trespass for false
imprisonment

PeterPeter , a colored man, plaintiff in this
suit, by his Attorneys, complains of John RichardsonJohn Richardson
defendant of a plea of trespass

For that the defendant heretofore, to wit, on the
first day of June in the year of our Lord one thousand eight hundred and thirty three, in DubuqueDubuque in the
Territory of IowaIowa to wit in the County of St. LouisCounty of St Louis
and State of MissouriMissouri, with face and arms made an
assault on said plaintiff and then and there beat,
bruised and ill treated him, and then and there imprisoned
him and kept him in prison without any reasonable
or probable cause whatever for a long space of time, to
wit for the space of one year these next following, countrary
to the laws of the State of MissouriMissouri and against the
will of the plaintiff, and other wrongs to the said
plaintiff then and there did against the peace
of the State of MissouriMissouri to the damage of the said
plaintiff in the sum of One Thousand Dollars.

And the said plaintiff covers that before
and at the time of the committing of the greivances
aforesaid by the said defendant, the said plaintiff
was and still is a free person, and that the defendant
held and still holds him in slavery