Jim Brown, by and through his next friend, Jenny Brown v. William Head

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Jim Brown, by and through His Next Friend, Jenny Brown V. William Head. 1844, St. Louis Circuit Court Historical Records Project, accessed October 9, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60921

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Case Title: Jim Brown, by and through his next friend, Jenny Brown v. William Head
Series: Freedom Suits
Plaintiff: Brown, Jim
Defendant: Head, William
Date Filed: 1844-10-14
Next Friend: Brown, Jenny
Filing Date: 1844-10-14
Plaintiff’s Attorney: Smith, Elias B.
Defendant’s Attorney: Lord, Charles B.; Leslie, Miron
Court Name: St. Louis Circuit Court
Court Term: 1844-11
Judge: Krum, John M.
Clerk: Ruland, John
Sheriff: Milburn, William; Dowling, Richard
Cause of Action: Trespass; False Imprisonment; Assault; Battery
Case Notes: Damages $500; plaintiff alleged to be 14 years old, son of Jenny Brown, a free person; plaintiff sued by next friend Jenny Brown.
Case Number: 229
Identifier: ccr1844.06801.008
Source: Missouri State Archives - St. Louis
Rights: Public Domain
PDF Download: Download PDF of all images
Transcription: **Jim Brown, by and through his next friend, Jenny Brown vs. William Head**

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**Page 1** (6801_001.jpg)
> *Legal Function: Complaint*

State of Missouri as St. Louis County
In the St. Louis Circuit Cort Nov Term 1844
Jim Brown who sues by his next friend Jenny Brown complains of William Head of plea of trespass and false imprisonment
for that whereas the said defendant on the day
of september in the year Eighteen hundred and forty
four made an assault upon the said plantiff[?]
at the county and state aforesaid and then and there imprisoned and attracted the said kept and detained him in prison then and there without any reasonable probable cause whatsoever for a long span of time to wit for the space of
twelve hours then next following country to the laws of the said state and against the will of the said
plantiff And the said plantiff further[?]
of the committing of the said grievances was still is
a free person And Father that the said defendant then and there held and still holds the said plantiff[?]
in slavery and then wrongs to the said plantiff the said defendant then[?] and there did Countrary[?] to
the pleas and dignity of the said state And to the
damage of the said plaintiff of Five Hundred dollars and Therefore the said plaintiff brings suit &c

*Elias B Smith p.q..*

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**Page 2** (6801_002.jpg)
> *Legal Function: Petition*

State of Missouri
as
St. Louis County
To the Hon. Judge of the Circut Court of St. Louis County[?]
ss
Your petitioner respectfully states to the Court Your Honor that the honor mentioned in the Declaration above is
held in slavery by William Read in this County and that
he the said Louis is entitled to his freedom. In Consequence of a action proceeding him in the state of Wrynim County[?] to the laws of the
state of Virginia to wit Jenny Brown the mother of said Jim
was brought into the state of Virginia for the purpose of sale by him the Martin of which slaves then and is now a free person and was afterwards brought to
the state of Missouri and in said state of Missiouri she has been[?] held in slavery for more than twenty years against
her will during which time the said Lein was born and now of the age of[?]. fourteen years (14 years)
Your petitioner therefore prays your Honor to allow him to sue as a free person
to establish his right to freedom and duly

*Sworn to and submitted before me the 14th day Oct. 1844
James J Purely a Justice of the County
Court and for St. Louis County Jenny her X mark Brown*
> *Legal Function: Caption*

In the St. Louis Circuit Court
Nov Term 1844

*Elias B Smith p.q..*

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**Page 3** (6801_003.jpg)
> *Legal Function: Order*

State of Missiouri County[?] of St. Louis In the St. Louis Circuit Court . - On reading the for giving petition
It is ordered that the petitioner“Jim Brown " has
leave to sue as a poor person, and that Elias B. Smith Esq., [illegible] [illegible]
is hereby assigned as his counsel: and it is further ordered that
said Petitioner have reasonable liberty of attending his counsel and
the Court, as occasion may require, that he be not removed without
the jurisdiction of this Court, and that he be not subjected to any
severity on account of his application for freedom.

*John M K. Judge, [illegible]*

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**Page 4** (6801_004.jpg)
> *Legal Function: Caption, part 2*

In the St. Louis County Court
Nov Term 1844
Jim Brown by his next friend
vs Trespass
Wm Head
[illegible]

*Elias B. Smith.
p.q..*

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**Page 5** (6801_005.jpg)
> *Legal Function: Summons*

County of St. Louis , ss. The State Of Missouri , To the Sheriff of St. Louis County—Greeting:
We command you to Summon William Head
if he be found in your County that he be and appear before before the Judge of our Circuit Court , on the first day of the next term thereof, to be
held at the City of St. Louis , within and for the county of St. Louis , on the third Mon-
day of November next, then and there to answer unto
Jim Brown who sues by his next friend
Jenny Brown of a plea of trespass
and false imprisonment
to the damage of said plaintiff Five hundred
dollars: And have you then there this writ.

*Witness, John Ruland , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
city of St. Louis , this 24th day of
October in the year of our Lord eighteen
hundred and forty four John Ruland Clerk.*
> *Legal Function: Summons, part 2*

I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal, at St. Louis , this day of 184

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**Page 6** (6801_006.jpg)
> *Legal Function: Certificate of Execution*

Executed this writ in the County of St. Louis
on the 2nd day of October 1844 by reaching it and the
declarition to William Head the deffendant and
also by reading to Said William Head the orders
of the Judge endorsed upon this writ

*Fee \$1.50
William Milburn[?] Sheriff By R Dowling Deputy[?]*
> *Legal Function: Certificate of Filing*

No 229 St. Louis Circuit Court
November Term 1844
Jim Brown by his next
friend Jenny Brown
vs summons William Head
Trespass & false imprison= =ment[?]

*Damages $[?] 500
E B Smith p.q.
Filed Oct 24th 1844
John Ruland Clerk*
> *Legal Function: Order*

It is ordered that the petitioner have
reasonable liberty, to sue as a poor
person and Elias B Smith assigned
her as counsel. It is further ordered
that she have reasonable liberty to
attend the Court and her counsel as
occasion may require and that she
be not removed out of the jurisdiction
of this court & that she be not
subjected to any severity on account
of her application for freedom

*Free ✓ (138)*
> *Legal Function: Summons, part 3*

plea filed 15p 290 trespass feby[?] 2 1846 17 p 72

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**Page 7** (6801_007.jpg)
> *Legal Function: Answer*

Jim Brown who sues by his
next friend Jenny Brown
vs
William Head
In St. Louis Circuit Court
by Nov. term 1844.
And the said defendant William Head
by [illegible] his attornies[?], comes and
defends the force and injure when
and say, that he is not guilty of the
said suppored trespass above said what
charge in any part thereof in manner
and form, as the said plaintiff hath
above thereof complained against here
for this he puts himself upon the
country [illegible]

*Leslie Lord for Deft.*

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**Page 8** (6801_008.jpg)
> *Legal Function: Certificate of Filing*

Jim Brown
by hsi next friend
v
William Head
Plea [illegible]

*Leslie Lord for Deft. Filed Nov 18th 1844
John Ruland Clerk*

Item sets: All Circuit Court Records; Freedom Suits Case Files, 1814-1860; Circuit Court Cases