Josiah Cephas, a colored boy, by and through his next friend, Diana Cephas v. James Scott and Murray McConnell
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To the Hon. Luke & Lawless Judge of the
Circuit Court of the County of St LouisCounty of St Louis

The petition of JosiahJosiah Cephas CephasJosiah Cephas a colored boy, aged
two years and seven months, by his next friend
and mother DianaDiana Cephas CephasDiana Cephas , respectfully represents
to your honor, that in the month of April eighteen
hundred & thrity eight, he was born a slave on
the Eastern shore of the state of MarylandMaryland
where he continued to reside, until the spring of
the year Eighteen hundred and thrity nine
when he with his mother the said DianaDiana
were brought to the Country bordering on the
MississippiMississippiriver by one MarkDelahaDelaha
owner and master of your petitioner & his mother
the said DianaDiana . That the said DelahaDelaha in
the month of July Eighteen hundred and Thirty
nine settled at NaplesNaples on the IllinoisIllinoisriver in
the State ofIllinois IllinoisIllinois and took the said JosiahJosiah
your petitioner with him together with his said
mother DianaDiana , where both he and his said mother
remained from that time until the month of February
last past. That said DelahaDelaha made the
said town of NaplesNaples his place of abode and
hired out the said DianaDiana mother of your
Petitioner to labor and received the rewards of
her labor. That in the month of August 1839
the wife of said DelahaDelaha died at said
town of NaplesNaples. That in the month of
February last the said DelahaDelaha left the
said town and wentsouth as petitioner
believes for the purpose of residing there
that in the same month of February
last past, one MurryMcConnellMcConnell , pretending

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to be the owner of your petitioner, brought
your petitioner together with said DianaDiana his
mother, on board of a steam boat, then lying
at said town of NaplesNaples, and them
to the City of St LouisCity of St Louis in the State of MissouriMissouri
where he now is
in the custody and keeping of one JamesJames Scott
ScottJames Scott , who pretends to hold him under
the said MurryMcConnellMcConnell , and unjustly
and illegally deprives him of his liberty
& freedom. Yourpetitionerbelieves
that under this state of facts, that he
isentitled to hisfreedom, and prays
your honor to grant him leave to sue as
a poor person in order to establish his right
to freedom, against the said James ScottJames Scott
orsuch other person as may claim your
petitioner as a slave and your petitioner
will pray &c.

A King

Josiah by
his next friend
DianaDiana Cephas CephasDiana Cephas her