Sarah v. Michael Halton
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Territory of MissouriMissouri
Northern Circuit

The United StatesUnited States of AmericaAmerica to the Sheriff of the county
of St LouisSt Louis Geeting-

You are commanded that You summonMichaelMichael Halter that he
be and appear before the judges of our Superior CourtSuperior Court of our Territory of
MissouriMissouri at our said Superior CourtSuperior Court to be held in and for the said
Territory at the town of St LouisSt Louis in the Northern Circuit on the
fourth monday in March next then and there in our said court
before our judges to answer unto SarahSarah a free girl of color held in salvery
in a plea of trespass assault and batteryand false imprisonment
to her damage five hundred dollars-and have you then and
there this writ and certify to our said court for you
execute the same-

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Witness the Honorable
residing Judge of our said court at St LouisSt Louisthis-
fourteenth day of december in the year of our lord one thousand and eight hundred and eighteen and of our
Independence the forty third

J C TurnerTurner Clk S. C. N. C.

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No 191

April Term 1821
Superior CourtSuperior Court


March Term 1819


Summons
SarahSarah a free girl
trespass &
false imprisonment

MichaelMichael Halter

To the clerk of the
Superior CourtSuperior Court N.E.
This is an action of
trespass& false imp
risonment damage
$500 on which you
will issue a summons
to the sheriff
of StSt Louis LouisSt Louis Territory.

J. BartonJ Barton & Geyer

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Michael Halton not found in this Bailwick
March 20th 1819

J. K. WalkerK Walker
Dshff

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now costs 50

travel 100ms-5.50

$6.000

filed April 26th 1879

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Superior CourtSuperior Court
Northern Circuit
Michael Hattan

SarahSarah

And the said Defendant by
RR Pettibone PettiboneR Pettibone his Attorney comes and defends
the wrong of injury when and as
to the assaulting beating bruising ill
treating and imprisoning and keeping
in prison the said Plaintiff as in her
said declaration mentioned the said
Defendant saith that the said Plaintiff
ought not to have or maintain her
aforesaid action thereof against him
because he says that before and at the
said time when in the said
mentioned, to wit, at the plan of within
the jurisdiction aforesaid the said Plain-
tiff was and still is the slave of him the said
Defendant whereupon the said Defendant
at the said time when he did beat
imprison & retain in prison the said
Plaintiff so being the slave of him the
said Defendant as he lawfully might
do which are the same
trespass whereof the said Plaintiff
hath above thereof complained against
him and this he is ready to verify-
whereupon he prays Judgement

RR Pettibone PettiboneR Pettibone atty


for Deft.
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And the saidSarahSarah saith she
might not to be bound and precluded
from having and maintaining
her aforesaid action by reason of
any thing by the said MichaelMichael Halton HaltonMichael Halton
above in his alleges because
she saith that at the said time when
in the declaration mentioned was
not the slave of the said MichaelMichael
in manner and form as he has
above in his said plea alleges
and this she prays may be en-
queried of by the county and
the said defendant doth the like

J BartonJ Barton atty

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Michael HaltonMichael Halton
ads
SarahSarah

Plea- replication

filed September 20th 1819

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St.Louis Circuit CourtCircuit Court

SarahSarah a free girl
vs
Michael HaltonMichael Halton

Febry Term-1822

On the trial of this cause it was
proved on the part of the plaintiff that one WinnieWinnie mothe-
er of the said plaintiff was carried into the now state
of IllinoisIllinois between twenty and thirty years since by
the said defendant and her husband when and where
the said WinnieWinnie was by then in slavery during the
space of three or four years; that at the end of said
time of three or four years, the said PhebePhebe with
her said husband removed to the now state of
missouri carrying the said WinnieWinnie with them in
which lst mentioned place the said WinnieWinnie has
been held in slavery ever since such removal
and that said plaintiff was born after such res-
idence of the said WinnieWinnie in IllinoisIllinois as aforesaid
the Counsel for the defendant then required the court
to instruct the jury that a residence in the then
North west territory (now IllinoisIllinois) as above mentioned
did not render the said WinnieWinnie free under and
in virtue of the ordinance of Congress of the year one thousand seven hundred and eighty seven
for the government of the territory of the UnitedUnited States
StatesUnited States north west of the river OhioOhio-which instruction
the Court refused but charged the jury that

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Said ordinance did in law set the said WinnieWinnie
free if it should appear to the satisfaction of the
jury that the said defendant and her then hus-
band resided in IllinoisIllinois with intent to make that
territory the home of themselves and the said -
To this opinion of the court delivered to the
jury the Counsel for the defendant excepted and
Prayed the court to sign and seal a bill of excep-
tions taken thereto which is done accordingly in
open court this tenth day of march in the year one thousand eight hundred and twenty two.

N. S. Tucker

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St. Louis Circuit CourtCircuit Court

Sarah a free girl
vs
Michael Hatton

Bill of exceptions

PettibonePettibone & SpaldingSpalding atty

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SarahSarah a person of color
vs
Michael HaltonMichael Halton

Reasons for dismissing suit

Because there is no proof that
papers came from SuperiorSuperior Court
CourtSuperior Court and there is no petition on on
file

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LydiaLydia Colored person
vs
John Butten

do

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NancyNancy a colored person

IsaacIsaac Vateau

do

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JennyJenny do

Robert MusickRobert Musick

do

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JerryJerry colored man

Charels Hatian

do

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SamuelSamuel black man

John Whiterides
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Malinda

Phebe Whiterides

do

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LewisLewis vs Phebe Whiterides
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Hannah a black girl

Phebe Whiterides
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Sarah a person of color
vs
Michael HaltonMichael Halton

eight other suits

reasons for dismissing

filed February of 1822

A GambleArchibald Gamble

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Superior CourtSuperior Court Northern Circuit
March Term 1819.

County of St LouisCounty of St Louisto wit SarahSarah a
free girl held in slavery and of who
is permitted by the court to sue as a
poor person. by J BartonJ Barton and HenryHenry SS Geyer
GeyerS Geyer her attornees assigned by the
Court as counsels complains of MichaelMichael Halton
HaltonMichael Halton of a plea of trespass-for that
the said MichaelMichael Halton HaltonMichael Halton , heretofor
to wit on the first day of January in the year of our lord one thousand eight hundred and fifteenwith
force and arms at the county
aforesaid lawfully an assault
did make in and upon the said
SarahSarah and then and there beat
bruise and said
SarahSarah and then and there
imprisoned the said SarahSarah and kept and detained her in prisonwithout any reasonable
on probable cause whatever and

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has [ scince ] kept and still
doth keep and detain her in
prison against the will of her the
said SarahSarah and contrary to the
law of this territory and this wrong
to the said SarahSarah then and
there did against the peace of
the United StatesUnited States of AmericaAmerica. and
to the damage of the said SarahSarah
five hundred dollars and Therefore
she sues.

J. BartonJ Barton
GeyerGeyer atts