Squire Brown, a person of colour v. Charles R. Anderson

Item

Squire Brown, a Person of Colour V. Charles R. Anderson. 1844, St. Louis Circuit Court Historical Records Project, accessed October 9, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60927

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Case Title: Squire Brown, a person of colour v. Charles R. Anderson
Series: Freedom Suits
Plaintiff: Brown, Squire
Defendant: Anderson, Charles R.
Date Filed: 1844-01-17
Filing Date: 1844-01-17
Plaintiff’s Attorney: Dayton, Benjamin B.
Defendant’s Attorney: Krum, John M.; Todd
Court Name: St. Louis County Court
Court Term: 1844-01
Clerk: Ruland, John
Justice of the Peace: Mullanphy, Bryan
Sheriff: Brotherton, Marshall; Milburn, William
Cause of Action: Trespass; False Imprisonment; Assault; Battery
Case Notes: Owned by William Anderson, sold to Charles Anderson; plaintiff claimed Anderson did not provide him with clothing, would hire him out and keep all the wages and threatened to send him away.
Case Number: 328
Identifier: ccr1844.06858.016
Source: Missouri State Archives - St. Louis
Rights: Public Domain
PDF Download: Download PDF of all images
Transcription: **Squire Brown, a person of colour v. Charles R. Anderson**

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**Page 1** (6858_001.jpg)
> *Legal Function: Motion to File in Forma Pauperis*

To the Honorable Bryan Mullanphy[?] Judge
of the Circuit Court of St Louis County
The petition of Squire
Brown a man of color respectfully represents
that he is [illegible]
of instituting a suit against one Charles R
Anderson in order to establish the right
of your petitioner to freedom that his claim [illegible]
is founded upon the following grounds to wit
that sterry Brown who had formerly owned
your petitioner for some six or eight years [illegible]
to the fifth day of May 1841.& during the time
he so owned your petitioner hired out your
petitioner to work in the County of St Clair
State of Illinois at various times between
the years 1839 & 1841. for several months at
a time. Your petitioner represents further
that since May 1841. he has been [illegible]
from said & [illegible] Brown his former &[?]
is now deemed by the said Anderson as his property & that he is now by the said Anderson
held in slavery.
Your petitioner therefore
prays that he may have learn to sue as a
poor person in order to establish his right
to freedom

*Squire his mark Brown*
> *Legal Function: Affidavit*

State of Missouri
County of St Louis
ss
Squire Brown the petitioner
above named being duly
sworn deposes & says that the facts set forth
in the above petition are true to the best of the
knowledge beliefs of this deponent

*Sum to this 17 day of January
1844, before me*

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**Page 2** (6858_002.jpg)
> *Legal Function: Order*

State of Missouri
County of St Louis
Be it remembered that this
within named Squire Brown is hereby allowed
to sue as a poor person & Benjamin B Dayton is
assigned as his counsel. and it is hereby
ordered that said Brown have reasonable
liberty to attend his counsel & the court as occ-
asion[?] may require. that he be not removed
out of the jurisdiction of the St Louis circuit
court that he be not subjected to any sever
ity on account of his application for freedom
In listing which [illegible] [illegible] set may
hand this seventeenth day of January 1844 —

*Bryan Mullanphy[?] Judge [illegible] 8th [illegible] of
Missouri*

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**Page 3** (6858_003.jpg)
> *Legal Function: Complaint*

St St. Louis Circuit Court
November Term 1843 St Louis County ss.
Squire Brown plaintiff in
this suit by his attorney complains of
Charles R Anderson of a plea of trespass
In that the said defend
ant heretofore to wit on the first day of January
eighteen hundred forty four at the City of
St. Louis at said County with force & arms
made an assault on said plaintiff & then
beat bruised &[?] ill treated him & then & there im
prisoned[?] him & kept him in prison for a long
space of time to wit for the space of ten days
then next- following contrary to the laws this
State of Missouri & againstthe will of the
said plaintiff. & other ways to the said
plaintiff then & there did against the Law
of the State of Missouri to the damage of
the said plaintiff of five hundred dollars.
And the said plaintiff
avers that before & at the time of the committing
of the grievances aforesaid by the said defendant
he the said plaintiff was & still
is a free person & that the said defendant
held & still holds him in slavery. Therefore
he brings his suit [illegible]

*B. B. Dayton [illegible]
Plff [illegible]*
Charles R Anderson
ad
Squire Brown
And the said Defendant Charles R
Anderson . Comes & defends the wrong [illegible]
& says that he is not guilty of the trespass
& assault & battery in manner & form as. the
said plff in his said Declaration hath
alleged & of this he puts himself on the County
Todd & Krum[?] for Deft.

*This plea filed Jany 17th 1844. John Ruland Clerk*

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**Page 4** (6858_004.jpg)
> *Legal Function: Certificate of Filing*

No. 328. In the St St. Louis Circuit Court .
November Term 1843. St St. Louis Circuit Court
Squire Brown
vs
Charles R Anderson
Suit for freedom
Trespass
Dam $ 500. ad
[illegible] pleas
June 18

*B. B. Dayton
plff atty Filed by consent Jany 17th 1844 John Ruland Clerk*
Peter & [illegible] filed (by consent) & Plff allowed to the as a poor person order assigning Counsel &c & plea
filed BK 14 p 338. Venue changed to Comr. pleas BK 15 p 131 (June
18. 1844.)

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**Page 5** (6858_005.jpg)
> *Legal Function: Affidavit*

State of Missouri
County of St. Louis
Buyam B Dayton buy duly
sum deposes & says that on
the 17th day of January [illegible] a suit was
commenced in the St. Louis County Court by Squire Brown against
Charles B Anderson for freedom. by filing
a declaration by Consent & also a Petition
that plaintiff have been to sue as a poor
person as provided by Statutes at the [illegible]
an order was made by the Honorable Bryan
Mullanphy[?] Judge of said Court that
said Brown had [illegible] as a poor
person that this [illegible] be assigned as
his Counsel. also an with that said
Brown have reasonable liberty to attend
his Counsel & the Court as occasion
might require.& that he be not removed
out of the jurisdiction of the said Court
& that he be not subject to any severity
on account of his application. John
M Shrew Esq an attorney of [illegible]
[illegible] appeared for the said Anderson
& concealed to all the said orders &
the [illegible] of the said declration & also
on behalf of Todd & Krum[?] of which [illegible]
his is to [illegible] filed a plea for the
said Anderson on the [illegible] day after
said and this [illegible] further says
that he is informed by John W [illegible]
Constable of St Louis Court that he
said [illegible] at the request of said
Anderson this day awarded [illegible] Brown
took him to the Slave Boat Admiral
for the purpose as said Anderson
told him of [illegible] him south. that
[illegible] said Brown was put on said boat

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**Page 6** (6858_006.jpg)
what was [illegible] for New Orleans
In
what with said Brown has defauled
for that place. [illegible] this affiant believes
therefore that said Brown [illegible] is now by [illegible] out
of the jurisdiction of this Court
Subscribed to this 19th
January 1844 before me

*B B Dayton Bryan Mullanphy[?]
Judge 8th. Jud. Cir.[?]. of Mo.*
> *Legal Function: Order*

State of Missouri
County of St. Louis The State of Missouri
to the sheriff of the county of St. Louis greeting
whereas - Bryan Mullanphy[?] the Judge
of our Circuit Court of the Eighth Judicial
Circuit, which includes the county of St. Louis
is satisfied from the foregoing affidavit that
Squire Brown a man of color a petitioner for
freedom, who has instituted suit in said court
to recover the same, is about to be removed
out of the Jurisdiction of said court, you are
hereby commanded to seize said petitioner wherever he may be found and bring him
before our said Judge on Twentieth January
in 1844 at nine o'clock A. M. at the goal in said county
and summon any person claiming him
or in whose possession he may be found
to appear before our said Judge at said time
& place & have you then there this writ-
As witness the hand of our said Judge
At Chambers in the City of St Louis this
nineteenth day of January in the year of
Our Lord One thousand Eight hundred and forty four

*Bryan Mullanphy[?] Judge 8th Jud. Cir.[?] of Mo.*

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**Page 7** (6858_007.jpg)
> *Legal Function: Certificate of Execution*

Executed this writ in the County of
St Louis on the 20th day of January 1844 by
seizing the body of Squire Brown and having
him before the Honorable Bryan Mullanphy[?]
Judge of the 8th Judicial Circuit of Missouri at
the goal as I am herein commanded and
also by reading it to Israel Morris , he being
the person claiming the said Squire Brown
and in whose possession he was found

*William Milburn[?] Shff by N.C [illegible] Dpty fees $ 2.00 Extra [illegible] 20.00 $ 22.00*

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**Page 8** (6858_008.jpg)

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**Page 9** (6858_009.jpg)
> *Legal Function: Order*

State of Missouri
County of St Louis
Ss
whereas Squire Brown a
man of color has been brought before me
by virture of warrant hereto annexed
and one Israel Morris who claims him
being, at the St Louis goal on 20th
Jany 1844, called, comes not there upon
the sheriff is hereby ordered to take possession
of said Squire Brown , and hire him out
from time to time during the pendency
of the suit that hath been brought by said
Brown in the St Louis County Circuit Court
to recover his freedom and take a bond
from the hirer in the penalty of [illegible] hundred dollars conditioned as provided by
eighth section of the act approved 27 Jan 1835[?]
entitle "an act to enable persons held
a in slavery to sue for their freedom - "

*Bryan Mullanphy[?] Judge 8th Jud. Cir.[?] of
Missouri*

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**Page 10** (6858_010.jpg)
> *Legal Function: Certificate of Filing*

No 328 In the St Louis Circuit court
November Term 1843.
In the matter of Squire
Brown a person of colour
vs
Israel Morris &
C. R Anderson
Judgt[?] is Morris & Anderson for costs of this proceding BK 14 p 357. Motion to set same
aside as to Anderson filed Feby 12th 1844 & overruled 14 p 398. motion to set aside last overruling
(for a rehearing) filed Feby '44 overruled BK 14 p sustained 14p 422 &
no to set aside judgt[?] overed & Bill of Exs.[?] filed 14p 422.

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**Page 11** (6858_011.jpg)
> *Legal Function: Motion to Set Aside Judgment*

In the matter of Squire
Brown a person of color In the Circuit Court
November Term 1843
Charles R.Anderson
comes & moves the Court that so much of
the judgment of this court renderd on the
Twenty sixth day of January A D 1844 as [illegible]
that said Anderson pay [illegible] the costs & charges
incurred in this behalf, be set aside &
vacated. Because the same is without
authourity in law.

*Todd & Krum[?]
attys for Anderson*

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**Page 12** (6858_012.jpg)
> *Legal Function: Certificate of Filing*

In Circuit Court
In the matter of
Squire Brown a
person of color
Mo. to vacate
judgt[?]. as to Chas.R.Anderson-

*Todd & Krum[?]
attys. for Anderson Filed February 12th 1844 John Ruland Clerk*

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**Page 13** (6858_013.jpg)
> *Legal Function: Motion to Dismiss*

In the matter of
Squire Brown
person of color
Charles R Anderson by
his attornies[?] move the
court to set aside the [illegible]
made in this cause one overruling
the motion of said Charles
R.Anderson filed on a
former day of the present
term of this Court, &
that a new trial be granted
to said Charles R Anderson

*Todd & Krum[?]
for Chas. [illegible] R.Anderson*

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**Page 14** (6858_014.jpg)
> *Legal Function: Certificate of Filing*

In the matter of
Squire Brown
a person color
Motion to set aside
order —

*Filed February 29th 1844. John Ruland Clerk*

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**Page 15** (6858_015.jpg)
> *Legal Function: Ruling on Motion to Dismiss*

In the matter of
Squire Brown a
person of color de
Be it remembered
that on the 12th day of February 1844 Charles R. Anderson filed his motion
in words & figures following to wit:
(here insert said motion) which
motion the court overruled
thereupon the said Charles R
Anderson on the 29th day of February
AD 1844 filed his motion in
word & figures following to wit:
(here insert said motion) which
motion the court overruled to which [illegible] judgment
of the court the said Charles R
Anderson by his [illegible]
this his bill of exceptions
may be signed & sealed &

*Bryan Mullanphy[?] Judge of the 8th Jud
Cir.[?] of Mo.*

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**Page 16** (6858_016.jpg)
> *Legal Function: Certificate of Filing*

In the matter
of Squire Brown
a person of color & c
Bill of exceptions [illegible]

*Filed March 15th 1844. John Ruland clerk [illegible] [illegible] [illegible]*

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