John Singleton vs. Alinander Scott, Robert Lewis
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To the Honorable WilliamWilliam C. CarrCarr Judge
of the circuit court of the country of
St. LouisSt Louis.

The Petition of John SingletonJohn Singleton , a man
of colour, represents to your honor, that he
is a free man, according to & by the laws of
the land, having been born of a free mother in the state of IllinoisIllinois and having
been reared there from his birth to manhood
that his mother, Phillis Singleton, before
the birth of your petitioner, was the slave of
one Ogle, now an inhabitant of St. Clair
county of IllinoisIllinois, and was emancipated by
said Ogle before the birth of your petitioner,
which happened some time in the year...

And your petitioner further represents, that he
always, from his birth, enjoyed and exercise his
natural freedom, in the state of IllinoisIllinois until about six years ago, which your petitioner
was stolen and kidnapped by one
J... Lamkins, and was taken by him as
a slave to the now state of AlabamaAlabama, where
said Lamkims sold your petitioner as a slave,
to one Zachariah Neal, against whom your
petitioner brought suit for his freedom, but the forsaid suit could be decided, you petitioner
was taken from there to New OrleansOrleans, by one
HenryHenry Byron, who sold your petitioner there

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as a slave, & your petitioner, soon after came
into the hands and possession of our RobertRobert Lewis
LewisRobert Lewis , who claims your petitioner to be his slave,
but by what means or by what authority your
petitioner does not know. That your petitioner
knowing his rights to freedom, attempted to regain
it, and went an board the steam boat AmericaAmerica
of St. LouisSt Louis. commanded by Mr. AlexanderAlexander Scott ScottAlexander Scott
and came to the City of St. LouisCity of St Louis in the state of
MissouriMissouri, some time in august, of the present year
where your petitioner was arrested and cart into
the common jail of the county of St. LouisSt Louis,
where he now is, by the authority and order,
as your petitioner is informed & believes, by of
AlexanderAlexander Scott ScottAlexander Scott . as a run away slave, the property
of said Robert LewisRobert Lewis with the avowed intention
of sending or carrying your petitioner to New
OrleansOrleans, and returning him to the custody
& possession of said LewisLewis . And your petitioner
is informed and believes, that your petitioner was
arrested & imprisoned as aforesaid, by said ScottScott -
as the agent or attorney, of said LewisLewis , and by
& under his authority. Your petitioner therefore
prays that your honor will permit & order that
he shall be allowed to institute his suit against
said ScottScott and LewisLewis for the recovery of his
freedom, and that he may be permitted to
sue as a poor person. And your petitioner
further prays that your honorissue your writ of
Habeas Corpus, directed to said ScottScott , and to the
Sheriff of St. LouisSt Louis county, in whose custody your
petitioner now is for the body of your petitioner,
and that your honor will therefore take such
order in behalf of your petitioner as shall

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sum met and proper your petitioner not being detained for any criminal or supposed criminal charge and your petitioner will
ever pray

John his mark

X

Singleton
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State of MissouriMissouri
County of St. LouisCounty of St Louis

Personally appeared before me
the undersigned a Justice of the peace within and
for the County of St. LouisCounty of St LouisJohnJohn Singleton SingletonJohn Singleton the
person whose name is subscribed to the fore
going petition, who being by me Sworn upon
his corporal oath, saith, that the facts set forth
in said petition as stated upon his aver know-
ledge are true, and those stated are heresay of
others he believes to be true.

St. LouisSt Louisaugust 30th 1829
Sworn to and subscribed before me
PeterPeter FergusonFerguson Justice of the Peace
County St. LouisCounty St Louis

John his mark

X

Singleton
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State of MissouriMissouri Third judicial Circuit
County of St. LouisCounty of St Louissct.

It is hereby ordered that the above named
JohnJohn Singleton SingletonJohn Singleton the petitioner be permitted to
institute a suit as a poor person to by his claim to freedom
agreeable to the statute of such case made
and provided by IssacIssac C. McGirkMcGirk Esquire
is assigned to him as counsel. It is moreover
ordered that the petitioner have reasonable liberty to allowed his counsel and the court when occasion
may require and that he shall
not be taken or removed out of the jurisdiction of

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of the court nor be subject to any severity because
of his application for freedom given under my hand at chambers
this 31st of August 1827.

WillWill C. CarrCarr Judge of the Circuit
aforesaid

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JohnJohn Singleton SingletonJohn Singleton
vs
Alexr Scott and RobertRobert Lewis
LewisRobert Lewis

Petition to be permitted
to the sue for his
freedom.

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State of MissouriMissouri
County of St. LouisCounty of St Louis


In the Circuit court of
St. Louis County, November Term 1827

JohnJohn Singleton SingletonJohn Singleton , a free man of colour
complains of AlinanderAlinander Scott ScottAlinander Scott and RobertRobert Lewis LewisRobert Lewis
of a plea of Trespass; For that the said AlinanderAlinander Scott
ScottAlinander Scott & RobertRobert Lewis LewisRobert Lewis , on the twenty seventh day of august, in the year of our Lord eighteen hundred and twenty seven, with force and arms, made an
assault in and upon the body of him the said JohnJohn Singleton
SingletonJohn Singleton , to wit, at the County of St. LouisCounty of St Louis in the
state of MissouriMissouri, and then and there beat, bruised
and ill treated him the said John, and then &
there imprisoned him the said John and Kept
and detained him in prison there, for a long time, to wit for the space and term ofeight days, then following and
still keep and detain him in prison, without
any reasonable or probable cause whatsoever,
contrary to the laws of the land, and against
the will of the said John; and other wrongs to
the said John then and there did against the
peace and dignity of said state, and to the
damage of the said John of five hundred dollars,
and therefore he brings his suit, &c.

IssacIssac C. McGirkMcGirk Atty


for Pltff, assigned
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No 23

St LouisSt Louis Circt Court
Nov. Term, 1827.

John SingletonJohn Singleton
vs
Alinander ScottAlinander Scott &
Robert LewisRobert Lewis

To the Clerk. This is an action of assault &
Battery & false imprisonment
to try pltffs right to freedom.

Issue a Summons
for defendants.

I. C. McGirkMcGirk atty P.Q.

Filed 3rd September 1827

ArchArchibald Gamble GambleArchibald Gamble Clerk

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Executed this writ on AlexanderAlexander Scott ScottAlexander Scott . September 5th 1827
by delivering a certified copy of the declaration, order of
the judge, and the summons. Robert LewisRobert Lewis not found in my county

R SimpsonR Simpson Sheriff

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Service $1.00
non Est. 50

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JohnJohn Singleton SingletonJohn Singleton
vs
A Scott

And the said defendant comes and defends the force and injury whereas and say they are not guilty of the
Trespasses andimprisonments in the
declaration mentioned in manner
& form as the plaintiff hath above
thereof complained against himand of this he puts himself upon the county &

And the said plaintiff
doth the like. .

I.C.McGirkMcGirk for Pltff

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Singleton
vs
ScottScott

Plea

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In st.Louis

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Singleton
vs
ScottScott

Plea
Robert LewisRobert Lewis

filed January 8th 1829

A Gambled Clerk

.
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County Of St. LouisSt Louis, Sct.

The State of MissouriMissouri,

To The Sheriff Of Saint LouisSt Louis County--Greeting:

You are hereby commanded to summon ClaytonClayton Tiffin TiffinClayton Tiffin - WilliamWilliam Hopkins Cox
WilliamWilliam HopkinsWilliam Hopkins SamuelSamuel Wiggin WigginSamuel Wiggin
that, setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the Third day of April, at the city of St. LouisSt Louis,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein JohnJohn Singleton SingletonJohn Singleton is plaintiff,
and AlexanderAlexander Scott ScottAlexander Scott is defendant,
on the part of the plaintiff; and have you then there this writ.

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Witness, Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the city of St. LouisSt Louis, this 12th day ofMarch in the year of our Lord one thousand eight hundred and twenty eight

Archibald GambleArchibald Gamble

Clerk C.C.
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Executed this writ on Clayton TiffinClayton Tiffin and
WilliamWilliam Hopkins HopkinsWilliam Hopkins and William Cox by reading to the same this18th day of March 1828. SamuelSamuel Wiggin WigginSamuel Wiggin not found

Service 1.50
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March 1828

John SingletonJohn Singleton vs Scott, Lewis

for Clayton TiffinClayton Tiffin , William Cox, William HopkinsWilliam
SamuelSamuel Wiggin WigginSamuel Wiggin
for plaintiff
3rd April

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State of MissouriMissouri
County of St. LouisCounty of St Louis

In the circuit court
of St. LouisSt Louis county, Novr. Term 1827

John SingletonJohn Singleton , a freeman of color,
complains of Alinander ScottAlinander Scott and RobertRobert Lewis
LewisRobert Lewis of a plea of Trespass; For that the
said Alinander ScottAlinander Scott and Robert LewisRobert Lewis , on
the twenty seventh day of august, in the year of our Lord Eighteen hundred and twenty seven,
with force and arms, made an assault
in and upon the body of him the said
John SingletonJohn Singleton , to wit, at the county of StSt Louis.
LouisSt Louis in the state of MissouriMissouri, and then &
there beat, bruised and ill treated him the said
John, and then and there imprisoned him the
said John, and Kept and detained him in
in prison for a long time, to wit, for the
span and term of eight days then next following,
and still detains him in
person, without any reasonable or probable
cause whatsoever, contrary to the
laws of the land, and against the will of
the said John, and other wrongs to the said
John then and there did, against the peace
and dignity of the state; And the said plaintiff
avers, that before and at the time of the committing
the said grievances he was and still
is a free person, and that the said defendants
then & there held and detained him, the plaintiff, &
still hold & detain him in slavery
the said plaintiff saith he is injured and
hath sustained damages in the sum of
five hundred dollars, and therefore he brings his suit, &c.

I C. McGirkMcGirk Atty


for pltff
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John SingletonJohn Singleton
vs
A. Scott & RobertRobert Lewis LewisRobert Lewis

March Term 1828
Amended declaration
I. C. McMcGirk GirkMcGirk for
plff

filed April 22nd 1828

Agamble Clerk