To the Hon,. Bryan Mullanply, of the Circuit
Court of the County of St. Louis , State of Missouri

The petitioner of Jonathan ,, a man of color, aged
about thirty four years respectfully represents, that
he was born, a slave, in the
state of Virginia ,, and brought, by his master Edward
Gleason , to White County Tennessee ,, where he continued
to reside, with said Edward Gleason , as his slave,
until his death, when your petitioner on the division,
of said Gleason , estate among his children,, became,
the property of James Gleason , one of Edward Gleasons,
sons,, that said James , D Gleason moved, to
the state of Illinois ,, and in the year eighteen hundred
and thirty one brought your, petitioner to St Louis , in
the state of Missouri , and hired, him out and
the wages of his hire, that said James D Gleason ,
resided, in the County of Madison in the state of
Illinois until the year eighteen, hundred and thirty five,
he then died, that frequently the time your
petitioner came to St. Louis in Missouri in the year
eighteen hundred and thirty one to the time of the death
of the said James , D . Gleason ,, your petitioner was taken
to the state of Illinois , by his master, and there held
to labor, that on one, occasion, he was taken, by the
said James D Gleason , in the year eighteen, hundred
and thirty two or three, from, St. Louis in Missouri ,, and
brought to his Gleason farm, in Madison
County Illinois ,, where he remained, for a period, of
about eight months at labor, for the said Gleason , as his
slave, - that in the year eighteen hundred and thirty
five said Gleason , died leaving, a widow,, now intermarried,
with Willoughby ,, and a son now
living William Gleason , - that the said Willoughby ,
married, said widow, in eighteen hundred and thirty eight

that shortly after this marriage,, a seperation
took place between them on account of the bad conduct,
and habitual,, of the husband,
and a bill for divorce, at the suit of the wife
Eleanor Willoby, is now defending in the Madison ,
Circuit Court , Illinois , - that at the present,
term of the St. Louis Court of Common Pleas one
Joel Dannah, obtained judgment against said
Aza Willoughby and an execution was issued,
and a levy made, upon your petitioner
as Aza , Willoughbys property, by the Sherrif, of
St. Louis County Marshall Brotherton , in whom
custody, he now is confined in the jail of said County,
although your petitioner never, was in said Aza Willoughbys,
possession, nor, has he ever received, any portion,
of your petitioners wages as he claims,. Under, these
state of facts, your petitioner believes that he is
entitled to his, freedom, and with the full consent,
of the widow, of James D . Gleason , now the wife of
said Aza Willoughby ,, who is guardian, of her, only child
living, by her first, husband, he prays your honor, to
allow him to sue, as a poor person, in order, to
establish, his right to freedom.

Jonathan , & his mark,

State of Missouri
St. Louis County ss

Jonathan , a man of color,
being sworn says, that the facts set forth, in the
forgoing petitioner are just true,

sworn to submitted, the
16th September 1841
before, me
Jonathan ,X his mark,

Alphonso Witmore ,
Justice of the peace.

I Bryan Mullanphy ,, Judge of the Circuit court
of St Louis County, being of opiniion that the
foregoing petition, contains sufficient matter
to authorize the commencement of a suit, do
make the following orders.

First. That Jonathan , a man of color be allowed
to sue as a poor person to establish his right
to freedom, and
as his counsel.

Second. That the person Jonathan , 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.

Bryan Mullanphy Judge 8th

State of Missouri
St Louis County ss.

The facts set, forth in the forgoing petition are just and
true and my full consent, is hereby given to Jonathans,
suit for freedom.

Eleanor Willoughby ,

Writ for Petitioner

George

In the Circuit Court of St Louis County
State of Missouri
St Louis County ss.

Jonathan , a man of color, complains
of Marshall Brotherton , Jose Darrah,
and Aza Willoughby , of a plea of trespass,, for
that the said defendants on the fifteenth day
of September eighteen hundred and forty one
with force and arms assaulted the said plaintiff
to wit at the County aforesaid, and then and there
beat, bruised, and illtreated him the said plaintiff,
and then and there imprisoned him the said
plaintiff 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 twelve hours, contrary to the laws
of the said state and aganist the will of
the said plaintiff- And the said plaintiff
and declares,, that before and at the
time of the committing the said grievence
by the said defendants, he was and still is
a free person and that the defendants held
and still hold him in slavery.

Wherfore the said plaintiff says he is injured
and hath sustained damage to the
amount of dollar and therefore he brings suit .

King & for plff,

In Circuit Court of St Louis .
November Term 1841

Joel Darrah, and
Aza Willoughby ,
in false imprisonment
suit for freedom

The clerk, will issue,
summons in this
entitled cause,
to the Coroner, of St Louis
County .
King

Murdoch ,
attys, for plff,>

The State Of Missouri , County of St. Louis , ss.To the Coroner of St. Louis County-Greeting:

We command you to summon Marshall Brotherton , Joel Danah and Aza Willoughby , if they
be found in your County, that they be &
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 , on the third Monday
of November next, then and there to answer unto petition
of Janathan, a man of color, of a plea of
trespass
to the damage of said plaintiff of one
dollar: 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 seventeenth day of
September in the year of our Lord eighteen
hundred and forty one. John Ruland Clerk.

I. Bryan Mullanphy Judge of the Circuit Court of St. Louis County
being of opinion that the foregoing petition contains sufficient
matter to authorize the commencement of a suit, do make the
following orders.

First that Jonathan , a man of color, be allowed to sue as a poor
person to establish his right to freedom, and do assign King & Murdoch as his counsel.

Second. That the person Jonathan , 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.

Bryan Mullanphy Judge 8th
Jud.Cir. of Mo,

Executed this writ on Marshall Brotherton in St Louis
County on the 17th day of September 1841 by offering
read the within Petition and Summons to him and
he refusing, to hear the same Joel Danah , & Aza Willoughby ,
not found in my County

of St Louis County
fees $2.00

no 32
St. Louis Circuit Court
November Term 1841

Suit for freedom $1:00

King Murdoch

Filed 17th September 1841 Jn. Ruland Clk
free

for plff Bk 13 p, 557 for 12 p, 424

St. Louis Circuit Court .

Take Notice, That on the thirtieth day of September in the
year of our Lord one thousand eight hundred andforty one between the hours of
eight, in the forenoon andsix in the afternoon, of that day, at
the office of Louis S . Labeaume , in the
City of St Louis , County of St Louis , state of
Missouri
depositions will be taken by the undersigned, to be read on the trial of the above entitled case, on
behalf of the plaintiff; and that the taking of said depositions, if not completed
on that day, will be continued from day to day, at the same place and between the same hours,
until completed.
To the above named Defendants

King & Murdoch attys, for Plff St Louis 25 Sept 1841

Noticed to take
Deps.

I served, of copy of this notice on M.Brotherton
St Louis 25 Sept 1841

F. B .

I also a copy of this notice in ; office Cir . Court
St Louis the same up . 25 Sept 1841

F. B .

I left a a copy, this notice in the office of H.S .Sayer with 6 C.
a white person, over the age of 21 years. The 25 sept 1841. is
not yet atty of reason in this can, no atty bring marked, but he is atty for
Danah is Ex and that he would appear atty
I have left, this notice.

B

Opened & filed 29 October 1841

Jn Ruland Clk

Depostions for plff

Justice Labeaume , Fee $1.

Deposition of a witness produced, sworn and examined, at the
office of Louis Labeaume , in the City County of St Louis ,, Missouri
before me Louis Labeaume , a justice of the peace for the
county aforesaid, in a certain cause pending in the
St. Louis Circuit Court for the County of St. Louis in the state
of Missouri , between Johnathan (of color) plaintiff
and Marshall , Brotherton , Joel , Danah & Aza Willoughby
defendants,, on the part of the plaintiff

Samuel Jackson , of lawful, age being produced,
sworn and examined deposeth, and saith, that
he has been living in St Louis , and about the County
seventy two, years, I know the plaintiff
Johnathan for about years, I have
seen him to day two, or three, times, A
Mr. James Gleason , brought the plaintiff
to this County from Tennessee ,, that
Gleason , settled in Madison , County Illinois ,
about four miles from the River ,, Gleason ,
took Johnathan whom he claimed, as a
slave, over and to his farm, in Illinois , &
kept, him there six, or eight months, at
labor - Deponent has frequently, seen
said Johnathan plaintiff working on the
farm of Gleason splitting, rails, &
chopping wood, - I remember, of said
Johnathan being hired, out to one Brady in
Illinois ,, at twenty five cents, for one day, by
his master, that, is the only time, I knew
of his being hired, out, I was, living at the
time in Illinois ,, Brady a neighbour

and brother in law of James Gleason , after
Johnathan had months
in Illinois ,, he was brought to this state &
hired, to Danie D Page by said Gleason ,
I actually saw, Johnathan at work in this
City for said Page - At the time Johnathan
was laboring in Illinois ,, he was a healthy
and able bodied, man and further,
this deponent saith not,

Saml Jackson , Sworn to and subscribed,
before me, this 30th day
of Sept 1841
Louis Labeaume J, P.

State of Missouri
County of St. Louis

I, Louis Labeaume ,
a justice of the peace within and for the
County aforesaid, do hereby Certify that
Samuel Jackson the, deponent was, by me
sworn to testify, the whole truth, of his
knowledge touching the matter, in Controversy
in the cause aforesaid: that deponent, was
examined, and his examination by me reduced
to writing and subscribed by said deponent, in my
presence, on the 31st day of September 1841,
and between the hours of eight o clock in the forenoon
and six o clock in the afternoon of said
day, at my office, in the City & County
of St , Louis , State of Missouri ,.
Given, under my hand this day, of October 1841

Louis Labeaume , Justice.

St. Louis Circuit Court
No. November Term 1841

And the said, defendant
Marshall , Brotherton by
his attorneys, comes & defends therefore denying,
that he is, not guilty, - of the, said suppe
sed trespass, above to his charge or any
in manner form as the said plaintiff,
hath upon and to
this he puts himself upon the, County

&
and, the plaintiff
B.

No. 32,
St. Louis Circuit Court ,

Plea not

Filed November 15 1841 Jn. Ruland Clerk

County of St Louis , ss.The State Of Missouri ,To Francis Gleason , & Alfred Sparks ,
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the 31st day of August 1842
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 Jonathan (of Color) is
plaintiff and Marshall Brotherton , is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this 30th day of August
in the year of our Lord one thousand eight hundred and
forty-two. Jn. Ruland Clerk C.C.

in the County of St. Louis

Served, this Subpoena by reading, it to
Francis Gleason & Alfred , Sparks the
31 august 1842 William Milburn , Sheriff

Fee $ 1.00 by Richard H Pitts Dpty.

writ

x Francis Gleason , x Alfred Sparks ,

County of St. Louis , ss.The State Of Missouri ,To Samuel Jackson ,
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the 31st day of August
1842 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 Jonathan (of Color) is
plaintiff and Marshall , Brotherton is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Witness, John Ruland , Clerk of our said Court, with the
seal thereof hereto affixed, at office, in the city of St. Louis ,
this 30th day of August in
the year of our Lord one thousand eight hundred and
forty-two Jn. Ruland Clerk, C.C.

witness

Samuel , Jackson 31 Aug. 1842

County of St. Louis , ss.The State Of Missouri ,To George F Gleason ,
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , forthwith,
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 Jonathan , (a man of color is)
plantiff and Marshall Brotherton is,
defendant on the part of defendant,
and herein you are in no wise to fail.

Witness, John Ruland , Clerk of our said court, with the
seal thereof hereto affixed, at office, in the City of St. Louis ,
this thirty first, day of august in
the year of our Lord, one thousand eight hundred and
forty Jn. Ruland Clerk, C.C.

Sub

George F Gleason ,
forthwith,

Executed this writ in the County
of St Louis aug : 31st 1842 by reading
it to within named witness

Fee 50 William Milburn Sheriff,
by Richard H. Pitts ,
Deputy,

The defendant by
his attys moves, the court to set aside,
the verdict of, in this court,
grant a new trial, for the following reasons,
That the verdict, is against, law
That the verdict, is
That the verdict, is this
of

That the court gave,
wrong instructions to the jury,

That the defendant was or
the the of
with

Motion Reasons, for
a new trial,

Filed September 1st, 1842 Jn Ruland Clerk

If the jury find, from the evidence that
the defendant did not hold or detain
the plaintiff otherwise, than as sheriff
and by virtue, a writ of execution to have,
directed that at the line of the
the plaintiff was held as a slave
by the defendant in the executed the
jury, ought to find for the defendant
in action

If the Defendant laboured in Illinois , whether
voluntarily, or under coercion, ; either is a introduction
of slave labour into Illinois , such as
the right of the master to the slave in case,
the master knew of such labouring and assisted,
thereto unless, such labouring took place
while the master was taking such slave
thro, the state of Illinois ,
The object of the prohibition is to prevent the prohibition is to prevent the introduction,,
of slave labour into Illinois , not to prevent a
master from coercing, his slave.

If the jury believes, from the evidence that the plaintiff
went or was, taken to remain in the state
of Illinois , for the benifit of his health,
or upon, a visit to his owner while therefor
that not taking him out, as a
slave under the coercion, of his owner they
will find for the defendant

The plaintiff asks the following
instructions.

1. If the jury, believes from the evidence that James D Gleason ,
being a resident of Madison , County Illinois , and the owner of Jonathan , than the plaintiff as his slave, brought
him from the state of Tennessee , into the county of Madison ,
in the state of Illinois , and there held him to labor and service
for several months that they will find for the plaintiff

2.If the jury, believe from the evidence that said Gleason , being
the owner of the plaintiff as his slave, took him from a
state in which slavery is allowed, to Madison , County in the
state of Illinois , and there permitted the said Jonathan , to
remain for several months at a time whether at work or not
that he is entitled to his freedom and they will find for the
plaintiff

3.If the jury, believe from the evidence that said Gleason , being
a citizen and resident of Madison , County in the state of Illinois , and
owner of the plaintiff as his slave, whom he had hired in the city of
St Louis , in Missouri , brought the said plaintiff while labouring under
disease and sickness, from St Louis , in Missouri to Madison ,
County in Illinois , and there kept him for several months until his
recovery, that they will find for the plaintiff.

4.If the jury, believe, that the said Gleason , being the owner of
the said Jonathan , as his slave, kept the said Jonathan , in
Madison , County Illinois , whether before his sickness, or after his
recovery at labor for himself or permitted him there to remain
as, labor for his and benefit that they will find
for the plaintiff.

5. That by the ordinance, of of 1787 and the constitution
of the state of Illinois , slavery is probhitied in the territory
which forms that state and althought the owner of a slave
may without affecting his rights, in his slave while travelling
his slave property through that state yet there is
nothing in the law that justifies the idea that Illinois ,

is a slave hospital or that the master or owner
being there can in case of sickness, of his slave, move,
him from a state in which slavery is allowed to
Illinois , for the purpose, of attending to his recovery
unless, it be shown that it be absolutely necessary, for his
recovery.

6. If the jury, believe, that James D Gleason , being the
owner of the plaintiff as his slave, permitted him to
go Madison , county Illinois , and there to remain
for several months or allowed him there to remain
they will find for the plaintiff although it may be,
shown that said plaintiff went there or remained
there voluntarily, and did not there under the
coercion, of his master.

Circuit Court St Louis
County.

We the jury, upon our oaths do find
the defendant guilty of the trespass,grievance
and false imprisonment in and form as
the said plaintiff has alledged, against him

George F Gleason stated,, in
my in the presence
of W Dayton , that he knew the
plaintiff Jonathan , a man of
color - that said Jonathan ,
was brought from, the state of
Tennessee by, the brother, of
said Gleason , was the property
of his brother at the time of
his death - George F Gleason ,
came, to St Louis at the same time,
that said Jonathan came,
that the said Jonathan injured,
his foot or leg in was
cause sick in
that his
Brother send him into Illinois ,
for the purpose of having him,
cured of his
illness, that said Jonathan ,
recovered, for some time,
perhaps 6 or 8 months
but could not say precisely,
how long that while said
Jonathan , was in Illinois , he
was sick most, of the time, that
said Jonathan hired, himself
to labor, for a short time to
W Gleason , stated to
whom but I cannot, recollect
the name, to gather corn, that
said Jonathan , received
himself for his service,

George F Gleason , said that he knew
that his mother, never hired,
out said Jonathan , in the state
of Illinois , know also that
his mother, did not
the wages of said Jonathan ,
for any services said,
Jonathan rendered, in Illinios ,
said he know also that his
brother did not, know that
said Jonathan , had engaged,
his services to, anyone
in Illinois , until after
the said Jonathan , had
returned to Missouri ,
W Gleason ,also stated that Jonathan ,
while he was in Illinois frequently,
assisted in the business,
labor of the farm where he was
staying but he did so volun,
tarily at his, own instance,
W Gleason , said he knew
the facts above stated from the fact,
that he was with his
brothers, affairs lived immediately
adjoining, the farm, where said
Jonathan , was staying and saw
said Jonathan about every,
day, while he was in Illinois ,

If, the jury, believe from the evidence,
that any person having the right to the
Control or Services, of the plaintiff -
her to the state of to
and while or ramining in said
state the plaintiff for a
such person as a will find
for the plaintiff.

If the jury believe that the plaintiff
was to the state of Illinois by
any person having a right to
and that the ramained them for the
of or more
that the plaintiff remained in is
by the at the defendant
find for the plaintiff

If the jury from the
that any person having a right to the
services of said plaintiff his to
Illinous which then find and to
others-they will find for the plaintiff