Brunetta Barnes, a person of colour v. John Berry Meachum
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To the honourable Luke E. LawlessLuke E Lawless Judge of
the St. Louis County Circuit CourtCircuit Court .

The petition of Brunetta BarnesBrunetta Barnes -
an infant within the age of twenty one years
to wit. the age of fifteen years, who appears by her
next friend PeterPeter CharlevilleCharleville , respectfully re-
presents. That she is a person of colour, and
the daughter of parents who were at the time
of her birth and still are, free- That your
petitioner is unlawfully restrained of her
freedom by a certain BerryBerry Mitchell Meachum MitchellBerry Mitchell Meachum MeachumBerry Mitchell Meachum in the
city of St LouisSt Louis and State of MissouriMissouri, said Ber-
ry MitchellMitchell Meachum MeachumMitchell Meachum being a man of color and by
profession a clergyman of the Methodist Baptist persua-
sion or belief: your petitioner shows to your honour
that she is detained by the said MitchellMitchell Meachum MeachumMitchell Meachum
and restrained of her liberty by virtue of a
claim proferred by said MeachumMeachum to have the ser-
vices of your petitioner as his slave. Your peti
tioner avers that she is of right entitled to her
freedom- that she was born of free parents &
that by no act of her own nor by the proceedings
of any authoritative tribunal has that right
ever been forfeited. but that she is forcibly abrid-
ged of the same by the said MeachumMeachum as aforesaid
your petitioner further shows that she is fearful of
being removed from the jurisdiction of this state in con
sequence of this application to your honour or in an-
ticipation of your honour's action thereupon. and
that the said MitchellMitchell Meachum MeachumMitchell Meachum treats her with harshness
and inhumanity. to wit by frequently & cuelly beat
ing her. In consideration whereof may it please
your honour to grant unto your petitioner permission to
sue for her freedom as a poor person: and futher may
it please your honour to grant a warrant directed
to the Sheriff of St. Louis County commanding him
to seize your petitioner & have her before this court
and to summon the said MitchellMitchell Meachum MeachumMitchell Meachum or other per

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son in whose possession your petitioner may be
found. to appear before this court on a day and at
a place to be therein specified, and receive such
order as the court may make in the premises &
abide by the same. And that it may please your
honour to grant unto your petitioner such other
and further relief as to your honour may seem
fit and the nature and equity of the case may re-
quire. And as in duty&.

ThosThomas T Gantt . TThomas T Gantt .GanttThomas T Gantt for Petr