State of Missouri
County of St Louis

ss Be it remembered that on the
12th day of December 1844 A
petition was filed in the St Louis Circuit Court in
petition the words & figures following to wit: To the Hon the
Judge of the St Louis Circuit Court the petition of
Thomas Jefferson a man of Color aged about thirty
years respectfully represents to your Honors that he
was born a slave in the state of Virginia . Where he
resided until the year eighteen hundred and thirty
five, that in the spring of that year, your petitioner
was brought by his Master one Charles Drexter to St
Louis in the State of Missouri where he resided until
the Spring of Eighteen hundred and thirty nine. that
in the month of March or April of the year last na
-med his Master the Said Charles Drexter told your
Petitioner to one Doctor Samuel Prosser who is a brother
of said Drexters Wife. that said said Doctors Samuel
Prosser then resided and now resides at Jacksonville
in the State of Illinois . that said Prosser immediately
after becoming the owner of your Petitioner to wit:
in the month of April of the year Eighteen hundred
and thirty nine took your Petitioner from St Louis
in the State of Missouri and conveyed him to the County
of Morgan in the State of Illinois and there held him
to labor and service on his the said Prossers farm
situate within four miles of Jacksonville in the said
County of Morgan State of Illinois . from the said month
of April until the month of December in the Same year
being for a period of almost eight months that petitioner
was employed during said time at ordinary farming
labor for the said Prosser . that in the month of December
of said year last named, there began to be a good deal of talk in the neighborhood about said Prosser holding
Petitioner as a Slave in said State of Illinois and said
Prosser fearing the interposition of the
authorities there came from Jacksonville in a carriage
with his father in law to his Farm where your petitioner/2 was at work, put petitioner into it and drove off and
brought Petitioner to St Louis in the State of Missouri
and there hired him out. And now does and ever since
has received the rewards of Petitioners labor. That
Petitioner now is and has been for the last two years
and now in the possession of one Milton W. Hopkins who
holds Petitioner in Slavery as a hireling from said
Prosser . Your Petitioner believes that he is entitled to
his freedom and prays your Honor for leave to sue as
a poor person, in false imprisonment against said Milton
W. Prosser Hopkins in order to establish his right to freedom
and he will pray &c Thomas Mark Jefferson . State
of Missouri St Louis County vs Thomas Jefferson a man
of Color being duly sworn says that the matters and
things contained in the foregoing petition are true
Thomas his mark Jefferson Sworn to & subscribed the 10th
day of December 1842 Alphonso Wetmore Justice of the
Peace. Upon which petition the following orders were
made. County of St Louis State of Missouri is Being
Satisfied that the foregoing Petition contained sufficient
matter to authorize the commencement of a Suit. I
do make the following orders - I wish that the said Thomas
Jefferson a man of Color be allowed to sue as a poor
person to establish his right to freedom and also assign
F B. Murdock, Esq. as his Counsel. Second that
that the said Thomas Jefferson has reasonable Liberty
to attend his counsel and the Court as occasion may
require

require that he be not removed out of the Jurisdiction
of the County and that he be not subject to any
severity on account of his application for freedom
Done in open Court 12th December 1842 Bryan Mullanphy
by Judge &c and on the day and year last
aforesaid the following Declaration was filed to wit.
Declaration State of Missouri St Louis County as in the Circuit
Court of St Louis County March Term 1843 Thomas
Jefferson , a man of Color, complains of Milton W
Hopkins of a plea of trespass, for that the said Defendant
on the first day of December Eighteen hundred
and forty-two, with force and arms made an
assault upon the said Plaintiff to wit at the County
aforesaid and then and there beat bruised and ill
treated him the said Plaintiff and then and there
imprisoned him the said Plaintiff and kept and
detained him in prison there without any reasonable
cause whatever for a long time, to wit. for the Space
of twenty four hours then next following contrary
to the laws of the said State and against the will
of the said Plaintiff and the said Plaintiff avers
that before and at the time of the committing of
of said grievances, he the said Plaintiff was and
still is a free person. And that the Defendant held
and still holds him in slavery to the said Plaintiff
damage one hundred Dollars and therefore he brings
Suit &c A B Murdock Atty for Plff St Louis 12th
Dec. 1842 “ Upon which Declaration a Summons was
Summons issued in the words & figures following to wit " County
of St Louis as the State of Missouri to the Sheriff of St
Louis County Greeting. We command you to summon
Milton W. Hopkins 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 March next and then and there to answer
unto Thomas Jefferson (a man of color) of a plea of
Trespass in false imprisonment to the damage of
said Plaintiff One Hundred Dollars. And have you
then there this writ Seal Witness John Ruland
Clerk of our said Court with the seal thereof hereto
affixed at office in the City of St Louis this twelfth
day of December in the year of our Lord eighteen
hundred and forty two 2nd Ruland Clerk
“Upon which summons the Sheriff made the following
Shffs return return to wit: "Executed this writ in the County of
Saint Louis on the 31st day of December 1842, by
reading it and the declaration and order of the
Judge to Milton W. Hopkins the Defendant William
Milburn Shff by Henry B. Belt Deputy and on
the following 26th day of March last year aforesaid
the following admission of Defendant was filed to wit:
Admission "In the St Louis Circuit Court Suit for freedom Thomas
Jefferson vs Milton W. Hopkins Milton W. Hopkins the
defendant in this case admits that at the time of the
institution of this suit he held the said Thomas
Jefferson a Man of Color in his Service as a Slave
having hired him of Doctor Prosser of Jacksonville
Illinois M W. Hopkins I agree that the above facts
are true and that this may be recd in evidence M
Leslie Attorney for Prosser "And on the following Fifth
day of May 1843 the following Plea was filed to wit
Plea In the St Louis Circuit Court April Term 1843 Thomas
Jefferson vs Milton W. Hopkins And the said Defendant

by his Attorneys comes and defends the wrong & injury
when &c & says he is not guilty of the said supposed
grievances above laid to his charge or any part thereof
in manner & form as the plaintiff hath above thereof
complained against & of this the Defendant puts
himself upon the County &c Drake & Rannells Attys
for Deft. And upon the Twenty seventh day of May
eighteen hundred and forty four the following
proceedings were had to wit Thomas Jefferson
vs Milton W . Hopkins Trespass The Judge of this
Court having heretofor acted as Counsel in this
cause it is ordered that the venue thereof be changed
to the St Louis Court of Common Pleas and that
the Clerk of this Court make out a full true and
complete Transcript of the record and proceedings
in this cause and transmit the same, duly
certified, together with all original papers filed
in the cause and not forming part of the record
thereof to the Clerk of said Court of Common pleas

State of Missouri
County of St Louis
ss

I John Ruland Clerk of the Circuit
Court within and for the
County aforesaid Certify the foregoing to be a full
true and complete transcript of the record and
proceedings in the case of Thomas Jefferson vs Milton
W . Hopkins as the same remains of record and
on file in my office.

In testimony whereof I have hereto
set my hand and affixed the
seal of said Court at office in
the City of St. Louis this fifth
day of July 1844.

Jn. Ruland Clerk

No 219 Court of Common Pleas
September Term 1844

Thos. Jefferson
vs
Milton W. Hopkins

Trans: in change venue from Cir. Ct.

Clk fees - $4. 25

Shff Shff Milburn 2.50

$ 6.75

Filed Aug. 28, 1844N. Paschall
Clk $ 1.87

Jury verdict for Deft 6 p 129 mo. for new trial
overruled6 p 182.

oath

County Of St. Louis , ss.
The State Of Missouri ,To Wm Carr Lane ,
John Hildreth ,
Mrs Mahalia Dresden
Mrs Frances Hubbard
Greeting:—

You are hereby commanded, that, setting aside all manner of excuse and delay, you appear before
our St. Louis Court Of Common Pleas, at the City of St Louis , on the 25th October
next then and there to testify, and the truth to say in a certain cause pending
in our said court, wherein Thomas Jefferson is
plaintiff and Milton W. Hopkins is defendant
on the part of defendant and herein you are in no wise to fail

Witness, N. Paschall Joseph W ., Clerk of our said Court, with the seal
thereof hereto affixed, at office, in the City of St. Louis , this
22d day of October in the
year of our Lord one thousand eight hundred and forty four John Smith Clerk
N. Paschall Clerk

Thos Jefferson
vs
Milton W. Hopkins

Wits for deft.

Wm Carr Lane
John Hildreth
Mrs Mahalia Drexler
Mrs Franceis Hubbard

(for the two last witnesses
inquired of Mr Hubbard
of the firm of Hubbard &
Block, on main St opposite the market.)

Oct 25Executed Wm Milburn
Shrff fee $ 1.25

County Of St. Louis , ss.
The State Of Missouri ,To William Can Lane
Greeting:—

You are hereby commanded, that, setting aside all manner of excuse and delay, you appear
before our St. Louis Court Of Common Pleas, at the City of St. Louis , on the
25th October 1844 then and there to testify and the truth to say
in a certain cause pending in said court, wherein Thomas Jefferson is
plaintiff and Milton W. Hopkins is defendant
on the part of the plaintiff
and herein you are in no wise to fail.

Witness, Nathaniel Paschall, Clerk of our said Court, with the seal thereof
hereto affixed, at office, in the city of St. Louis , this 24th
day of October in the year of
our Lord eighteen hundred and forty-four.N. Paschall Clerk.

Executed this writ By a copy at the residence
of Dr Wm C Lane at the County of St Louis
this 24th day of October 1844.

William Milburn
Sheriff
By R Dowling Deputy Fee 50 Cts

ThomasJefferson
vs
M. W. Hopkins

Subp.

Wit. DrWm Carr LaneTo appear 25 Oct 1844 fee 50 cts

County Of St. Louis , Sct.
The State Of Missouri ,To the Sheriff of St. Louis County—Greeting:

We command you to attach Wm Carr Lane
by his body and him safely keep, so that you have his body
before the Judge of the St. Louis Court of Common Pleas, now in session at the City of St .
Louis , within and for the County of St. Louis , on theForthwith
184 then and there to testify and the truth to say in a certain matter of controversy,
now pending in said Court, between Thomas Jefferson
plaintiff, and Milton W. Hopkins defendant wherein
the said Wm Carr Lane has heretofore been summoned
on the part of the said defendant.

Witness, Nathaniel Paschall, Clerk of our said
Court, at the City of St. Louis , this 25th
day of October in the year of our Lord one
thousand eight hundred and forty-fourN. Paschall Clerk, C.C.P.

Thomas Jefferson
vs
Milton W. Hopkins

attacht for

Wm Carr Lane Forthwith.
Came in Court before
attachment was executed. Wm Milburn
shrff

Verdict

Thos. Jefferson
vs
Doct Prosser

We the Jury find
for the defendant

A G Cummingham
foreman

Thomas Jefferson
vs
Milton W. Hopkins

The Plff in this case by
his attorneys moves the Court
for a new trial, for the
following reasons

1st That the verdict is against law,

2d That the verdict is against the evidence

3d That the verdict is against to the law & evidence

4th That the plaintiff since the trial, has received
new and important evidence, without which
he cannot obtain a fair trial.

T B. Murdoch
for Plff

Thomas Jefferson , of color
vs
Milton W. Hopkins

Mo. & Reasons for new
trial.

Filed Oct 28 1844N Paschall Clk

Refused

If the jury believe from the evidence that
Doctor Prosser had the change of the plaintiff
after the family of M. Dreschsler left St. Louis
for the South in May 1839 & that which such
charge existed, the plaintiff was permitted
by Doc. Prosser to be employed in the
State of Illinois & that subsequently Doctor
Prosser became & now is the owner
of the plaintiff they will find for the plaintiff.

Given

Jefferson
vs
Hopkins

Instruction asked by deft.

If the jury find from the evidence
that the plaintiff, while in the
State of Illinois , was the slave of Charles
W. Drechsler & do not find that he was
in that State with the knowledge and
consent of said Dreschsler, they will find
for the defendant.

Refused

If the jury believe from the evidence
that at the time the plaintiff was working
on the farm of Doctor Prosser in Illinois
Doctor Prosser knew it & was the general
agent of the owner of the plaintiff for
taking charge of plaintiff, they will
find for the plaintiff

In St. Louis Common Pleas Court.

The plaintiff asks the following instructions.

1 That the introduction of a slave into the State of Illinois
and then holding him to service and labor, by the owner of such slave, or by another, with the knowledge and
consent of the owner, is in violation of the laws and constitution
of that state, and works the emancipation
of the slave.

2. That the jury, may infer such knowledge and consent
from all the facts and circumstances attending the case.

3. That such knowledge and consent is a matter of
fact, for the jury to determine from all the facts and
circumstances, given them in evidence.

Refused

If the jury believe from the evidence
that the plaintiff ran away into Illinois
when Drechsler family left in May 1839 &
went to the farm of Doctor Prosser & there
was put to work & kept to work for several
months with the knowledge & consent
of Doctor Prosser & that Doctor Prosser
was the agent of Drechslerin for taking
change of the plaintiff at that time, they
will find for the plaintiff

Refused

If the jury believe from the evidence
that the plaintiff was slave of Doctor
Prosser at the time he was worked upon
his farm, they will find for the plaintiff.

Refused

If the jury believe from evidence that the
plaintiff was taken to the State of Illinois
by his owner or the agent of his owner & there put to
do labor in said State, they will find for the plaintiff.

Refused

4. That if the jury believe from the
evidence, that the plaintiff Thomas Jefferson was
taken to Illinois and there held to labor by Dr. Prosser or was by
him there kept or permitted to be kept at service and labor, the said
Prosser was acting in violation of law and constitution,
of Illinois , and he cannot, shield himself from
the effect of that violation, by setting up title to plttf subsequently
acquired

Thom Jef
vs
Hopkins