To the Honorable John M. Krum Judge of the Circuit Court of St. Louis County:

Your petitioner, Nat , a man of color humbly
represents to your Honor that he was purchased
and held as a slave by one Milton Duty, in his
lifetime, since deceased, that the said Duty
being then a resident of the State of Mississippi
by his last will and testament, dated the 26th
day of October 1836, directed that at his decease
your petitioner, among other slaves which he
then owned, should be manumitted and set
free and sent to the State of Missouri , of the
laws of said last mentioned State would permit
the same. Your petitioner further represents that
the said Duty removed your petitioner, amongst
other his said slaves, to the said State of
Missouri , in the month of March 1837, and in
the month of August 1838 departed this life
in the city and county of St. Louis and State
of Missouri , having made no other will than
the one above-mentioned; that the said will
was, as your petitioner is informed and believes,
established and admitted to probate in the Pro-
bate Court of Warren County in the State of
Mississippi on the 26th day of November 1838,
and on the 22nd of June 1839, was recorded as
the last will and testament of the said Duty
in the County Court of St. Louis County and letter
of administration thereof granted to one George
W . Coons of the said city and County of St. Louis ,
who now, as your petitioner verily believes,
wrongfully and unjustly holds him in slavery
Your petitioner therefore humbly prays that he
may be permitted to prosecute this his suit for
freedom as a poor person, that counsel be as-
signed him, and that the orders, prescribed by
Statute in such cases, be made in his be-
half, and as in duty bound he will ever
prays &c.

Nathaniel his Mark

State of Missouri
St. Louis County
ss.

This day personally came before
me the undersigned, the above named petitioner
Nat , who being duly sworn on his oath says
that the facts Stated in the foregoing petition
are true to the best of his knowledge and be-
lief.

Sworn to and subscribed
before me this 4th Day
of June 1844. Alphonso Witmore Nathaniel his
MarkJustice of the peace

State of Missouri
St. Louis County
ss.

Nat , a man of color plaintiff com-
plains of George W. Coons defendant of a plea of trespass
and false imprisonment, for that the said de-
fendant on the tenth day of June A.D. 1844,
with force and arms, at the County aforesaid
assaulted the said plaintiff and then and there
beat, bruised, and ill-treated him, and then
and there imprisoned him, and kept and
detained him in prison there, without any
reasonable or probable cause whatsoever, for
a long time, to wit: for the space of six hours
then next ensuing contrary to the will of the
said plaintiff and contrary to the laws of the
State of Missouri :

And the said plaintiff avers that before
and at the time of the commission of the griev-
ances by the said defendant above mentioned, he
said plaintiff was and still is a free person
and that the said defendant held and still
holds him in slavery, against the peace of
the State of Missouri and the liberties of the
people thereof, and to the damage of the plain-
tiff, of five thousand dollars, wherefore he sues

Risque & Townsend
for plff.

St. Louis Circuit Court
November Term 1844,

Nat . (a man of color)
vs.
George W . Coons

Suit for freedom
Let Summons issues

Risque & Townsend Make the usual
orders & R & T.
appointed as
Counsel

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

We command you to Summon George W. Coons 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 Nat
a man of color of his petition for freedom
to the damge of said plaintiff
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 eleventh day of
June 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 filed 15 p 292.Mo to dismiss & reasons therefore filed 16 p 202. mo overruled
16 p 247. Jury verdict for Deft Jany 27 1846. 17 p 59. Mo for new trial &c 17 p 64
mo overruled & bill of exceptions filed 17 p 76 mo & appeal filed same prosecuted 17 p 90

No 35 St Louis Circuit Court
November term 1844

Nat (a person of Color
vs & summons
12th June
George W . Coons

Suit for freedom

Risque & Townsend

On hearing petition it is ordered that the petitioner be permitted to sue as
poor person to establish his right to freedom
and the Court doth assign Risque
& Townsend as his counsel and that he have reasonable liberty to attend the court
and his counsel as occasion may require
that he be not removed out of the jurisdiction of this Court
and that he be not subjected
to any severity an account of his applica-
tion for freedom.

John M Krum Jud 8th CirFiled June 11th 1844 John Ruland Clerk free

Executed this within the county
of St. Louis on the 12th day of June 1844 by
offering to read it and the declaration for
George W. Coons , the defendant which he refused
to hear Also by reading to the said George
W Coons the orders of the Judge endorsed upon this writ

William Milburn Shff
by A. C. Osburn Depy Fees $ 1.50

Nat (a person of color)
vs
George W. Coons In the St Louis Circuit
Court
Nov Term 1844

And now comes the said defendant, George W. Coons
by his attorney, and says that he is not guilty of the
said several supposed grievances or either of them
in manner and form as the same are by said
plaintiff in his declaration above charged and
alleged against him and of this he puts himself
upon the county &c

And for a further plea in this behalf the said
defendant says that the said def plaintiff was
not at the time of the commencement of this
a free person, in manner and form as in said
declaration above alleged against him and of
this he puts himself upon the country & c

J B Walker
atty for Deft.

Nat (a person of color)
vs
George W. Coons

Plea

J B Walker
atty for DeftFiled Nov 18th 1844 John Ruland Clerk

Nat
A Person of color
vs
Geo W Coons adm of
Milton Duty DecdIn St Louis Circuit Court
April Term 1845

And the said deft by his
attys comes and moves the Court to dismiss
and cause for the following reasons

1 Because the process issued in this cause
was illegal and granted withoutauthority of law

2 Because the said plff had no right to
institute an action without firstfinding an affidavit
according to the provisions of the statute
in such case made & provided

3 Because there is no sufficient affidavit filedherein

4 Because said supposed affidavit
is informal & insufficient & illegal

5 Because said plaintiff being a negro
he could not make an affidavit against
the deft who is a white man

6 Because the said complaint & affidavit
are in other respects informal & insufficient

7 Because the Clerk acted without legal
authority in permitting the plaintiff to sue
in manner aforesaid

Walker & Hudson atty for
deft

Nat of color
vs
Geo W Coons admn,

Motion to dismiss

Walker & Hudson
attys for deftFiled 9 May 1845 John Ruland Clerk

Nat of Color
vs
George W Coons

We the jury in the above
entitled cause find the defendant not guilty
in manner & form as charged in the
plaintiff's declaration

A Bryanforeman

Nat of color
vs
Geo W. Coons

Verdict for Deft

Nat (a person of color)
vs
Geo. W . Coons In St Louis Circuit Court

And now comes the said plaintiff by his attorney
and moves the Court toset aside the verdict of
the Jury, rendered in this cause, and for a new
trial for the following reasons, viz:

1. Because said verdict is against law.

2. Because said verdict is against the evidence given in
said cause.

3. Because said verdict is against the weight of evidence.

4. Because said verdict is against law and evidence.

5. Because the court rejected legal & competent evidence
offered by said plaintiff.

6. Because the Court misinstructed the Jury.

7. Because the Court refused to give legal instructions
asked by said plaintiff.

8. Because the Court admitted illegal & improper evidence
on the part of the defendant in which were objected to
by to plaintiff -

Jas B.Townsend
for plff.

St. Louis Circuit Court

Nat (a person of Color)
vs
Geo. W . Coons

Motion by plff. for new
trial

Filed Jany 28. 1846 Jn. Ruland Clk

Nat (a person of color)
vs
Geo. W. Coons In St. Louis Circuit Court

Be it remembered that on the trial of this cause
to wit : on the twenty seventh day of January
A. D. 1846. the said plaintiff offerred in evidence
a certified copy of the record of the authenticated copy of the
will of Milton Duty decd. and probate thereof
as recorded in the probate court of St. Louis County,
which is in the words & figures following to wit:
(here insert said copy and certificates marked A.) to the reading
of which as evidence the defendant by his counsel
objected, and the court sustained the objection
and excluded said copy, to which exclusion
the plaintiff by his counsel then and there ex-
cepted ; the plaintiff then offered the original
authenticated copy of said will and probate thereof with the certificate of the clerk
of the county court of St. Louis county that the
same were recorded in his office in the words & figures following (here
insert said copy and certificates, marked B.)
to the reading of which in evidence the defendant by his
counsel objectedand the objection was overruled and the court overruled
said objection allowed said that men-
tioned copy to be read to the jury ; the plaintiff then offerred
in evidence and read to the jury the following
extracts from the statutes of the State of Mis -
sissipi No. 1 to wit (here insert § 2 page 385, of
the Statutes of the State of Mississippi compiled
by V. E. Howard and A. Hutchinson, published
in 1840 also insert § 11 at page 387, also § 12
page 388, also § 17 page 389, also § 18 of Article
of constitution of Mississipi, also § 1 & 2 pages
468 or 469, also § 10 & 12 at page 470, of same
statutes, compiled and published as aforesaid)
also said plaintiff offerred and in like manner
read to the jury, the following section of the consti-
tution of the state of Mississippi to wit : (here
insert the 18 section 4th Article of constitution
of state of Mississippi from page 26 of same
compilation). Plaintiff then examined as
a witness for him Richard Dowling, who
stated that he knew Milton Duty in his
lifetime, that said Duty was residing at the
time of his death in the city of St Louis , state
of Missouri , that he recollected the time of
said Duty's death, having been at his residing
a few minutes thereafter, that said Duty
was, in his opinion, upworth of 30 years
of age at the time of his death, that said
Duty, in a conversation which witness had
with him some few days before his death,
declared that he intended to fee free his slaves, some 30 in number
at his death, as he
had made a will to that effect, that
the negroes of said Duty were in the
city of St Louis at the time of his death,
and that witness had seen the plaintiff
at the house of said Duty prior to his
death. Plaintiff then examined David
Adams, as a witness on his behalf, who stated
that he was acquainted with said Duty in
his lifetime, that said Duty, at the time
of his death, was residing in the lower part
of the city of St Louis , near to witness, that
said Duty died in St. Louis in the year 1837
or 1838, that he had been residing in
said city some months, witness could
not say how long, previous to his death,
that said Duty removed from the state of Mississippi to the state of Missouri and brought

Insert at (No. 1) in marginofBill
of Exceptions

[1A] no. 1 # The title page of which is in the words & figures following
to wit, (here insert title page of statutes) The defen
plaintiff that then produced Briggs, who testified
that he had practiced law some 8 years in the state
of Mississippi , and that the said copy, of state the
statutes was the one generally used in that state
as the one printed by authority of law in that
State, and was procured by him from the clerk of
a Court of Record in that state- To the reading
of which extracts from said copy of the statutes
and to the testimony of said Briggs the defendant
objected, and the objection was overuled by the Court
and the defendant excepted to saiddecision overruling
the same, and the plaintiff then read in evidence
the following extracts from saidstatutes,

his negroes with him from said state of Mis-
sissippi to said state of Missouri , that the plaintiff, here in court, is one of said Duty's
negroes, but witness did not know his
name, that said Duty had some 25 or 30
negroes at the time of his death. Plaintiff
then examined James Adams , likewise a
witness for said plaintiff, who stated that
he was acquainted with said Milton Duty
now deceased, that said Duty lived in
the city of St. Louis , and about 75 feet from
the residence of witness, that said Duty
died in said city in July or August in the year 1838 or 1839, that said Duty came to
St. Louis from the lower country and brought
his negroes with him, that plaintiff's name
is Nat , and that he said plaintiff Nat
was one of the negroes of Milton Duty,