Margaret v. George Brown, William Dallam

Item

Margaret V. George Brown, William Dallam. 1831, St. Louis Circuit Court Historical Records Project, accessed October 8, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60750

Case Title
Margaret v. George Brown, William Dallam
Series
Freedom Suits
Plaintiff
Margaret
Defendant
Dallam, William
Date Filed
1831-07-26
Next Friend
Brown, George
Filing Date
1831-07-26
Plaintiff’s Attorney
Newman, John
Court Name
St. Louis Circuit Court
Court Term
1831-11
Judge
Carr, William C.
Clerk
Gamble, Archibald
Sheriff
Walker, John
Cause of Action
Trespass
Assault and Battery
False Imprisonment
Case Notes
Plaintiff, aged 21, born in Kentucky; freed via her grandmother who was owned by Colonel Richard Dallam & freed by manumission in Maryland; the Colonel's son, the defendant, forcibly moved plaintiff to St. Louis with her mother, Jane, & siblings.
Case Number
4
Related Court Case Number
6742
6743
Related Project ID
ccr1831.06742.003
ccr1831.06743.003
Identifier
ccr1831.06741.007
Source
Missouri State Archives - St. Louis
Rights
Public Domain
Transcription
**Margaret vs. George Brown, William Dallam**

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**Page 1** (6741_001.jpg)
> *Legal Function: Petition for Permission to Sue as Poor Persons*

To the Honourable the Judge of the St Louis Circuit
Court . This petition of Margaret , Henry
Sally ,
persons of colour, represents to your Honour, that
they, as they belive are entitled to their freedom on
the following grounds: their mother Jane was formerly
the slave of Col.Dallam of Maryland and by
him taken to the State of Kentucky [illegible] where
she resided untill a few years since, and where your
your petitioners were born, that [illegible] [illegible] her
master removed her from Maryland he informed
her that he had manummitted[?] her, such
manummissions[?] to take effect at a future
time, and that said time had elapsed before your
petitioners were born; your petitioners say
that they are informed   believe that said
manummission[?] of their matter was by deed
and that the deed is now of record in the proper
office in the state of Maryland, which can be
obtained. They also state that some time after
the arrival of their mother in Kentucky she
was by her said master actually freed   discharged
from all service   obedience, he giving her
complete   perfect personal liberty and power
to do with her self what she pleased, and requiring
from her neither service or wages for her time.
That from that time until the time of her masters
death a period from ten to fifteen years she
lived as a free person with the consent of her
master as aforesaid in the same town or neighborhood
with him. That they your petitioners
were with their mother, brought to St Louis by
a son of their old master Cal Dallam namely
William Dallam , who afterwards went to Kentucky

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**Page 2** (6741_002.jpg)
and that they are now claimed by him as his slaves
and that said Dallam by his agents have been and
now are making preparations to carry off your
petitioners to the South beyond the reach of
assistance   where it will be impossible for
them to assert their right to freedom your petitioner
say that they are all imfants under twenty
one years- they therefore pray that they may
severally be permitted to sue as poor persons
by their next friend George Brown , and that
your honour will assign them counsel for
to prosecute their suits for freedom- And as
your honour has already authorized their
said mother to sue for her freedom, your petitioners pray your honour to grant them
the same privilege in which case they believe
they will be able to establish their right to
freedom   your petitioners will [illegible] pray etc[?]

*Henry
Sally
Margaret
by
their next
friend George Brown*

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**Page 3** (6741_003.jpg)
> *Legal Function: Order Granting Permission to Sue as Poor Persons*

State of Missouri
Third Judicial Circuit Court : It is hereby ordered
that an the foregoing petition that the subscribers thereto
Henry , Sally and Margaret be permitted to sue as
poor persons by George Brown their next friend
to establish their right to freedom and John Newman
Esq is assigned on their counsel - It is also ordered
moreover that said Henry Sally and Margaret shall have reasonable
liberty to attend their counsel and the Court when other occasion may require
that said Henry , Sally and Margaret not be removed out of the jurisdiction
of the Circuit Court of St Louis County nor be Subjected to any
severity because of their application for freedom given under
my hand their 22 day of July A.D 1831.

*[illegible] [illegible] [illegible]*

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**Page 4** (6741_004.jpg)
> *Legal Function: Order Granting Permission to Sue as Poor Persons Part 2*

Margaret
Sally
Henry [illegible]
Petition [illegible]

*Filed July 22nd 1831 A gamble Clk*

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**Page 5** (6741_005.jpg)
> *Legal Function: Certificate of Execution*

The defendants not found in my
County 12th Novr 1831
[illegible] [illegible] [illegible]

*[illegible] [illegible] [illegible]*
> *Legal Function: Caption*

No 4 St St. Louis Circuit Court
November Term 1831
Margaret by next friend
vs
William [illegible]
Declaration

*Dallow Filed 23rd July 1831 Archibald Gamble Clerk*
> *Legal Function: Cover*

This is an action of trespass
assault   battery   false
imprisonment [illegible]
$ 500 [illegible] [illegible] summons

*[illegible] [illegible]*

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**Page 6** (6741_006.jpg)
> *Legal Function: Complaint*

In the St St. Louis Circuit Court
County of St Louis , to wit, November Term 1831
Margaret a girl of colour
an infant under the
age of twenty one years by George Brown her
next friend complains of William Dallow in
custody   of a plea of trespass of assault   battery
false imprisonment for that heretofore
to wit, on the twentieth day of july in the year
Eighteen hundred   thirty one at the county aforesaid
the said Defendant with force   arms made
an assault upon the said plaintiff   then
there beat wounded   ill treated her and then
there with force and arms falsely   unlawfully
imprisoned the said plaintiff   kept her and
detained her in prison there without any
lawful authority or cause for a long space of
time to wit for the space of two days there next
ensuing - and said plaintiff further says that
before and at the time of the committing of the
said several grievances she was   still is a
free person   that said Defendant held   detained
still holds   detains her in slavery wherefore
the said plaintiff says she is greatly injured
and hath sustained damage to five hundred
dollars   therefore she sues   etc[?]

*John Newman esq [illegible]*

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**Page 7** (6741_007.jpg)
> *Legal Function: Summons*

The State of Missouri
County of Saint Louis . ss To the Sheriff of the county of Saint Louis
Greeting
We Command you to summon William Dallam that he be and appear
before the Judge of our Circuit Court at the next November term thereof
to be held at the city of St Louis within and for the County of Saint Louis
on the fourth monday of November next then and there to answer unto
Margaret a Girl of color an infant under the age of twenty one years by George Brown her next friend of a plea of trespass assault and Battery and false imprisonment wherefore the said plaintiff says she is greatly injured
and hath sustained damage to five hundred dollars and have you then there
this writ

*Witness Archibald Gamble Clerk of our sid Circuit
Court at Office this Twenty Second day of July One
thousand Eight Hundred and thirty one Archibald Gamble Clerk*
> *Legal Function: Order*

copy of the order of the Judge on endorsed on the petition of plaintiff [illegible]
State of Missouri - Third Judicial Circuit to wit; It is hereby ordered that on
the foregoing petition that the subscribers thereto Henry Sally and Margaret be
permitted to sue as poor persons by George Brown their next friend to establish
their right to freedom and John Newman Esq is assigned as their counsel it
is also ordered moreover that said Henry Sally and Margaret shall have
reasonable liberty to attend their counsel and the court when occasion may
require and that said Henry Sally
Margaret shall not be removed out
of the Jurisdiction of the Circuit Court of St Louis County nor be subjected
to any severity because of their application for freedom- given under my
hand this 22 day of July A D 1831

*Will C Carr*

Margaret V. George Brown, William Dallam. 1831, St. Louis Circuit Court Historical Records Project, accessed October 8, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60750