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 William WaltonWalton gave your petitioner to his daughter ElizabethElizabeth Lansford who then resided in the state of IndianaIndiana to wait for the said ElizabethElizabeth 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 slavery 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

MissouriState of MissouriMissouri Third Judicial Circuit CourtCircuit Circuit CourtCourt . 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 George F StrotherGeorge George F StrotherF 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 with PeterPeter 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 pauperis complains of James WaltonJames James WaltonWalton of a plea of trespass . For that the said James WaltonJames James WaltonWalton on the first day of May in the year 1830 with force and or was in the county of St LouisSt Louis made an assault on the said PeterPeter to wit at St LouisSt Louis county 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 aforesaid grievances were committed in the said PeterPeter was and still is a free person told the not James WaltonJames James WaltonWalton 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 St LouisSt St LouisLouis 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 summon James WaltonJames James WaltonWalton 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 County of S LouisCounty County of S Louisof County of S LouisS County of S LouisLouis 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 St LouisSt St LouisLouis on the 12th day of March

This is an action of assault and beating and false imprisonment .

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 attorney comes 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 suit Book 6 page 284

defendants page

plea Not guilty - 2 plff not free

You are here by commanded to summon John T WaltonJohn John T WaltonT Walton and Archibald GambleArchibald Archibald GambleGamble 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 August next 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 James WaltonJames James WaltonWalton 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 August next 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 Henry WaltonHenry Henry WaltonWalton 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 December instant at the City of St LouisCity of St. Louis, thenand 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 Henry WaltonHenry Henry WaltonWalton 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 December instant 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 George WaltonGeorge George WaltonWalton on the 4th Dec 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 march next 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 Henry WaltonHenry Henry WaltonWalton 2nd day of March 1832 in county of St LouisSt St LouisLouis

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 march next 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 John T WaltonJohn John T WaltonT John T WaltonWalton 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 John T WaltonJohn John T WaltonT 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 James WaltonJames James WaltonWalton is defendant, on the part of the Defendant and have you then there this writ.

for Jacob Walton forthwith for defendant

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