a certain Peter Sarpy contrary
to law, he therefore prays that he may be
permitted to bring suit as a poor person
by Celeste his mother and next friend
for the recovery of his freedom against
the said Peter Sarpy . Your petitioner
further represents that he is appre-
hensive that the said Sarpy may send
or take your petitioner beyond the bounds
of this State, he your petitioner therefore
prays that the said Sarpy . be com-
pelled to bond and security. to
have your petitioner forthcoming to
answer and abide by the judgment
of the court in the premises and may
it please your honor to make the
usual orders in such casesmade &
as in duty bound will everpray
-

Andrew by
Celeste his mother
& nextfriend
her mark

State of Missouri
County of St Louis
ss.

This day Celeste a free woman
of color personally appeared before the court
designed a petition of the peace for the
county aforesaid and made oath that the
matters and things in the foregoing peti-
tion contained to far as they abpend
upon her own knowledge an and then
and there coming from the information of others she belives to be true.

Sworn and Subscribed
to this eighth day of July
AD 1839 of James L Purth
Justice of the peace
CountyCeleste her
mark

It is hereby ordered that Andrew be allowed to sue as
a poor person to establish his right to freedom by Celeste
his mother and next friend and that Ferdinand W Risque is
assigned him as counsel for that purpose.

That the said Andrew have reasonable liberty to attend
his counsel and the court, as occasion may require;
that he be not removed out of the jurisdiction of the
court and that he be not subject to any severity
on account of his application for freedom.

L E Lawless
Judge C. County St .
Louis

No. St Louis
Circuit Court : Nov: Term 1839

Andrew by Celeste his
mother & next friend
vs
Peter Sarpy
Petition

St Louis Circuit Court .
July November Term 1839. County of St. Louis To wit:

Andrew by Celeste his mother and next friend
by leave of the court first had and obtained com-
plains of Peter Sarpy of a plea of trespass for
false imprisonement. For that the said defen-
dant heretofore to wit on the first day of July
in the year of our Lord
one thousand eight hun-
dred and thirty nine with force and arms
assaulted the said plaintiff to wit at the
county aforsaid and then and there beat bruised
and ill treated him and then and there im-
prisoned him and kept and detained him in
prison there without any reasonable or pro-
bable cause whatsoever, for a long term, to
wit: for the space of hours then next
following contrary to law and to the will
of the said plaintiff, and the said plaintiff
avers that before and at the time of the
committing of the grievances, was, and still
is, a free person and that the defendant
held and still holds him in slavery, and
other wrongs to the said plaintiff then and
there did to the damage of the said plaintiff
two hundred dollars and therefore he brings
his suit &c.

F. W. Risque
Attorney for Plff

No. St Louis Circuit
Court . November Term 1839.

Andrew by Celeste his mother
and next friend
vs
Peter Sarpy
Declara-
tion.

This is an action of Tres-
-pass for false imprison-
ment to recover freedom
Damage $200. Clerk
will issue summons.

F. W. Risque
atto: for Plff.

County of St. Louis , ss.
THE STATE OF MISSOURI ,To the Sheriff of St. Louis County—GREETING:

We command you to Summon Peter Sarpy 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 Monday
of November next, then and there to answer unto Andrew , who
sues by Celeste his mother and next friend of a
plea of trespass for false imprisonment
to the damage of said plaintiff of two 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 Eighth day of
July in the year of our Lord eighteen
hundred and thirty-nine. Jn. Ruland Clerk.

I acknowledge myself bound for all costs that may accure in the above cause.

Witness my hand and seal, at St. Louis , this day of 18

Sub & Judge of Liberation for Plff BK 12 p 81

No 20 St Louis Circuit Court
November Term 1839

Andrew by Celeste his mother
and next friend
vs
Peter
Andrew Sarpy

Summons

Trespass for false imprisonment

Dam. $200

Risque p q

Filed July 8th 1839 Jn. Ruland Clerk

Executed this writ in the County of Saint
Louis on the 8th day of July 1839 by reading
it and the declaration to Peter Sarpy .

Service 1.00 Marshall Brotherton
SheriffBy Wm M. Knight
Depty

And the said defendant
by his attorney comes & defends the wrong & injury
and says that he is not guilty of the said supposed
grievances above to his charge, or any or either
of them or any part thereof in manner & form as the
said plaintiff hath above complained against him,
And of this he the said defendant puts himself
upon the Country.

Bogy & Hunton
Attys for deft

No 20 Nov. T

Peter Sarpy
ads
Andrew -(a colored man)

Suit for freedom
Plea- not guilty

Bogy & Hunton
attys.Filed November 27th 1839 Jn Ruland clerk

In St Louis Cir. Court , Nov T. 1841

Andrew by next friend
vs
Peter Sarpy

False imprisonment to
recover freedom.

In this cause We agree
that a Judgment of Guilty be entered
in this entitled cause against

Deft Peter Sarpy , and the Plaintiff Andrew , Feby. 2. 1841.

Bogy & Hunton
attys for Sarpy