Francois LaGrange v. Bernard Pratt, Pierre Chouteau Jr., John P. Cabanne, Bartholomew Berthold, B. Pratt & Co.
Item
Francois LaGrange V. Bernard Pratt, Pierre Chouteau Jr., John P. Cabanne, Bartholomew Berthold, B. Pratt & Co. 1827, St. Louis Circuit Court Historical Records Project, accessed October 4, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60680
- Case Title
- Francois LaGrange v. Bernard Pratt, Pierre Chouteau Jr., John P. Cabanne, Bartholomew Berthold, B. Pratt & Co.
- Series
- Freedom Suits
- Plaintiff
- LaGrange, Francois - alias Isidore/Isadore
- Defendant
- Pratte, Bernard
- Chouteau, Pierre Jr.
- Cabanne, John P.
- Berthold, Bartholomew
- B. Pratt & Co.
- Date Filed
- 1827-03-08
- Filing Date
- 1827-03-08
- Plaintiff’s Attorney
- Charless, Joseph Jr.
- Court Name
- Missouri 3rd Circuit Court
- Court Term
- March Term 1827
- Judge
- Carr, William C.
- Sheriff
- Simpson, R.
- Cause of Action
- Trespass
- Battery
- False Imprisonment
- Case Notes
- Plaintiff also known as Isadore, also spelled as Isidore; plaintiff born in Missouri, sold to Pierre Menard of Kaskaskia, Illinois and lived a short time in Illinois before being sold to defendants.
- Identifier
- ccr1826.05532.036
- Source
- Missouri State Archives - St. Louis
- Rights
- Public Domain
- PDF Download
- Download PDF of all images
- Transcription
-
**Francois LaGrange vs. Bernard Pratt, Pierre Chouteau Jr.,John P. Cabanne, Bartholomew Berthold, B. Pratt & Co.**
---
**Page 1** (5532_001.jpg)
> *Legal Function: Caption*
No 29 St St. Louis Circuit Court
March Term 1826
Petition of
Francois La Grange
Alias Isadore
vs
Barthold [illegible]
*filed 8 March 1827 A Gamble clk*
---
**Page 2** (5532_002.jpg)
---
**Page 3** (5532_003.jpg)
> *Legal Function: Plaintiff's Petition*
To William C. Carr Esquire Judge of the
Circuit Court St. Louis County.
The petition of Francis La Grange [illegible]alias Isidore
a free man of Color, humbly Sheweth[?], That your
petitioner was born in St Louis upper Louis iana[?] now the State of Missouri , of black
Parents, and that sometime in the year eighteen hundred
and fifteen Pascal Carrs[?] who owned
your petitioner since his infancy sold him to
Pierre Menard of Kaskaskia in the State
of Illinois , by whom he was removed to Kaskia,
and retained at his house for two or
three months and afterwards said Pierre surely your
petitioner, on board of a boat, bound for New
Orleans , to serve as a hand, that your petitioner
was absent from Kaskaskia five or six month
on said voyage, and That upon his return he was
again retained by said Pierre at his house, for
some two or three months, when he was sent to
St. Louis and sold to Pratte , [illegible], Chouteau ,
and [illegible], who now hold your petitioner
in bondage as a Slave, Contrary to the laws
of this land, In tender consideration whereof
your petitioner humbly prays your honor to be
permitted to institute suit in the Circuit Court
for his freedom, and that he may be permitted
to sue as a poor person, and that your honor
would make such other and farther order in
this behalf as shall be deemed [illegible] by your
honor and your petitioner will [illegible] pray [illegible]
Francois La Grange alias Isidore
[illegible] X
---
**Page 4** (5532_004.jpg)
Upon view of the within petition it is hereby
ordered that said Francis LaGrange [illegible] alias Isidore
be permitted to institute suit as a poor person
to [illegible] his freedom and Joseph Charles Jr is as
signed him as counsel-
And it is further ordered, that said petition
& have reasonable liberty to attend his counsel
and the court when occasion may require &
that said petitioner shall not be taken or moved
out of the Jurisdiction of the Court nor be subject
to any severity because of his application for free
dom.
*March 8 1827. Will . C [illegible] Judge 3[?] Circuit*
---
**Page 5** (5532_005.jpg)
> *Legal Function: Plaintiff's Petition Part 2*
State of Missouri
County of St. Louis
St. Louis Circuit Court
March from 1827
Francais La [illegible] Grange alias Isidore
a free man of Colour, who is permitted by the
[illegible] by his next friend as a poor person
by his attorney complains of Bernard Pratt
Pierre Chauteau Jr[?] Bertholomew [illegible] and
John P . Cabanne doing business under the
style & firm of B. Pratte [illegible] of a plea
of trespass on the case For that whereas
heretofore, [illegible] on the first day of March
in the year of our Lord one thousand eight
hundred and twenty seven, with force and
[illegible] the city of St. Louis , unlawfully and
[illegible] and upon the body of said
Isidore , and then and then, did [illegible] bruise and
ill treat him said Isadore , and then and there
imprisoned him said John Isadore, and kept and
detained him said Isadore in prison, and state
keeps and detained him in prison without any
reasonable or just cause whatsoever, contrary to
the laws of this State, and the said defendant
other wrongs then and there did to him said
Isadore against the peace and dignity of the State,
wherefore said Isadore says he is inspired [illegible] by said
defendants and hath sustained damages to the
amount of seven hundred dollars and therefore
he sues &
*Charles Atty for
plaintiff*
---
**Page 6** (5532_006.jpg)
> *Legal Function: Summons for Defendants*
State of Missouri County of St. Louis Ss The State of Missouri
County of St Louis set To the Sheriff of St Louis County Greeting:
The command you to sommon Bernard Pratte , Pierre Chouteau Jr
Barthelomew[?] Berthold and John P. Cabanné that they be and appear
before the Judge of our Cricuit Court at the next term thereof to be held at
the City of St Louis within and for the County of St Louis on the fourth
Monday of March instant then and there to answer to Francois La -
\- Grange alias Isadore of a plea of trespass on the case to the damage of
the said Isadore Seven hundred dollars and have you then there
this writ
*Witness Archibald Gamble Clerk of our said
Court at office this Eighth day of March in
the Year 1827 Archibald Gamble Clerk*
> *Legal Function: Caption*
No. 29 St St. Louis Circuit Court
March Term 1827
Francis La Grange alias
Isadore a free man of Color
vs B. Pratte [illegible]
Narr.[?]
*Filed March 8th 1827 Arch Gamble Clerk*
> *Legal Function: Order*
[illegible] [illegible] of the [illegible] petition of is hereby ordered that
Francis La Grange alias Isadore be permitted to
[illegible] his freedom
And it is further [illegible] that [illegible] [illegible]
have reasonable liberty to attend his counsel and
the Court when occasion may require & that said
petitioner shall not be taken or removed out of the
jurisdiction of the law nor be subject to any
severity because of his application for freedom.
*March 8th 1827 Will C. Carre Judge 3. Circuit[?] A Copy A Gamble Clk*
---
**Page 7** (5532_007.jpg)
> *Legal Function: Certificate of Execution*
Executed this writ on Bernard Pratt March 8th 1827 in
the city of St Louis , by giving the writ and declaration to him to
[illegible] and his acknowledging the service thereof. On [illegible]
[illegible]
decleration & order, at his place of abode with his wife, a free white
person above the age of fifteen years and a member of the family
and on Pierre Chouteau Jr on the same day by having a true & attested
Copy of the writ decleration and Order at his usual place of abode
in the city of St Louis with Mrs Jarpy wife of John B Sarpy Esq
the being a free white person above the age of fifteen years.
*John P. Cabanne is not to be found in my County March 10th 1827 R Simpson Sheriff
By Jno Simonds Jr Dp Sherriff[?] Service $ 3.00
Non Est. 0.50
\$3.50*
---
**Page 8** (5532_008.jpg)
---
**Page 9** (5532_009.jpg)
> *Legal Function: Defendants' Answer*
Francois Lagrange
alias Isadore
vs
B Pratte [illegible]
and the said Bernard
by Geyer his attorney comes & defends
the force and injury when &c and
says that he is [illegible] guilty of the trespass
assault battery and false impri
sonment in [illegible] declaration mentioned
in manner and form as the plaintiff
[illegible] above thereof complained against
him and of this he puts himself upon
the country &c
*Geyer for defs*
> *Legal Function: Defendants' Answer Part 2*
And the said Bertholomew also by
Geyer has attorney comes & defends the
force and injury when &c, and says
that he is not guilty of the greivances
in the declaration complained of
in manner & form as the plaintiff
hath above alleged & of this he prays
may be inquired of by the county
*Geyer for defs*
> *Legal Function: Defendants' Answer Part 3*
And the said Pierre by Geyer his attorney also
comes & defends the force & injury when and so
forth & says that he is not guilty of the said
supposed trespass & imprisonment in the
declaration mentioned in manner & form
as the plaintiff hath above there of complained
---
**Page 10** (5532_010.jpg)
against him & of this he puts himself upon
the county &[?]
*Geyer for dfs[?]*
> *Legal Function: Caption*
Francois
vs
B. Pratte
& al
*filed March 27th 1827 A Gamble Clk*
---
**Page 11** (5532_011.jpg)
> *Legal Function: Deposition Notice*
Francois a colored man
vs
Pierre Chouteau Junr[?]
St St. Louis Circuit Court
Take notice that on Monday the
16th, instant between the hours of six a clock in the
forenoon & eight a clock in the afternoon i the
office of Douey[?] Breese Esq. District attorney of the
U. States , in the Town of Kankaskia[?], State of Illi
nois, I shall proved to take the depositions of [illegible]
to the [illegible] the trial of the above case on behalf
of the defendant.
*July 9th, 1827 Pierre Chouteau Jr To Francois plaintiff
as above*
---
**Page 12** (5532_012.jpg)
> *Legal Function: Caption*
Francois
vs.
P. Chouteau Jr
I acknowledge [illegible]
of the [illegible]
[illegible]
*[illegible]*
---
**Page 13** (5532_013.jpg)
> *Legal Function: Deposition Notice*
Pierre Chouteau Jnr[?]
In [illegible] notice that on Monday the 16th day of July in [illegible] between
the Hours of eight in the morning and six in the
afternoon in the office of him [illegible] by [illegible]
attorney of the [illegible] states in the town of Kaskaskis
that of Illinois of deportions of [illegible] will be taken
to be [illegible] in [illegible] on the [illegible] of the [illegible] now
pending with Circuit Court of the Country of St. Louis
in which Francois a colour man is plantiff
and your an defendant
*July 9th 1827 St Louis [illegible] attorney for Francois
Ja colour man*
---
**Page 14** (5532_014.jpg)
> *Legal Function: Caption*
St Louis
colour man
Pierre Chouteu Jnr[?]
Notice of [illegible] [illegible]
> *Legal Function: Certificate of Execution*
A copy of the written notice was delivered by me
to Pierre Choutau Jr. on the 9th July 1827
*R Simpson Shf Service $ 50*
---
**Page 15** (5532_015.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness*
County Of St. Louis , Sct.
State Of Missouri , To The Sheriff Of Saint Louis County....Greeting:
You are hereby commanded to Summon Pascal Corré
that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit Court , on the seventh day of August at the City 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 Francois La Grange alias Isadore is — plaintiff, and Peter Chouteau Junior
defendant, on the part of the plaintiff, and have you then there this writ.
*Witness, Archibald Gamble , Clerk of our said Circuit Court , at
the City of St. Louis , this 14th day of
June in the year of our Lord, one thousand eight hun-dred and twenty seven Archibald Gamble Clerk C. C.*
---
**Page 16** (5532_016.jpg)
> *Legal Function: Caption*
July 1827
Francois La Grange
alias Isadors
vs
P Chouteau Jr .
for Pascal Cerré
for Plaintiff
*August 7th*
> *Legal Function: Certificate of Execution*
Executed this writ on Pascal L. Cerré July 23rd 1827
*Jno Simonds Jr Dp.[?] Sheriff Service $ 0.50*
---
**Page 17** (5532_017.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness Part 2*
Fiancois Grange
a coloured man
vs
Pierre Chouteau Jun
St Louis Nov 5th 1827 Mr Pierre Chouteau Jun
[illegible]
[illegible] notice that in the twentieth and twenty five days
[illegible] of november [illegible] fun between the hours of
nine in the afternoon and five in the afternoon of said
days at the office of coming [illegible] [illegible] [illegible]
of the named state in the town of Kaskuskia[?] state
of Illinois the [illegible] of witnesses will be taken to be
that in evidence on behalf of the plaintiff in the
[illegible] [illegible] with Circuit Court of the court
of St Louis in which you an [illegible] and
[illegible] Francois Lagrange a coloured man
is plantiff
*[illegible] attn plantiff[?]*
---
**Page 18** (5532_018.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness Part 3*
Francois
vs
P. Chouteau Jun
*Notice*
> *Legal Function: Certificate of Execution*
Served a copy of the within notice on
Pierre Chouteau [illegible] Nov 5th 1827 in the
City of St Louis
*Jn[?] Simonds Jr Dp.[?] Sheriff Service \$0.50*
---
**Page 19** (5532_019.jpg)
> *Legal Function: Deposition Notice*
Francois
a coloured Man
vs
Pierre Chouteau Jun
In St Louis Circuit
Court St Louis Nov 6 1827
Francois the above named of lawfully & his counsel
will take notice that on the twenty record and
twenty third days respectively of November instant between
the hours of eight of the forenoon and six of the
afternoon of said days at the office of the clerk
of the circuit court of the county of Randolph in the state
of Illinois depositions of witness will be taken
to be read in my behalf at the trial of the
above cause
*Pierre Choteau Jn[?] by
Geyer his attoy To Francois the Plantiff
& Luke [illegible]
George F Shother attornies for plff*
---
**Page 20** (5532_020.jpg)
> *Legal Function: Certificate of Execution*
A copy of the within notice was delivered to Luke
A Lawless Nov 8th 1827 and also a copy delivered to
Francois .
*Nov. 10 1827. RSimpson Shf[?] Service $ 1.00*
> *Legal Function: Caption*
Francois
vs
Chouteau
Notice to be served
on Francois Lawless
& Shother —
---
**Page 21** (5532_021.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness*
County Of St. Louis , Sct.
The State of Missouri , To The Sheriff Of Saint Louis County--Greeting:
You are hereby commanded to summon Francis Chouteau & Mrs F Chouteau
that, setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit Court , on the third day of December, at the city 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 Francois Lagrange alias Isadore is plaintiff,
and Peter Chouteau Junior is — defendant,
on the part of the plaintiff; and have you then there this writ.
*Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the city of St. Louis , this fourteenth day of
November in the year of our Lord one thousand eight
hundred and twenty seven Archibald Gamble Clerk C. C.*
---
**Page 22** (5532_022.jpg)
> *Legal Function: Caption*
November 1827
F Lagrange alias Isadore
vs
P. Chouteau Jr
for my
x P. Chouteau 15[?]
x & wife
*for plff
3 Decb.*
> *Legal Function: Certificate of Execution*
Executed this writ on Francis Choteau & wife
Nov 15 1827 by Monday to there the same
*Service $ 1.00 R Simpson Shff*
---
**Page 23** (5532_023.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness*
County Of St. Louis , Sct.
The State of Missouri , To The Sheriff Of Saint Louis County-Greeting:
You are hereby commanded to summon Pascal Corré
that, setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit Court , on the Third day of December, at the city 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 Francois Lagrange alias Isadore is plaintiff,
and Peter Chouteau Junior is defendant,
on the part of the plaintiff; and have you then there this writ.
*Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the city of St. Louis , this Sixth day of
October in the year of our Lord one thousand eight
hundred and twenty Seven Archibald Gamble Clerk C. C.*
---
**Page 24** (5532_024.jpg)
> *Legal Function: Certificate of Execution*
Execution this writ on Pascal Corre Nov 19, 1827
by Monday to him the same
*R Simpson Shiff Service $ 50*
> *Legal Function: Caption*
November 1827
Francois Lagrange
alias Isadore
vs
P Chonteau Jr.
for Pascal Corré
for plaintiff
*3rd December*
---
**Page 25** (5532_025.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness*
County Of St. Louis , Sct.
The State of Missouri , To The Sheriff Of St Louis County--Greeting:
You are hereby commanded to summon Pascal Corre and Bartholomew
Berthold
that, setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circut Court , on the 3rd day of December, at the city 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 Francois Lagrange alias Isadore is plaintiff,
and Pierre Chonteau Junior is defendant,
on the part of the defendant; and have you then there this writ.
*Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the city of St. Louis , this Eleventh day of
October in the year of our Lord one thousand eight
hundred and twenty Seven Clerk C. C.*
---
**Page 26** (5532_026.jpg)
> *Legal Function: Caption*
November 1827
F LaGrange alias Isadore
vs Pierre Chouteau Jr
[illegible] a for
x Pascal Corré
15[?]
x Bart Berthold 17
for defendant
*3 Dec.*
> *Legal Function: Certificate of Execution*
Executed this writ on B Berthola Nov 17 on Pascal
Corré Nov 19th 1827 by Monday to them the same
*R Simpson Shf Service \$1.00*
---
**Page 27** (5532_027.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness Part 2*
Francois Lagrange
Isadore
vs
Pierre Chouteau
[illegible] on behalf of said plaintiff [illegible] a
[illegible] trial for the [illegible]
[illegible] [illegible] in said [illegible] case in
County to St Louis Dorinda[?]
*[illegible]*
---
**Page 28** (5532_028.jpg)
> *Legal Function: Summons and Request for Sheriff to Detain Witness Part 3*
[illegible] [illegible] [illegible]
Francis Lagrange
P. Chouteau
*filed Decr 8th 1827 A. Gamble Clk*
---
**Page 29** (5532_029.jpg)
> *Legal Function: Bill of Exception*
Francois Lagrange
alias Isadore a
coloured man
V
Pierre Chouteau
Be it remembered that on the trial of the [illegible]
joined in said cause the plaintiff by his wit
nesses proved as follows to wit by the witness Pascal Corré
he proved that said said Pascal Corré in the year 1816 was
owner of the plaintiff who was slave of said Corré that
said Corré detained of selling said plaintiff that
Pierre Chouteau Jun the said Defendant wished to purchase
said slave that said Pascal Corré declined selling said
said slave to said Pierre Chouteau because he Corré
wished to sell him to some person who would take
said slave away from, Corré that [illegible] [illegible] [illegible]
of the state of Illonois and [illegible] at Kaskakia[?] [illegible] in said
state proposed purchasing said slave from said Corré
to which said Corré agreed and accordingly for the
sum of five hundred dollars which was paid to [illegible]
by said person [illegible] [illegible] and [illegible] him said
slave By the [illegible] said the two said plaintiff proved that the said (her that the Pascal Corré about the month of september 1816 named as author by by a city of Illionois on defendant of Kaskakia said take and slave Francois from Pascal Corré for the sum of five hundred dollars that said prison did note when he purchased said slave want said slave for his own use and was well aware that he could not hold said Francois in slavery in the state of Illinois that he said purchased said slave in names of an agreement an understanding between him said mentioned and said Pierre Chouteau that the underlanding betwen said men and and said Pierre Chouteau was that the slave was to be delevered to said Chouteau at any time within six n seven months provided said Chouteau should lay said Menard the prea wheel he gave Corré for said plaintiff that shortly after the sale said Pierre Chouteau applied to said Menard to transfer the negro to him Chouteau as had him recently agreed between them that Menard refused to do so at this term for the on that he had bought the slave from Corré in correction of recovering him from St Louis and that it was that he should remove the slave from St Louis in order to make Corré believe that it was his (Menard's) intention so to do when he bought the said slave from Corré that shortly after the purchase of said plantiff said Menard removed him from St Louis and sent him to the main a la in the state of Missouri that said Menard employed and plaintiff at men a la for some time and then sent him to Kas Kas Kis for the purpose of sending him as a hand on board of a keel boat to New Orleans that said plaintiff removed about two days at the Kas Kas Kis and was the part in said keel boat to New Orleans That said plaintiff returned in same boat to Kas Kas Kis about the last of march 1817 and remained at that[?]
---
**Page 30** (5532_031.jpg)
> *Legal Function: Bill of Exception Part 2*
plan eight or nine days and then was sent in a keel boat to St. Louis that on the return of said plaintiff for saint Louis in said keel boat said Menard sent him after a four days at Kas Kas Kia to the swamp in Missouri where he remained about three weeks and then returned to Kas Kas Kia and was from there immediately sent to St Louis and delivered up to said Pierre Chouteau in of the an between said Pierre and said Menard that the delivery of said plaintiff to said Pierre Chouteau took place about the month of June 1817[?] The said Defendant then
on his behalf read in evidence the following depositions
to and the deposition of one Francois Menard which
is in the words and figures following to wit Francois
Menard of lawful age being produced owner and examiner
& (here set out Deposition as read) and as a the Deposition
of our Baptist [illegible] which is in the wards & [illegible]
following [illegible](here said our Daines[?] deposition) [illegible]
further wondered [illegible] offer in said cause the
Counsel for the plantiff moved the court to
[illegible] the Jury as follows there set out the
[illegible] [illegible] which in [illegible] the said court
refused to give to which refusal and [illegible]
said plantiff by his Counsel [illegible] and tend,
[illegible] his bill of exception which is signed by the Judge aforesaid
*Will . C. Carr*
---
**Page 31** (5532_032.jpg)
> *Legal Function: Bill of Exception Part 3*
Francois La Grange
alias Isadore
Pierre Chouteau Jr
Bill of Exceptions
*Filed 20th December 1827 A Gamble Clerk*
---
**Page 32** (5532_033.jpg)
> *Legal Function: Bill of Exception Page 4*
Pierre Menard stated he was not interested in this
wit at the of might seen that he was - that some
time in the year 1816 Pascal Corré applied to him
to purchase a negro man (the plaintiff) which he said
Core wished to sell, that he replied to said Core
he could not purchase as he W. Core knew [illegible]
[illegible] the witness resided at Kaskaskia in
the state of Illinois where slavery was not toler[?]
rated. Some time afterwards understanding
W Peter Chouteau Jr. the defendant wished to
purchase a slave he informed him that W Cere had
one for sale - to which W Chouteau replied W Cere
would not sell him the slave because he was desi
rous to sell him the some one who did not reside in
the town of of St. Louis . It was suggested by M.
Berthold that he M Menard could buy the slave
for W. Chouteau; but the witness objected to this
as it would not be treating his friend M. Cere
correctly. He however [illegible] agreed to buy
said slave for M. Chouteau and take him
down the river and keep him there some
months (perhaps five or six) and there deliver
him to the defendant, that he accordingly
bought the slave paid said Cere 500 $ for him took him to the [illegible] in
Missouri and delivered him to M Valle[?] to go
to work at Mine La Motta[?] with some other
hands - that sometime afterwards he sent
from said [illegible] to Kaskaskaia where he was
part on board a keel boat as ahand and
remaining there about two days went to New
Orleans and returned about 30 March 1817 as ahand[?] in said boat
to Kaskaskia where he remained a few days
for the purpose of unloading the boat, that he
was there sent in the sent to the by swamp in Cape [illegible]
County and after remaining there five or six
weeks returned on the boat to Kaskaskiaa & after two or three days
he was sent to St Louis & delivered to the deft
where
---
**Page 33** (5532_034.jpg)
he has remained [illegible] since. The witness repeated
that he bought the slave for defendant and
not for himself. The witness further said M.
Chouteau returned him the \$500 where be
said the slave to him - He also stated
he never bought him with any intention
of keeping him or making Kaskaskia his
place of residence-
---
**Page 34** (5532_035.jpg)
> *Legal Function: Jury Instructions*
Francois Lagrange
Pierre Chouteau
The counsel for the plaintiff prays the
followers [illegible] to the jury
1 that of this the jury shall be of opinion this the plaintiff
[illegible] in the state of Illinois with the person
who [illegible] [illegible] and who was a resident of said state
that this [illegible] [illegible] for the plaintiff
refused
2 That the right of the plaintiff to his freedom
is with [illegible] to any [illegible] [illegible] a under
standing between the person who purchased and
bought him to Illinois and any other person
[illegible] refused
3 That is the jury shall be of this the
plaintiff from [illegible] any [illegible] lawfully a resident of
of the state Illinois and in the therein of
a [illegible] of this [illegible] [illegible] [illegible] and [illegible] [illegible] [illegible] plaintiff this shall [illegible] a [illegible]
[illegible] given
4 that of the Jury shall be of opinion that the plaintiff
was said by [illegible] by a wherein of the state of
Missouri to a [illegible] of the state of Illinois [illegible]
and [illegible] [illegible] [illegible] [illegible] to said purchased
the sent and is [illegible] between said purchaser and
[illegible] person shall [illegible] the [illegible] of the plaintiff [illegible]
[illegible] same to his [illegible] [illegible] [illegible] of [illegible] [illegible] [illegible] residence in the state of Illinois
refused, because no [illegible] proved
---
**Page 35** (5532_036.jpg)
The court instructed the jury that if
they believed the plaintiff was bought
by Col Mernard[?] for his own use & [illegible]
to Illinois & Reps there with the in
[illegible] to make that his the slaves permanent
place of residence, they ought to
[illegible] for the plf[?].
> *Legal Function: Jury Instructions Part 2*
Francois LaGrange V. Bernard Pratt, Pierre Chouteau Jr., John P. Cabanne, Bartholomew Berthold, B. Pratt & Co. 1827, St. Louis Circuit Court Historical Records Project, accessed October 4, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60680