John Filion v. Pierre Chouteau, Jr.
Item
John Filion V. Pierre Chouteau, Jr. 1832, St. Louis Circuit Court Historical Records Project, accessed October 8, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60786
- Case Title
- John Filion v. Pierre Chouteau, Jr.
- Series
- Fur Trade
- Plaintiff
- Filion, John
- Defendant
- Chouteau, Pierre Jr.
- Date Filed
- 1832-11-10
- Filing Date
- 1832-11-10
- Plaintiff’s Attorney
- W.D.
- Defendant’s Attorney
- Geyer, Henry S.
- Court Name
- Saint Louis Circuit Court
- Court Term
- 1832-11
- Clerk
- Gamble, Archibald
- Sheriff
- Walker, John K.
- Blood, Sullivan
- Cause of Action
- Debt
- Case Notes
- Pierre Chouteau entered contract in 1828 with Filion who was to serve as a trapper with the American Fur Company; damages $3,000; Filion also spelled Filions.
- Case Number
- 131
- Identifier
- ccr1832.07976.006
- Source
- Missouri State Archives - St. Louis
- Rights
- Public Domain
- PDF Download
- Download PDF of all images
- Transcription
-
**John Filion v. Pierre Chouteau, Jr.**
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**Page 1** (7976_001.jpg)
> *Legal Function: Plaintiff's Complaint*
In the Circuit Court
November Term 1832.
St Louis County to wit John Filion complains of
Pierre Chouteau Junior of a plea of trespass in the
case upon promises: [illegible] whereas the said Choutean
heretofore to wit on the tenth day of April in the year
of our Lord one thousand eight hundred & twenty eight
at St Louis aforesaid did by a certain instruction
writing (which the plff cannot present in court because
the same is in the power & possession of the Deft)
promise & agree in consideration that he the said Filion
at St Louis aforesaid would enter into the second of the
American Fur Company (of which said company
the [illegible] Chouteau then was & now is an agent & director at
St Louis for the waters of the Missouri ) for the term
of one year from the last mentioned date & would serve
in the same in the business of trapping he the one Chouteau
undertook & then & there promised to pay the said
Filion
for his wages in the service of the [illegible]
company the sum of two hundred & sixty dollars
at the expriation of one year from the one last mentioned
date. and the said Filion says that in pursuance of said
written instrument & obligation he the one Filion did im-
mediately enter into the serviced employ of said American Fur Company & faithfully served the said Co.
in the business of trapping for one whole year next
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**Page 2** (7976_002.jpg)
following the [illegible] mentioned date to wit the first day
of April in the year of our Lord one thousand eight
hundred & twenty eight of which service to the said
Chouteau had due notice.
And whereas also heretofore to wit on the day & year
last aforesaid at St Louis aforesaid in condersation that
he the said Filion would contribute other his work labour
& services for & in behalf of the American Fur Company
in the business of trapping he the said
Chouteau (one
of the directors & partners of the American Fur Co. as
aforesaid) undertook & then & there faithfully promised
to pay the one
Filion so much money as he
therefore reasonably deserved to have of the Choteau[?]
for any length of time which he might continue in
the service of [illegible] Chouteau whenever he the said
Chouteau should be there unto afterwards requested.
And the said
Filion [illegible] that [illegible] in the promise of
undertaking of the [illegible] Chouteau he entered into the
service & employement of [illegible] Chouteau & remained
& continued in the same for the space of four years
& a half from the last mentioned date & that his
labor & services which were contributed in favor of said
Chouteau were reasonably worth the fullest sum of
two thousand dollars of which Chouteau since had notice.
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**Page 3** (7976_003.jpg)
> *Legal Function: Plaintiff's Complaint, part 2*
And whereas also afterwards to wit on the tenth day of
April in the year of our Lord one thousand eight
hundred & twenty nine at the Company aforesaid, he
the said Chouteau did promise & engage in consideration
that the said Filion would continue in the further
service & employment of the [illegible] Chouteau in the
in business of trapping, to pay him the said Filion
either the usual wages of a trapper or one half the furs &
peltries[?] which the said Filion should bring in from
the hunt at any time while he remained in the
employ of the American
Fur Company (of which
the one Chouteau was a partner as aforesaid.) And the
one Filion [illegible] that he [illegible] in the [illegible]
undertaking of the [illegible] Chouteau did remain & continue
in the service of [illegible] Choutean in the business of trapping
as aforesaid with the choice of taking one half of the
furs which he might obtain in trapping, & that he
by his great diligence & skill did procure a large
quantity of furs of great value to wit three hundred
beaver skins & other peltries[?] all of which were of
the value of fifteen hundred dollars & that he performed
livery services of great value in behalf of the [illegible] Chouteau ,
& that in pursuance of the [illegible] mentioned agreement
he remained in the active service & employ of the said
Chouteau for the space of three years & a half from the last mentioned date of which services, he the [illegible] Chouteau
had due notice to wit at [illegible] aforesaid.
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**Page 4** (7976_004.jpg)
And whereas also afterwards to wit on the first day of
October in the year of our Lord one thousand eight
hundred & thirty two, at St Louis aforesaid, he the
said Chouteau was indebted to the said
Filion in
the further sum of two thousand dollars for the work
labor & services of the [illegible] Filion done & performed
in behalf of [illegible] American Fur Company in the
business of trapping, at the special insistence & request
of the in Chouteau , & for the period of four years &
a half preceding the last mentioned date. And
being so indebted he the said Chouteau in consideration
thereof to wit on the day & year last mentioned, undertake
& [illegible] there promised to pay the said
Filion the
said [illegible] mentioned sum of money when he the said
Chouteau should be there unto afterwards requested.
Yet the said Choutean not regarding his said agreement
or either of his said promises & undertakings so by him
made as aforesaid, hath not as yet paid the said
Filion either of the said sums of money or any part
or parcel of the furs aforesaid, though often requested
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**Page 5** (7976_005.jpg)
> *Legal Function: Plaintiff's Complaint part 3*
by the [illegible] Filion so to do;but hath hitherto refused
& neglected and still doth refuse & neglect so to do
Whereby the said
Filion that he hath sustained
great injury to wit in the sum of three thousand
dollars & for this he brings this suit [illegible].
*W. D. [illegible]
Atty for Plff*
> *Legal Function: Summons of Pierre Chouteau, Junior *
The State of Missouri
County of Saint Louis ss To the Sheriff of the County of Saint Louis Greeting
We command you to summon Pierre Choutean Junior that he
be and appear before the judge of our Circuit Court at the next
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 [illegible] then
and there to answer unto John Filion of a plea of trespass on the
case upon promises whereby she said Filion saith that he hath
sustained preat injury to writ in the sum of three thousand dollars
and have you then there this writ
*Witness Archibald Gamble Clerk of our
said Circuit Court at Office this Tenth
day of November One thousand Eight
Hundred and thirty two
Archibald Gamble Clerk*
> *Legal Function: certificatation of execution*
Executed this writ on Pierre Chouteau Junior by
offering to read it & the declaration to him which
he refused to hear & acknowledged the service
of the same in the city of St Louis on the tenth
day of November 1832
*John K Walker Shffs
by S. Blood Dp Shff Service $ 100*
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**Page 6** (7976_006.jpg)
And the said Pierre Chouteau Junior by Geyer his
attorney comes & defends the wrong and injury when &
[illegible] that he did not undertake & promise
in manner & form as the plaintiff hath above
thereof alleged against him & of this he
puts himself upon the country &c.
*Geyer for Deft.
filed Nov29th 1832 A G Clk*
> *Legal Function: cover*
No
Action of Assumpsit
In the Circuit Court
November Term
1832 Filion v. Chouteau .
> *Legal Function: caption*
No 131
Saint Louis Circuit Court
November Term 1832. John Filion
vs
Pierre Chouteau Jr .
This is an action of Assumpsit
Damages \$3000 -
Let a summons issue
*Filed 10th November 1832
Archibald Gamble Clerk*
> *Legal Function: Certificate of Filing*
Plea [illegible] filed
Nov 29th 1832
*A Gamble Clk*
> *Legal Function: court record*
Discontinued Book 6 page 453
*Arch . Gamble Clerk*
Nov - 10th
John Filion V. Pierre Chouteau, Jr. 1832, St. Louis Circuit Court Historical Records Project, accessed October 8, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60786