Stephen Brown, by and through his next friend, Jenny Brown vs. William Head
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State of MissouriMissouri
St. Louis County


The Circuit CourtCircuit Court of St. Louis County

Your petitioner purposefully states to St. LouisSt Louis
Court your Honor that the person mentioned in the declaration above held
in slavery by by WilliamWilliam Head in the County and that the now
Stephen BrownStephen Brown is entitled to his freedom in Consequence
of a certain grounding had in the the state of VirginiaVirginia to wit
Jenny BrownJenny Brown the Master of said StephenStephen was brought by her
then North into the state of VirginiaVirginia Contrary to the laws of the
said state of VirginiaVirginia by reason of which she was then and is now a free person and was afterwards brought
to the state of MissouriMissouri and in said state of MissouriMissouri kept in slavery against him with for more than
twenty years during which time the said StephenStephen was
born and is now at the age of Seventeen years

Your petitioner prays this court
a permit and allow him the said StephenStephen to sue as a free
person to establish his right to freedom and as in duty

Sworn to and subscribed before the 14th day of oct 1844

James JJames J Purely A Justice of the

County CourtCircuit Court for St. Louis County


Jenny BrownJenny Brown her mark