To the Hon. Circuit CourtCircuit Court of St. Louis County and the StateMissouri
of MissouriMissouri, your petitioner George JohnsonGeorge Johnson , humbly complaining,
respectfully represents to your honorable Court that he is a
free man of color, and that he is now claimed and held as a
slave by one HenryHenry MooreMoore , a citizen of MissouriMissouri, who has now
your petitioner confined in the trading yard of B. W. Lynch of
this City, and he is not allowed to see his friends or counsel.
Your petitioner further states the following to be the grounds on
which his claim to freedom is founded:

To wit - that he was born of free colored parents in Fayette County
in the State of PennsylvaniaPennsylvania, and tht he has remained free
from his birth to the present time, never having owed service, nor
belonged to any person whatever.

Your petitioner further states that, he has resided a free man
of color in the State of MissouriMissouri for the last eight years.

Your petitioner further states that by reason of his said free
birth by his free parents, he feels that he is entitled to his
freedom, and prays the Court to permit him to sue, as a
poor person, for his freedom, and, until such suits shall be
decided, to allow him free access to his counsel and the
Court, and to prevent him from being removed beyond the jurisdic
tion of this Court.

It is hereby ordered that the said George JohnsonGeorge Johnson
a man of colour be allowed to sue for the free
dom of himself as a poor person and that he have reasonable
liberty to attend his counsel and the Court as
occasion may require, and that he be not re
moved out of the Jurisdiction of this Court, and
that he be not subject to any severity on account
of his application or suit for freedom.

Filed 16th June 1852

George JohnsonGeorge Johnson the
Plff in the above entitled cause
states that he is a free man of color
and as such entitled in law and
equity to his freedom. That he was born
in the county of Fayette in the
state of [ PennsylvaniaPensylvania ] of free colored
parents on or about the Eighth day of January in the year of our Lord Eighteen hundred and twenty six
which said State of [ Pensylvania ] was
on the day and year aforesaid a
free State in which the institution
of slavery did not exist by the laws
of said state or by the laws of the
Federal Government of the UnitedUnited States
StatesUnited States of AmericaAmerica and at the time
of Plff's birth his parents were free
colored citizens of the state of
[ PennsylvaniaPensylvania ] - and the Plff further
[ stats ] that by reason and virtue of his
said birth and nativity in the state of
[ PennsylvaniaPensylvania ] he is entitled to his freedom -
Nevertheless the Plff states that on or
about the first day of May, 1841
he came to the State of MissouriMissouri and
was on the Twenty sixth day of May1852 and fifty two in the year Eighteen hundred and fifty two for a day seized and held in custody and
close confinement by HenryHenry MooreMoore the
defendant, who claims the Plff as his
[ lawfull ] slave and that the said deft

has since the seizure of the Plff held
him confined in the trading yard of
B W Lynch a negro trader in the
city of St. LouisSt Louis. The Plff further
states that before and at the time of
the committing of the grievances by the
deft he was and still is a free person
and that the deft held and still holds
him in slavery - he therefore prays
the Court to grant him Judgement of
Liberation and declare him to be a
free man.

George JohnsonGeorge Johnson being duly sworn
states that the foregoing petition and
the matters therein stated are true.
Sworn to & subscribed before me
this 19th of June 1852.

Suit for freedom NelsonNelson for Plff
Issue Summons

We command you to summon HenryHenry MooreMoore
to appear
before the Judge of our Circuit CourtCircuit Court , on the first day of the next
term thereof, to be held in the City of St. LouisCity of St Louis, within and for the
County of St. LouisCounty of St Louis, on the third Monday of November
next, then and there to answer the complaint of George JohnsonGeorge Johnson
as set forth in the annexed petition
and have you then there this writ.

I acknowledge myself bound for all costs that may accrue in the above cause.

Witness my hand and seal, at St. LouisSt Louis, this day of
185

to the

Summons

Pet for Freedom

It is hereby ordered that
the said George JohnsonGeorge Johnson a man of co
lor be allowed to sue for his freedom
of himself as a poor person and that he have reasonable
liberty to attend his Counsel and the
Court as occasion may require, and
that he be not removed out of the
Jurisdiction of this Court, and that he
be not subjected to any severity on
account of his application or suit
for freedom.

Executed the within writ in the County of StCounty of St Louis.
LouisCounty of St Louis County on the 16th day of June 1852
by delivering a copy of the same and also a
copy of the petition to the within named HenryHenry
Moore.

Further executed this writ by reading to HenryHenry
MooreMoore the rule of Court endorsed in the petition
with this writ, in the County of St. LouisCounty of St Louis
on the 17th day of June 1852.

Belt	$1
Jury	2
CerreCerre	3.20
Paid	$6.20

Suit for Freedom

HenryHenry B Belt Sheriff states
that upon reading the order to the defendant
in above case by his Deputy (J H Gamble) the
said defendant stated to him that he
would not obey the order and that
he should take the plaintiff out of the jurisdiction of this Court
, and therefore the said
GambleArchibald Gamble Deputy as aforesaid took said
plaintiff into custody and still holds him
and the said HenryHenry B Belt now
asks of the Court to make an order to
him said plaintiff out according to law.

Joseph H Gamble Deputy Sheriff st
makes oath & says that the above
statement is true.

Return & Petition of
Sheriff

April T 1852. Order to Sheriff to hire out &c22 p 72 - Return
and petition of Shff filed 22 p 92

Know all men by these presents
that I, George JohnsonGeorge Johnson , of St. LouisSt Louis, Mo, do hereby constitute
my legal Attorney W. Boudes
ThompsonThompson , my true and lawful
Attorney, for me and in my
name to do all lawful
acts and things in my case
now pending in St. Louis County
for my freedom - to prosecute
or dismiss the same for the
present as he may deem
advisable, and to attend
to all my interests as I
might or could do if I
were at liberty and
personally present.
And I hereby notify and
confirm all that my said
Attorney may or shall do
in my name in and
about the premises.

Filed 8th Sept 1852