Archibald Barnes, an infant, by and through his next friend, Peter Charleville v. Jon Berry Meachum
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To the honourable Luke E. LawlessLuke E Lawless . Judge of the
St. Louis County Circuit court.

The petition of Archibald CharlevilleBarnes of
St. Louis County and State of MissouriMissouri. who is an infant
within the age of twenty one years to wit the age of
sixteen years, and who appears by his next friend
PeterPeter CharlevilleCharleville respectfully represents. That
your petitioner is a person of colour, and the
son of parents who were at the time of his birth
and still are, free. That your petitioner is un
lawfully restrained of his freedom and held
in confinement by a certain BerryBerry Mitchell Meachum MitchellBerry Mitchell Meachum
MeachumBerry Mitchell Meachum a man of colour residing in St. LouisSt Louis MissouriMissouri
who claims your petitioner as his slave. Your
petitioner shows to your honour that the said
MitchellMitchell Meachum MeachumMitchell Meachum does treat the your petitioner with
great inhumanity harshness and severity:
and that, your petitioner fears that the
said MitchellMitchell Meachum MeachumMitchell Meachum will remove him unjustly and
unlawfully beyond the limits of the StateMissouri
of MissouriMissouri (as he has aften made threats of
doing) in consequence of this application
to your honour. Your petitioner avers that,
he is now free: that he was born free: and
that by no act of his own, nor by any pro-
ceedings of any anthoritative tribunal has
his right to his freedom been forfeited: but
that he is forcibly abridged of the same
by the said MitchellMitchell Meachum MeachumMitchell Meachum as aforesaid.

In consideration whereof may it please your
honour to grant unto your petitioner permission
to sue for his freedom as a poor person: and further
may it please your honour to grant a warrant dire
cected to the Sheriff of St Louis County, commanding
him to seize the your petitioner & have him before this
court, and to summon the said MitchellMitchell Meachum MeachumMitchell Meachum or other
person in whose hands the said petitioner may
be found. to appear before this court on a

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day and at a place to be therein specified and
receive such order as the court may make in the
premises: and give security to abide by the same
And that it may please your honour to
grant unto your petitioner such other & fur-
ther relief as to your honour may seem fit and
the nature of the case may require and as in
duty &c.

J. J. Gantt. for petr