To the Honorable John M . Krum Judge of the Circuit
Court of St Louis County. Your Petitioner
Malinda a woman of Colour. would Humbly represent
unto Your honor. That she was purchased
and held as a slave by one Milton Duty in
his life time, since deceased, that the said
Duty atthe time, and long before his death
was a resident of the City and County of
St. Louis Your Petitioner would further
represent that the said Duty before his
removal to the State of Missouri was
held your petitioner as his slave, long before
he removed from said State to the State
of Missouri . your Petitioner as his slave long before he removed from said state to the State
of Mississippi Your Petitioner further states
that before the said Duty moved from
the State of Mississippi to wit in the
Year of our Lord1836 he made his
Last Will and Testament in which he
directed at his decease, that your said
Petitioner among a number of other slaves which he owned should be manumited
and set free in the month1837.AD. the
said Duty moved to the State of Missouri
and brought with him your Petitioner
together with a number of other slaves owned
by him at that time, and in and in the
following year the said Duty departed
this life in the City of St. Louis having
made no other will or disposition of said
Your Petitioner, there is mentioned in said
will The said will was established and admited to record in the County of Warren

and State of Mississippi in the Probate
Court of said County on the 26th day of
November 1838AD., and on the 22nd day
of June 1839was duly admited to record
as the last will and testament of the
said Duty in the County Court of St Louis
County, and letters of administration
thereof granted to George W . Coons of said
County and City of St Louis , who now
as your Petition states wrongfully and
unjustly holds your Petitioner in slavery
and has caused her to be commited
and confined in close custody in the Jail
of said County without any reasonable Cause therefor..

You Petitioner therefor Humbly prays
your honour that she may be allowed
to prosecute her suit for her freedom against
the said Coons , as administrator, as
a poor person and their Counsel be
assigned her and that she discharged
from her present and un unjust illegal
imprisonment and that the several
orders be made in her behalf
touching the persons and in duty
bound she will pray

Malinda herxMark Duty

State of Missouri
St Louis County

this day personally come before
me the undersigned Justice of the peace
in and for the County and State afore-
said. Malinda (a person of Color) Who
has included the above Petition who being
duly sworn desposes & says That the facts
therein contained and set forth are
true to the best of her knowledge and
belief. Given under my hand this
22nd day of July 1843

Malinda herx mark Duty
Sworn to & Subscribed
before Me this 22nd of July 1845
Peter Cruess
Justice of the Peace
St louis Co. Mo.

This day personally appeared before me the under
signed a white person of lawful age a Justice of the Peace who being
duly sworn deposes and says that he is
well acquainted with Malinda who subcribed
the foregoing petition: and verily believing
that the statements
State set forth in
said petition are true, as he is informed
and verily believes witness my hand this
22nd day of July 1845.

State of Missouri
County of St Louis SS

This day personally appeard
before me the undersigned William Burchstead
who being sworn according to Laws makes oath
says that he is acquainted with the Petitioner Malinda ; and believes that the Statement set
forth in her said Petition in relation to her freedom
is in talked to further states that from the information he has received he believes she
is entitled to her freedom

William Burchsted
Sworn to & subscribed before
Me the this

23 day of Aug. 1845
Sheinhman
Justice of the Peace St Louis County, Mo

Malinda (of color)
Petition to sue
for freedom - - - -

Vidi &
p 28

On reading & considering the within & foregoing Petition it is ordered that
the said Petitioner Malinda be allowed to institute a suit to obtain her
freedom on giving security satisfactory to the Clerk of the St. Louis
Circuit Court for all costs that may be adjudged against her. And it is further ordered that the said Malinda have reasonable liberty to
attend her Counsel the said Court as occasion may require & that
she be not removed out of the jurisdiction of the Court
& that she be not subject to any severity on account
of her application for freedom & that Col. A. P. Field be & is
hereby appointed to prosecute suit for freedom.
St Louis Augt. 25. 1945

John M Krum Judge 8. Jud. Cir

In the Circuit Court

Declaration In
Trespass & False im
prisonment
October November Term 1843
This is an action of
Trespass & false imprisonment
The clerk will issue a
summons returnable to
the next Term of the
Circuit Court .

A P Fields
for Plff

In the Circuit Court .
of St Louis County
October November Term 1845.

Malinda a woman of color by A P
Field her attorney complains of George
W . Coons administrator: of the estate of
Milton Duty deceased, in custody &c of
a plea of trespass and false imprisonment
for this to wit that the said
defendant on the twentyfifth day of
May in the year of our Lord one thousand
eight hundred and forty five at
the County and Circuit aforesaid and
within the Jurisdiction of this Court
with force and arms assaulted the said
plaintiff and there and then beat bruised and
ill treated her and there and then imprisoned
and kepted and detained her in prison for a
long space of time to wit for the space
of six months then next unsuing against
The will and consent of her the said plaintiff
and contrary to the laws of the State of Missouri
and the liberty of the people thereof and the
said plaintiff avers that before and at the
time of the commiting of the said grievances
by the said defendant plaintiff
was and still is a free person and the said
defendant wrongfully and unjustly held
and still holds the said plaintiff in slavery
and other wrongs to the said plaintiff there
and then did, against the peace and and dignity of the State of Missouri and
to the damage of the said plaintiff one
thousand dollars and therefore she sues

A P Field
Attorney for Plaintiff

In the Circuit Court
November Term 1845

We do duly in the ourselves security for the
costs in the above cause, need do bind ourselves
to pay all costs may be adjudged against
the said plaintiff in the forgoing cause.
Witness our hands & seals this31st day
of October 1845

A. P. Field

D. N. Noll

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 , administrator
of the estate of Milton Duty deceased, 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 Mon-
day of November instnextthen and there to answer unto Malinda , a
woman of color, of a plea of trespass and false im-
prisonment
to the damage of said plaintiff one thousand 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 first day of
November in the year of our Lord eighteen
hundred and forty-five. John Ruland Clerk.

On reading & considering the within & foregoing petition, it is ordered that the
said petitioner Malinda be allowed to institute a suit to obtain her freedom
on giving security satisfactory to the clerk of the St. Louis Circuit Court
I acknowledge myself bound for all costs that may accrue in the above cause.
for all costs that may be adjudged against her. And it is further ordered
Witness my hand and seal, at St. Louis , this day of 184 that the said Malinda have reasonable liberty to attend her counsel
& the said Court as occasion may require & that she be not
removed out of the jurisdiction of the said Court, & that she be
not subjected to any severity on account of her application for

plea filed17p289contd17p27717p. 449cond17p 625dismissed at plff's costs
& exa 18p 315.

No 220
St. Louis Circuit Court November Term 1845

Suit for freedom

A. P. Field att
Filed 1st November 1845
John Ruland Clk
$1.00 pd by att (215)

Executed this writ in the
County of St. Louis on the 4th day of
November 1845by offering to read it
and the decleration to George W Coons
admr &c, the defendant which he refused
to hear and by reading to the said George
W Coons the orders of the Judge in this
case

William Milburn Shff

Service $ 2.00 By A C Osburn Depy

freedom, & that Col A. P. Field be & he is hereby appointed to prosecute the said suit for freedom.

John M Krum Judge 8th Jud.Cir.
St. Louis Augt 25.

In the Circuit
Court
November April Term
1845

And now comes the said defendant, George
W. Coons by his attorney, and defends the
force & injury, when &c, and says that he is
not guilty of the said several trespasses & grievances
in the said plaintiffs declaration charged
against him, nor of any or either of them
in manner and form as therein charged and
alleged against him, and of this the said
defendant puts himself upon the country &c

M B Walker
atty for Deft.

Plea not guilty
J B Walker
atty for Deft

Filed 20 April 1846
Jn Ruland Clerk