Your petitioner PeterPeter humbly rep
resents, that he was born in the state
of North CarolinaCarolina a slave the property of William WaltonWilliam Walton who came to
county of St LouisSt Louis and state of MissouriMissouri
about twenty three years since and
brought your petitioner with him, that
your petitioner resided with his master
Willam Walton in the county of St LouisSt Louis
about two years when the said Willi
am WaltonWalton gave your petitioner to his
daughter ElizabethElizabeth Lansford who then
resided in the state of IndianaIndiana to wait
for the saidElizabethElizabeth and her child
that the said ElizabethElizabeth took your petitioner
up her on back at the house
of William WaltonWilliam Walton in of there
by and conveyed him to her house in the
state of IndianaIndiana where he resided with
her about two years there he was
taken to and from there brought

to the county of St LouisSt Louis and state of MissouriMissouri
where he now resides and is held in slave
ry by James WaltonJames Walton most of which
he by the awarded affidavit
A which your petitioner asks to
in part of this his petition

Your petitioner being advised and
believing that the above events and gives him claim to and entitles him
freedom, prays to be permitted to sue
in forma pauperis to establish his right
to his freedom and that such other and fur
ther orders may be made in the
as the law and to your honor may
and

State ofMissouri MissouriMissouri Third Judicial CircuitCircuit Court CourtCircuit Court
. It is hereby ordered that PeterPeter the before named
petitioner is permitted to sue as a poor person to
establish his right to freedom on the foregoing pe
=tition and GeorgeGeorge F Strother F StrotherGeorge F Strother Esquire is assigned
as his counsel for that purpose. It is also ordered
that the petitioner PeterPeter have reasonable liberty

to attend his said Councel and the Court when
occasion may require and that the said petitioner
shall not be removed out of the jurisdiction of
the court nor be subject to any severity because
of his application for freedom. Given under
my hand at my chambers this 10th day of March 1831.

Petition to sue in forma pauperis

John T. Walton personally appeared
before the a Justice of the peace in and for the county
aforesaid, duly sworn on his oath saith that he is
acquainted withPeterPeter a Black boy that he has known him
ever since he can recollect knew him in North CarolinaCarolina
has known him in MissouriMissouri, saw him when he started from
this County and company with ElizabethElizabeth Lansford to go to IndianaIndiana as it was said, does not know of his own knowledge that he
went there. The deponent saith that ElizabethElizabeth Lansford the was the daughter of said William WaltonWilliam Walton , she started
from her father's in St Louis County, taking with her PeterPeter
the Black man aforesaid with the consent of her father and
on her intended trip to IndianaIndiana, they took place about
twenty one years ago-that ElizabethElizabeth Lansford never
returned to the county-That said ElizabethElizabeth Lansford never
returned to the county. That PeterPeter remained away for two
years or upwards. The deponent further saith that the said
PeterPeter was beaten as aforestated, in the a -with an understanding guaranteed by Henry WaltonHenry Walton the
son of the said William WaltonWilliam Walton , that the residence of the boy
should be changed every thirty days has often heard the said
William WaltonWilliam Walton in his lifetime remark that the boy (alledging
to said PeterPeter ) was free by the laws of IndianaIndiana, if he but
knew it

St Louis County to wit.PeterPeter a man of color
who by permission of the court sues in
forma pauperiscomplains of JamesJames Walton WaltonJames Walton of a plea of trespass. For that the
said JamesJames Walton WaltonJames Walton on the first day of May in the year 1830 with force
and or was in the county of St LouisSt Louismade an assault on the
said PeterPeter to wit at St LouisSt Louiscounty
aforesaid and then and there one
said hold of the said PeterPeter and with
great force and then and there did
the said PeterPeter and gave him the
said PeterPeter many blows and,
and then and there imprisoned the said
PeterPeter and kept and detained him in pris
on there without any reaonsable or probable
cause whatsoever for a long space of
time to wit for the space of Eleven months.
When the said PeterPeter avers that before
and at the time above mentioned when

when the aforesaidgrievances were committed
in the said PeterPeter was and still is a free person
told the not JamesJames Walton WaltonJames Walton there kept
and detained him and still holds and detains him in slavery. Contrary to law and against
the will of the said PeterPeter the said
PeterPeter was not only then and there greatly bruised and hurt
but was also then and there greatly
in and in circumstances to wit at StSt Louis
LouisSt Louis county aforesaid. and . the
then and there did to the damage of the
said PeterPeter $500 and therefore he brings
suit.

To the sheriff of St Louis County Greeting
We command you to summonJamesJames Walton WaltonJames Walton that he
be and appear before the Judge of our Circuit CourtCircuit Court
at the next term thereof to be held at the city of St LouisSt Louis
within and for the CountyCounty of S Louis ofCounty of S Louis SCounty of S Louis LouisCounty of S Louis on the fourth
monday of March instant then and there to answer
unto PeterPeter a man of color of a plea of trespass to the
damage of said plamliff of #500-and have you
then there this writ.

Executed this writ on James WaltonJames Walton the defendant
by offering to read it and the declaration to him
which he refused to hear read and acknowledged of the same in the county of StSt Louis LouisSt Louis on the
12th day of March

This is an action of assault and beating and false imprison
ment.

It is hereby ordered that PeterPeter the before named petitioner be permitted
to sue as a poor person to establish his right to freedom on
the foregoing petition and George F StrotherGeorge F Strother Esquire is assigned
as his counsel for that purpose. It is also ordered that the petitioner
PeterPeter have reasonable liberty to attend his said counsel and
the court when occasion may require and that he said petitioner
shall not be removed out of the jurisdiction of the Court nor
be subject to any severity because of his application for
freedom. Given under my hand at my chamber this 10 day of March 1831.

and the said JamesJames by his
attorneycomes and defends the force and injury
when &c and says that he is not guilty of
the in manner and form as the plaintiff
hath above thereof in his declaration alleged
and of this he puts himself the county

and the said JamesJames for further plea in
this behalf says that the the said plaintiff at
the time of the commencement of this suit was
not and is not a free person in manner
and form as the plaintiff alledges and of this he puts himself upon the county

Non suitBook 6 page 284

defendants page

pleaNot guilty - 2 plff
not free

You are here by commanded to summon JohnJohn T Walton T WaltonJohn T Walton and ArchibaldArchibald Gamble GambleArchibald Gamble
McDonald 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 tenth day of Augustnext at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein PeterPeter a man of Color is plaintiff, and
JamesJames Walton WaltonJames Walton is defendant, on the part of the
plaintiff-; and have you then there this writ.

John T WaltonJohn T Walton & Archibald McDonaldArchibald McDonald
not found in my county

for Plaintiff

You are hereby commanded to summon George WaltonGeorge Walton and Henry WaltonHenry Walton
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 tenth day of Augustnext 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 PeterPeter - a man of color is plaintiff, and
James WaltonJames Walton is defendant, on the part of the
defendant and have you then there this writ.

for defendant

Excuted this writ on HenryHenry Walton WaltonHenry Walton by leaveing
a copy of it at his house and it to George WaltonGeorge Walton
both in St Louis County on the 20th day of July 1831

You are hereby commanded to summon John T WaltonJohn T Walton and Archibald McDonaldArchibald McDonald
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 7th day of Decemberinstant at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein PeterPeter is plaintiff, and
James WaltonJames Walton is defendant, on the part of the
plaintiff ;and have you then there this writ.

Jn T. Walton & Arch McDonald
not found in my county

for plff

You are hereby commanded to summon George WaltonGeorge Walton and HenryHenry Walton WaltonHenry Walton
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 seventh day of Decemberinstant at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein PeterPeter is plaintiff, and
James WaltonJames Walton is defendant, on the part of the
defendant ; and have you then there this writ.

Executed on Henry WaltonHenry Walton on the 14th Novr & on GeorgeGeorge Walton WaltonGeorge Walton on the 4thDec 1831

for defendant

You are hereby commanded to summon George WaltonGeorge Walton and Henry WaltonHenry Walton
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 thirtieth day of marchnext at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein PeterPeter is
plaintiff, and James WaltonJames Walton is defendant,
on the part of the defendant ; and have you then there this writ.

for defendant

Executed this writ on Geroge Walton 29th
of February
& on HenryHenry Walton WaltonHenry Walton 2nd day of March 1832
in county of StSt Louis LouisSt Louis

You are hereby commanded to summon John T Watton and Archibald McDonaldArchibald McDonald
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit Conrt, on the 30th day of marchnext at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein PeterPeter is
plaintiff, and James Watton is defendant,
on the part of the plaintiff ; and have you then there this writ.

Archibald McDonaldArchibald McDonald & John T WaltonJohn T Walton
not found in my county

for plff

You are hereby commanded to summon JohnJohn T Walton TJohn T Walton WaltonJohn T Walton
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit CourtCircuit Court , on the day of April
at the City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of
controversy now pending in our said Court, wherein PeterPeter is
- plaintiff, and James WaltonJames Walton is
defendant, on the part of the plaintiff
and have you then there this writ.

not executed there being two
about the same time

Spa for

You Are Hereby Commanded To Summon JohnJohn T Walton T WaltonJohn T Walton
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit CourtCircuit Court ,forth with
at the City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of
controversy now pending in our said Court, wherein PeterPeter
is plaintiff, and James WaltonJames Walton
is defendant, on the part of the plaintiff
and have you then there this writ.

Executed this writ on John T WaltonJohn T Walton by read-
ing
it to him in St. Louis County on the 11th April 1832

sub

forthwith

You Are Hereby Commanded To Summon Jacob Walton
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit CourtCircuit Court ,forthwith
at the City of St.LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of
controversy now pending in our said Court, wherein PeterPeter is
plaintiff, and JamesJames Walton WaltonJames Walton
is defendant, on the part of the Defendant
and have you then there this writ.

for Jacob Walton
forthwith for defendant

Executedthis writ on Jacob Walton
by reading it to him in St. LouisSt Louis
on the 19th april 1832