Mary Ann Speaks v. John M. Jameson and James Quisenberry
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To the Honorable the St Louis Circuit CourtCircuit Court
within and for the County of St LouisCounty of St Louis

The petition of Mary AnnMary Ann Speaks a free person
of colour, who is now unjustly and illegally restrained
of her liberty by one JamesJames Quisenberry QuisenberryJames Quisenberry and one
John M. Jameson the keeper of the Common prison
within and for the County of St LouisCounty of St Louis, respectfully
represents, that she is now about thirty three years
of age, born in the County of AlexandriaCounty of Alexandria in the
District of ColumbiaDistrict of Columbia, that some eight years since
she was bound apprentice to learn the art & of a housewife in the said County of AlexandriaCounty of Alexandria
aforesaid by her mother, to one SusanSusan Blunt
BluntSusan Blunt for the period of ten years now and after
the first day of May eighteen hundred and thirty five or six; that in pursuance with said apprentice
ship your petitioner remained with the said
Blunt for the period of two years in the County ofCounty of Alexandria
AlexandriaCounty of Alexandria aforesaid, at which time the said
Susan BluntSusan Blunt being about to remove to the CountyCounty of St Louis
of St LouisCounty of St Louis in the state of MissouriMissouri, proposed to
your petitioner that if she would accompany her
to said county and State, she the said Blunt
would give or release your petitioner of two years
of the time she was so bound for as aforesaid;
that your petitioner having a fondness
for said said Blunt and her family agreed so to
come and did so come to the state and County
aforesaid about the first day of May eighteen hundred and thirty seven upon the said express
promise as aforesaid; that your petitioner has
abundance of proof to the effect as above stated,
which said proof is good and sufficient to establish
the foregoing facts; that some months since
the said SusanSusan Blunt BluntSusan Blunt departed this life interstate,
and that the said JamesJames Quisenberry QuisenberryJames Quisenberry is
administrator of all the estate, effects and credits
of the said deceased; that said Quisenberry

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does not pretend to claim your petitioner as a slave
belonging to his said decedent, but on the contrary
admits that she was born of free parents and is
of right free after she shall render to him as
such administrator compensation for said
unexpired term of apprenticeship; that the said
Quisenberry has no evidence whatever in his
possession that your petitioner may bound apprentice
to his intestate, save what has been above
stated by your petitioner and what the said
intestate in her life time so stated to which ready
to testify to the same; that she said Blunt
in her life time knowing full well of the express
agreement as aforesaid, and that the full term
of your petitioners time of servitude had expired
destroyed the indentures of apprenticeship as
aforesaid so that at this time the said
Quisenberry has no evidence whatever known
to the by which he can legally claim
the earnings of your petitioner; that your petitioner
has demanded of the said John MJohn M Jameson JamesonJohn M Jameson
keeper of the prison aforesaid the papers or
of committment by virtue of which he detains
the said petitioner , and that he said Jameson
stated that he has no or papers
by which he detains the said petitioner;
and that said Jameson informed your petitioners
counsel, that said Quisenberry brought
said petitioner and required him safely to keep
her until he learned his pleasure, at the
same time stating that your petitioner was
born free and would be entitled to her earnings
in a short time.

Now your petitioner is according to the statute
in such case made and provided, here points out
the illegallity of said imprisonment, and alleges
that the said imprisonment is illegal in

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this to wit, that under and by virtue of the laws
of VirginiaVirginia which at the time were in full
force and effect in the said County ofCounty of Alexandria AlexandriaCounty of Alexandria
and under which your petitioner was
bound apprentice as aforesaid, does not allow
or permit the master or Mistress to carry out
of the state of VirginiaVirginia or the county of Alex
andria out of the District ofDistrict of Columbia ColumbiaDistrict of Columbia
an apprentice nor did the said law allow or
permit the said SusanSusan Blunt BluntSusan Blunt to bring into this
state your petitioner-?

That the matter of apprenticeship as aforesaid
is a personal contract and dies with the person
and in as much as the said SusanSusan Blunt BluntSusan Blunt has
departed this life, your petitioner is liberted
from her servitude?

That she is entitled to her own earnings
because by the terms of her coming to this state
with said Blunt under the promise and agreement
as aforesaid and having served out
full the term of eight years she has performed
her part of said contract.

That a master cannot at his will whim and caprices incarcerate his
apprentice in the common prison without
That she is detained and deprived of her
liberty by the said Quisenberry and Jameson
without authority of law.

In view of the foregoing your petitioner
now prays for the writ of Habeas Corpus to the
said JamesJames Quisenberry QuisenberryJames Quisenberry and the said JohnJohn Jameson
JamesonJohn Jameson directed, Commanding them
and each of them to bring the body of of your petitioner forthwith
before your Honorable Court to do, submit to,
and secure judgment in the premises and
your petitioner as in duty even will ever pray &c

MaryMary Ann AnnMary Ann Speaks
by her attorneys

Primm & Taylor

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State of MissouriMissouri
County of St LouisCounty of St Louis

Ss

Personally appeared before the
undesigned Mary AnnMary Ann Speaks the within and
foregoing petitioner, and being duly sworn on
her oath says, the matters and things in the
same set forth are true to the best of her knowledge way

MaryMary her

x

mark A. Speaks Sworn to and subscribed
before me this 27th of Sept 1844
John RulandJohn Ruland Clerk St Louis Circuit CourtCircuit Court
By

Chas B. Clements D. C.

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Petition of MaryMary A. Speaks
for freedomHabeas
Corpus

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County of St LouisCounty of St Louis Sct
The State of MissouriMissouri

To JohnJohn M Jameson MJohn M Jameson JamesonJohn M Jameson Jailor of
the County of St LouisCounty of St Louis Greeting

We command you that the body of MaryMary Ann
AnnMary Ann Speaks under your custody as it is said
detained under safe and secure conduct together
with the day and the cause of her being detained
by whatsoever name the said Meary Ann Speaks
may be charged in the same you have before the
Judge of our Circuit CourtCircuit Court at ChambersChambers in the
City of St LouisCity of St Louis in the County aforesaid on the
twenty eighth instant at 9 O clock A.M. then and
there to do submit and receive whatsoever shall
be considered, concerning, the said Mary AnnMary Ann Speaks

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Witness John RulandJohn Ruland Clerk of
our said Court with the seal
thereof hereto affixed at office in
the City of St LouisCity of St Louis this twenty seventh day of September eighteen hundred and forty four.

John RulandJohn Ruland

Clerk By

B. Clements

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In obedience to the with in command
I have here the body of Mary AnnMary Ann
Speaks before the honorable JohnJohn M Krum
M. KrumJohn M Krum Judge of the MissouriMissouri
Circuit CourtCircuit Court on this 28th of Sept 1844 and having no papers by which
I hold the said Mary AnnMary Ann : she
being placed in my custody by
JamesJames Quisenberry QuisenberryJames Quisenberry as administrator
of Susan BluntSusan Blunt on the 26th the said at the same
time stating that she belongs
to the estate of SusanSusan Blunt BluntSusan Blunt and
the he wished her to remain in jail
untill he could get an order of Court
to hire or sell her for the remainder
of the time she had to serve this 28th of Sept 1844

J M Jameson

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No 386

St Louis Circuit CourtCircuit Court
April Term 1844

Mary AnnMary Ann Speaks vsJohn MJohn M .
Jailor of St Louis County

âBy the Corpusâ

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On reading the Petition & hearing the return of this writ
& the charges & allegations in this behalf there being
no proof shown that Mary AnnMary Ann Speaks is held in
slavery, & no sufficient or legal authority shown
to me by which the saidMary AnnMary Ann is held in
Custody. It is ordered that the said MaryMary Ann
AnnMary Ann be & she is hereby discharged from
the custody of the said Jailor.

Given under my hand 28th day of Sept. 1844

John MJohn M Krum KrumJohn M Krum Judge

&C