Squire Brown, a person of colour v. Charles R. Anderson
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To the Honorable BryanBryan Mullanphy MullanphyBryan Mullanphy Judge
of the Circuit CourtCircuit Court of St Louis County

The petition of Squire
BrownBrown a man of color respectfully represents
that he is
of instituting a suit against one Charles RCharles R Anderson
AndersonCharles R Anderson in order to establish the right
of your petitioner to freedom that his claim
is founded upon the following grounds to wit
that sterry BrownBrown who had formerly owned
your petitioner for some six or eight years
to the fifth day of May 1841.& during the time
he so owned your petitioner hired out your
petitioner to work in the County of St ClairCounty of St Clair
State of IllinoisIllinois at various times between
the years 1839 & 1841. for several monthsat
a time. Your petitioner represents further
that since May 1841. he has been
from said & BrownBrown his former &
is now deemed by the said AndersonAnderson as his property
& that he is now by the said AndersonAnderson
held in slavery.

Your petitioner therefore
prays that he may have learn to sue as a
poor person in order to establish his right
to freedom

Squire his mark Brown

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State of MissouriMissouri
County of St LouisCounty of St Louis

ss

Squire BrownBrown the petitioner
above named being duly
sworn deposes & says that the facts set forth
in the above petition are true to the best of the
knowledge beliefs of this deponent

Sum to this 17 day of January 1844, before me

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State of MissouriMissouri
County of St LouisCounty of St Louis

Be it remembered that this
within named SquireBrownBrown is hereby allowed
to sue as a poor person & Benjamin B Dayton is
assigned as his counsel. and it is hereby
ordered that saidBrownBrown have reasonable
liberty to attend his counsel & the court as occ-
asion may require. that he be not removed
out of the jurisdiction of the St LouisSt Louis circuit
court that he be not subjected to any sever
ity on account of his application for freedom
In listing which set may
hand this seventeenth day of January 1844 â

BryanBryan Mullanphy MullanphyBryan Mullanphy

Judge 8thof
MissouriMissouri

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St Louis Circuit CourtCircuit Court
November Term 1843

St Louis County ss.

SquireBrownBrown plaintiff in
this suit by his attorney complains of
Charles RCharles R Anderson AndersonCharles R Anderson of a plea of trespass

In that the said defend
ant heretofore to wit on the first day of January eighteen hundred forty four at the City ofCity of St Louis
St. LouisCity of St Louis at said County with force & arms
made an assault on said plaintiff & then
beatbruised&ill treated him & then& there im
prisonedhim& kepthim in prison for a long
space of time to wit for the space of tendays
then next- following contrary to the laws this
State of MissouriMissouri& againstthe will of the
said plaintiff. & otherways to the said
plaintiff then & there did against the Law
of the State of MissouriMissouritothedamage of
the said plaintiff of five hundred dollars.

And the said plaintiff
avers that before & at the time of the committing
of the grievancesaforesaid by the said defendant
he the said plaintiff was & still
is a free person & that the said defendant
held & still holds him in slavery. Therefore
he brings his suit

B. B. Dayton
Plff

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Charles RCharles R Anderson AndersonCharles R Anderson
ad
Squire BrownBrown

And the said Defendant Charles RCharles R Anderson
AndersonCharles R Anderson . Comes & defends thewrong
& says that he is not guilty of the trespass
& assault & battery in manner& formas. the
said plff in his said Declaration hath
alleged& ofthis he puts himself on the County
Todd& Krum for Deft.

This plea filed Jany 17th 1844.

John RulandJohn Ruland Clerk

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No. 328.

In the St Louis Circuit CourtCircuit Court .
November Term 1843.

St Louis Circuit CourtCircuit Court

SquireBrownBrown
vs
Charles R AndersonCharles R Anderson

Suit for freedom
Trespass

Dam $ 500. ad
pleas
June 18

B. B. Dayton
plff atty

Filed by consent Jany 17th 1844

John RulandJohn Ruland Clerk

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PeterPeter & filed (by consent) & Plff allowed to the as a poor person order assigning Counsel &c & plea
filed BK 14 p 338. Venue changed to Comr. pleas BK 15 p 131 (June 18. 1844.)

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State of MissouriMissouri
County of St. LouisCounty of St Louis

Buyam B Dayton buy duly
sum deposes & says that on
the 17th day of January a suit was
commenced inthe St. Louis County Court by SquireBrownBrown against
Charles B Anderson for freedom. by filing
a declaration by Consent & also a Petition
that plaintiff have been to sue as a poor
person as provided by Statutes at the
an order was made by the HonorableBryanBryan Mullanphy
MullanphyBryan Mullanphy Judge of said Court that
said BrownBrown had as a poor
person that this be assigned as
his Counsel. also an with that said
BrownBrown have reasonable liberty to attend
his Counsel & the Court as occasion
mightrequire.& that he be not removed
out of thejurisdiction of the said Court
& that he be not subject to any severity
on account of his application. JohnJohn M
MJohn M Shrew Esq an attorney of
appeared for the saidAndersonAnderson
& concealed to all the said orders &
the of the said declration & also
on behalf of Todd& Krum of which
his is to filed a plea for the
said AndersonAnderson on the day after
said and this furthersays
that he is informed by John WJohn W
Constable of St LouisSt Louis Court that he
said at the request of said
AndersonAnderson this day awarded BrownBrown
took himto the Slave Boat Admiral
for the purpose as said AndersonAnderson
told him of him south. that
said BrownBrown was put on said boat

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what was for New OrleansOrleans
In
what with said BrownBrown has defauled
for that place. this affiant believes
therefore thatsaid BrownBrown is nowbyout
of the jurisdiction of this Court
Subscribed to this 19th
January1844before me

B B Dayton

BryanBryan Mullanphy MullanphyBryan Mullanphy
Judge 8th. Jud. Cir.. of Mo.

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State of MissouriMissouri
County of St. LouisCounty of St Louis

The State of MissouriMissouri

to the sheriff of the county of St. LouisSt Louis greeting
whereas - BryanBryan Mullanphy MullanphyBryan Mullanphy the Judge
of our Circuit Court of the Eighth Judicial
Circuit, which includes the county of St. LouisSt Louis
is satisfied from the foregoing affidavit that
Squire BrownBrown a man of color a petitioner for
freedom, who has instituted suit in said court
to recover the same, is about to be removed
out of the Jurisdiction of said court, you are
hereby commanded to seize said petitioner wherever he may be found and bring him
before our said Judge on Twentieth January in 1844 at nine o'clock A. M. at the goal in said county
and summon any person claiming him
or in whose possession he may be found
to appear before our said Judge at said time
& place & have you then there this writ-
As witness the hand of our said Judge
At ChambersChambers in the City of St LouisCity of St Louis this
nineteenth day of January in the year ofOurLord One thousand Eight hundred and forty four

BryanBryan Mullanphy MullanphyBryan Mullanphy

Judge 8th Jud. Cir. of Mo.

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Executed this writ in the County ofCounty of St Louis
St LouisCounty of St Louis on the 20th day of January 1844 by
seizing the body of Squire BrownBrown and having
him before the Honorable BryanBryan Mullanphy MullanphyBryan Mullanphy
Judge of the 8th Judicial Circuit of MissouriCircuit Court at
the goal as I am herein commanded and
also by reading it to IsraelIsrael Morris MorrisIsrael Morris , he being
the person claiming the said Squire BrownBrown
and in whose possession he was found

WilliamWilliam Milburn MilburnWilliam Milburn Shff

by N.C Dpty

fees $ 2.00 Extra 20.00 $ 22.00
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State of MissouriMissouri
County of St LouisCounty of St Louis
Ss

whereas SquireBrownBrown a
man of color has been brought before me
by virture of warrant hereto annexed
and one IsraelIsrael Morris MorrisIsrael Morris who claims him
being, at the St LouisSt Louis goal on 20th Jany 1844, called, comes not there upon
the sheriff is hereby ordered to take possession
of said SquireBrownBrown , and hire him out
from time to time during the pendency
of the suit that hath been brought by said
BrownBrown in the St Louis County Circuit CourtCircuit Court
to recover his freedom and take a bond
from the hirer in the penalty of hundreddollars conditioned as provided by
eighth section of the act approved 27 Jan1835
entitle "an act to enable persons held
a in slavery to sue for their freedom - "

BryanBryan Mullanphy MullanphyBryan Mullanphy

Judge 8thJud.Cir. of
MissouriMissouri

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No 328

In the St LouisSt Louis Circuit court
November Term 1843.

In the matter of Squire
BrownBrown a person of colour
vs
IsraelIsrael Morris MorrisIsrael Morris &
C. R Anderson

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Judgt is Morris & Anderson for costs of this proceding BK 14 p 357. Motion to set same
aside as to AndersonAnderson filed Feby 12th 1844 & overruled 14 p 398. motion to set aside last overruling
(for a rehearing) filed Feby '44 overruled BK 14 p sustained 14p 422 &
no to set aside judgt overed & Bill of Exs. filed 14p 422.

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In the matter of Squire
BrownBrown a person of color

In the Circuit CourtCircuit Court
November Term 1843

Charles R.Anderson
comes & moves the Court that so much of
the judgment of this court renderd on the
Twenty sixth day of January A D 1844 as
that said AndersonAnderson pay the costs & charges
incurred in this behalf, be set aside &
vacated. Because the same is without
authourity in law.

Todd & Krum
attys for AndersonAnderson

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In Circuit CourtCircuit Court

In the matter of
Squire BrownBrown a
person of color

Mo. to vacate
judgt. as to Chas.R.Anderson-

Todd & Krum
attys. for AndersonAnderson

Filed February 12th 1844

John RulandJohn Ruland Clerk

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In the matter of
Squire BrownBrown
person of color

Charles R AndersonCharles R Anderson by
his attornies move the
court to set aside the
made in this cause one overruling
the motion of said Charles
R.Anderson filed on a
former day of the present
term of this Court, &
that a new trial be granted
to said Charles R AndersonCharles R Anderson

Todd & Krum
for Chas. R.Anderson

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In the matter of
Squire BrownBrown
a person color

Motion to set aside
order â

Filed February 29th 1844.

John RulandJohn Ruland Clerk

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In the matter of
Squire BrownBrown a
person of color de

Be it remembered
that on the 12th day of February 1844Char
-lesR. Anderson filed his motion
inwords& figures following to wit:
(here insert said motion) which
motion the court overruled
thereupon the said Charles RCharles R Anderson
AndersonCharles R Anderson on the 29th day of February AD 1844 filed his motion in
word & figures following to wit:
(here insert said motion) which
motion the court overruled to which judgment
of the court the said Charles RCharles R Anderson
AndersonCharles R Anderson byhis
this his bill of exceptions
may be signed & sealed &

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BryanBryan Mullanphy MullanphyBryan Mullanphy

Judge of the 8th Jud
Cir.ofMo.
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In the matter
of SquireBrownBrown
a person of color & c

Bill of exceptions

Filed March 15th 1844.

John RulandJohn Ruland clerk