Hester Williams, Priscilla Williams, and Mary Ella Williams, by and through their next friend, Jordan M. Early v. Frederick Norcum, et al.

Item

Hester Williams, Priscilla Williams, and Mary Ella Williams, by and through Their Next Friend, Jordan M. Early V. Frederick Norcum, Et Al. 1853, St. Louis Circuit Court Historical Records Project, accessed October 9, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60969

Case Title
Hester Williams, Priscilla Williams, and Mary Ella Williams, by and through their next friend, Jordan M. Early v. Frederick Norcum, et al.
Series
Freedom Suits
Plaintiff
Williams, Hester
Williams, Priscilla
Williams, Mary Ella
Defendant
Norcum, Frederick
McAfee, A. B.
Blakey, Granville C.
Moore, William E.
Loyden, Edmond
Date Filed
1853-10-11
Next Friend
Early, Jordan M.
Filing Date
1853-10-11
Plaintiff’s Attorney
Blackburn, Edward C.
McLean, Milton N.
Defendant’s Attorney
Williams, Willis L.
Court Name
St. Louis Circuit Court
Court Term
1853-11
Judge
Hamilton, Alexander
Clerk
Cerre, Michael S.
Hammond, William J.
Sheriff
Wimer, John M.
Maddox, Turner
Blakey, James C.
Picker, Charles
Hegdom, J. B.
Sworn Declarant
DeWitt, William
Glover, Samuel T.
Harvey, Thomas
Hawks, Cicero S.
Lynch, Bernard M.
Morehead, Phillip C.
Richardson, John C.
Smith, William
Cause of Action
Trespass
False Imprisonment
Assault
Battery
Case Notes
Hester alleged Priscilla was daughter of Norcum of New York, who destroyed original deed of emancipa(...)
Case Number
119
Identifier
ccr1849.06872.042
Source
Missouri State Archives - St. Louis
Rights
Public Domain
Transcription
**Hester Williams, Priscilla Williams, and Mary Ella Williams, by and through their next friend, Jordan M. Early v. Frederick Norcum, et al.**

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**Page 1** (6872_001.jpg)
> *Legal Function: Certification of Manumission*

New York Oct 5th 1849
This is to certify, that negroe woman Hester & Children formerly
my slaves in St Louis, are free, and have all the rights to go where
they please, that other coloured people have xxxxx - They
were set free by me in January last.

*F. Norcum*

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**Page 2** (6872_002.jpg)
[blank]
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**Page 3** (6871_003.jpg)
> *Legal Function: Plaintiffs' Petition*

Hester Wiliams
Priscilla H. & ~~Mary~~ Ella
her children, by ~~xxx~~
their next fried -- Plff

Jordan M. Early
A. B. McAfee
Frederick Norcum
Granville C Blakey —
^ defendants ^
Wm. E Moore

In the Circuit Court of
St Louis County St Louis
County Set. November Term
In the Circuit Court of
St. Louis County. St Louis
County Sct. November Term
1853

Plaintiff states that on
the day of January eighteen hundred and
forty nine the defendant Frederick Norcum
executed to the plaintiff a deed of manumission
for herself and her two children Priscilla
~~Williams~~ who was the illegitimate
child of the said defendant Norcum, and
~~Mary~~ Ella Williams the child by her ^ late ^ husband
by which said deed she became free as well
as both of her children ^ the other plaintiffs ^ . That on the seventh
day of October 1853. She carried the said
deed of manumission to the said Norcum
at his request and plaintiffs charge that
he destroyed the same; and had said plain-
tiffs arrested and caused them to[?] be
delivered to A. B. McAfee ^ Granville C Blakey ^ and the other
^ Moore ^ defendant alledging that he had sold
-them to the said McAfee , and Blakey & Moore
Plaintiffs further state that the defendant
Norcum in the month of October 1849
when plaintiffs were imprisoned [?] ^ on charge of being runaway slaves ^ gave to
the plaintiffs the following certificate in
words and figures as follows To wit

New York. Oct. 5th 1849
This is to certify that negroe woman Hester
& children formerly my slaves in St Louis

> *Legal Function: Certification*

This is to certify that negroe woman Hester
& children formerly my slaves in St. Louis
are free and have all the rights to to go where
they please that other coloured people have

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**Page 4** (6872_004.jpg)
they were set free by me in January
last.

*(signed) F. Norcum*

Thereby recognizing and ratifying the previous
deed of manumission all of which
will [illegible] freely appear, by reference to the
said certificate. marked (a) and made
a part of this petition.

Plaintiff further charge that the defendants
McAfee & Blakey & Moore[?] was before they purchased
plaintiff (if they have purchased them) aware
of all the facts set forth in this petition
and of the freedom of the plaintiff.
but not regarding their rights - both the
said defendants with force and arms
arrested the said plaintiffs. [illegible] at
the Circuit aforesaid on the 9th day of
~~November~~ October 1853. and then and there seized
and laid hold of the said plaintiffs
and with force and violence pulled and
dragged about the said plaintiffs and
then and there forced and compelled the
said plaintiffs to go from and out of
a certain public house situated and being
in the county of St. Louis into the public
street there, and then and there forced and
compelled them to go in and along
several streets, to a certain negro jail
situated in the county aforesaid and
owned and kept by the defendant
McAfee, & Blakey Moore and then and there impris
-oned the said plaintiff without any
reasonable or probable cause whatsoever for
a long space of time and against the
will of plaintiffs.

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**Page 5** (6871_005.jpg)
Plaintiff further aver that before and
at the time of committing the grievances[?]
complained of they were and
still[?] are free persons[?], and that
the defendants held[?] and still[?] hold
them in slavery
They therefore ask that the defendants
be compelled[?] to answer the allegations
of this petition as specifically[?] as[?] if they
were[?] here again[?] repeated by way[?] of
interogatory, and that upon a formal[?]
hearing of this case[?] judgment of freedom may be
awarded[?] to your petitioners[?] (the
plaintiffs) and damages to the amount
of five Hundred Dollar for which
they ask judgment.

Blackburn & McLean
Attys

> *Legal Function: Affidavit*

Jordan W Early (prochain amy) for Priscilla
Williams and Ella Williams minors and
agent for Hester Williams makes oath &
says that he believes the matters & things
stated in the foregoing petition as stated
are true

J W Early

Sworn to & subscribed
before me this 17th Oct
1853
M S Cerre clk

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**Page 6** (6872_006.jpg)
> *Legal Function: Caption*

St. Louis Circuit Court

Hester Williams
Priscilla Williams
by her next friend
J. W. Early and Ella Williams
by her next friend J. W. Early
vs
Frederick Norcum
A. B. McAfee

Petition on trespass
for Freedom
B. McLean
Attys

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**Page 7** (6871_007.jpg)
> *Legal Function: Petition for Appointment of Next Friend*

To the Clerk of the Circuit Court
The petition of Priscilla
and Mary Ella Williams children of Hester Williams
ask the appointment of Jordan W Early as
their next friend to enable them to bring a suit
for their freedomagainst Frederick Norcum
and A. B. Macaffe[?].

Priscilla Williams
Mary Ellen Williams

> *Legal Function: Affidavit*

I consent to act as next friend for
Priscilla Williams and Mary Ella
Williams minors in suit about to
be instituted by them for freedom
against Norcum & Macaffe[?]

St. Louis Oct 11th 1853
J W Early
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**Page 8** (6872_008.jpg)
> *Legal Function: Order*

I approve the within and appoint Jordan W Early,
as next friend to sue for the plaintiffs in
said case

*M S Cerre Clerk.*

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**Page 9** (6871_009.jpg)
> *Legal Function: Summons of A. B. McAfee, Frederick Norcum, Glenville C. Blakey, and William E. Moore*

County of St. Louis , Ss.
The State of Missouri , To the Sheriff of St. Louis County, Greeting:
We command you to summon A B McAfee[?] and Frederick
Norcum Glenville Blakey and William E Moore
to appear
before the Judge of our Circuit Court , on the first day of the next term
thereof, to be held in the City of St. Louis , within and for the
County of St. Louis , on the third Monday of November
next: then and there to answer the complaint of Hester Williams
Priscilla Williams and Ella Williams by their next friend
Jordan M Early
as set forth in the annexed petition
and have you then and there this writ.

*Witness, Michael S. Cerre , Clerk of said Court,
with the Seal thereof hereto affixed, at office in the
City of St. Louis , this eleventh day
of October in the year of our Lord
eighteen hundred and fifty three M S Cerre Clerk.*
> *Legal Function: Acknowledgement*

I acknowledge myself bound for all costs that may accrue in the above cause.
Witness, my hand and seal, at St. Louis , this 11th day
of October 1853

*J W Early L.S.*

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**Page 10** (6872_010.jpg)
> *Legal Function: Order*

On reading & considering the within petition it is ordered
that said petitioners be allowed to sue on and giving Se-
curity satisfactory to the Clerk for all costs that may be
adjudged against petitioners, and it is further ordered
that said petitioners have reasonable liberty, to attend Counsel
and the Court as occasion may require that they be not removed out[?]
of the jurisdiction of the Court and they be not subject to any severity
on account of their application for freedom

A True Copy attest A. Hamilton Judge 8th Jud. Cir MO
M. S . Cerre Clk.

> *Legal Function: Caption*

No. 119 St. Louis Circuit Court
November Term 1853
Hester Williams , Ella
Williams Priscilla Williams
by their next friend Jordan W Early
vs
A B McAfee and
G. C. Blakey
Fred. Norcum
William Moore
Pet for freedom
McLean

*Issued Oct 11th 1853 Md Cerre Jury[?] fee & writ[?] \$3. his by J M Early
Copy [illegible] \$1.50*
> *Legal Function: Certificate of Execution*

Executed this writ in the County of
St. Louis on the 12th day of Oct. 1853 by
leaving a certified copy of the writ & petition
at the usual place of abode of A. B. McAfee
with a white person a member of his family
over the age of fifteen years - also by leaving
a copy of the within writ, at the usual place
of abode of Granville Blakey, with a white
person a member of the family, over the age
of fifteen years - Frederick Norcum not
found in my county.

Jn M. Wimer
by Jm C Blakey dept
Service 2.00 Non est 50 $ 2.50

> *Legal Function: Certificate of Execution, part 2*

Executed this writ further in the county of St. Louis on the
12th day of Oct. 1853. by delivering a certified copy of the within
writ to Wm E. Moore & by offering to read the within petition to him
which he refuses to hear[?] fee[?] \$1.00[?] Jn M[?] Wimer[?] Shff

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**Page 11** (6871_011.jpg)
> *Legal Function: Defendant's Plea of Not Guilty*

State of Mo
County of St Louis In the St Louis
Circuit Court - Nov Term 1834
Hester[?] Williams & others.
vs
Frederick Norcum &c
Declaration under statute
for freedom
Defendant for plea to the amended declaration
filed in the above case on 20th November 1834, says,
that he is not guilty of the trespass[?] and imprisonment
as charged in the said declaration; and defendant
denies[?] that plaintiffs were ever or are now free
persons, and of these[?] things he puts himself
upon the County

*Willis[?] L Williams
Atty[?] for Deft[?]*

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**Page 12** (6872_012.jpg)
> *Legal Function: Caption*

No 119 In the St St. Louis Circuit Court
Hester[?] Williams & others
vs
Frederick Norcum[?]
Answer of defendant to amended[?]
declaration filed 20th Nov 1834.
Plea not guilty & that
plaintiff not free

*Filed November 24, 1854 Wm[?] J Hammond Clk[?] Williams p.d*

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**Page 12** (6871_013.jpg)
> *Legal Function: Defendant's Motion to Strike*

In the St St. Louis Circuit Court .
November Term 1854
Hester Williams & others
vs
[illegible]
Frederick Norcum[?]
1st. Defendant moves to strike[?] from the record,[?],
the paper marked "filed Nov. 20th 1854.," for
the reason
1. That said paper is not filed in accordance[?]
with, but directly[?] in derogation[?] of the rule of
this court.
2. The said paper is not an amendment of
the original[?] petition, nor is it a petition itself,
for freedom, as the suit purports[?] to be.
3. The said paper is not an[?] frivolous[?]
and of no sort of application to the matters
in issue.
2. Defendant asks[?] the court to make an order that
the Sheriff deliver the plaintiffs to the defendant
Norcom[?] or his agent, to be dealt[?] with as his slaves[?]

Willis L Williams p.d.

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**Page 13** (6872_014.jpg)
> *Legal Function: Caption*

Hester Williams & others
vs
Frederick Norcom
Motion to strike paper
marked "filed Nov. 20 1854"
from record - and
for final order in the
case.

Filed November 24, 1854
Wm J.Hammond Att

Williams p.d.
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**Page 15** (6872_015.jpg)
> *Legal Function: Plaintiffs' Petition for Leave to Sue*

Court House Papers
St. Louis To the Judge[?] of the St. Louis Circuit Court
of the County of St. Louis and State of
Missouri
The petition of Hester[?] Williams[?]
humbly represents, that in January[?] D
1849 she known[?] by the name of H Esther was the slave for life of F
Norcum[?] and also has two children[?] one
a girl[?] aged[?] now[?] five years named Mary
Ella and the other afore[?] named Priscilla
aged[?] nine years. And that at said[?] time
her[?] then Master F Norcum, set her free
by granting to her and her two children[?]
a deed[?] of Emancipation, and your
petitioner represents that said [illegible]
as she was informed and [illegible]
has a force[?] once free discharged[?] from ser-
vice of herself and her the children[?]
and[?] your petitioners further charges[?] that
she retained said deed[?] of Emancipation
in her possession[?] from the day of its[?]
Execution some time in January 1849
up and untill on or about the seventh[?]
of October AD 1853 when she at the request[?]
of the said Norcom[?] [illegible] him the deed
to have the same recorded as he[?] was[?]
informed that some further act[?] had
to be done[?] by the said Norcom[?], before the
said paper could be recorded, and
your petitioner states that said Norcom[?]
told[?] her[?] to come back[?] on the next morn
ing & he would give her the said papers
properly[?] recorded[?] and certified, and
petitioner states that when[?] she[?] came

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**Page 16** (6872_016.jpg)
to[?] the said[?] Norcom[?] for said paper that she
was informed that she was together with[?] her
two[?] children[?] sold by the said Norcum[?] to
one[?] A. B. Macafee[?] a negro[?] trader[?]
by whom she was taken[?] possession of
and is now confined in his negro yard[?]
in[?] the city of St. Louis , and is informed
and verily[?] believes[?] that the said Macafee[?]
[illegible] intends[?] forthwith to remove[?] her
without the[?] limits[?] of this state[?], and
jurisdiction[?] of this court
Your petitioner further states[?] that in
October 1849 and after the execution
of the deed of[?] Emancipation she was [illegible]
as a runaway[?], and F Norcum[?] then who
was in the city[?] of New York sent to her
to procure her released[?] the certificate
hereunto[?] attached[?] & made[?] a part of this
petition
And your petitioner prays that
an order may be permited by your Honor[?]
to allow[?] her to[?] sue[?] as a poor person
she having [illegible] [illegible] means[?] &[?]
that your Honor[?] will also permit[?] an
order that she may have reasonable
liberty[?] to attend[?] her counsel and the
the Court[?] as [illegible] may require[?]
and that a warrant[?] may issue for
your petitioner [illegible] the [illegible] and
that she may have such relief[?] as well[?]
as the law[?] provides[?] and the necessity[?]
of the case [illegible].

*Hester[?] Williams[?] by Blackburn[?] & McLean[?] her[?] attys.*

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**Page 17** (6872_017.jpg)
> *Legal Function: Affidavit*

Milton[?] N. McLean being duly[?] sworn saith
that he nelieves[?] the matters & things set
forth in the foregoing petition are true
and there makes an order is granted by the
Circuit Court that said[?] Hester[?] and her
two children[?] Ella & Priscilla Martha
command one of the presentence of the
Court
Sworn to[?] & subscribed[?]
before me this[?] 11th
Oct 1853

*M. S. Cerre Clk M. N. McLean*

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**Page 18** (6872_018.jpg)
> *Legal Function: Order*

On reading and considering
the within petition it is ordered that the said
petitioners be allowed to sue on giving security
[illegible] to the clerk[?] for all costs that may
be [illegible] payment petitioners
And it is further ordered[?]
that said petitioner has reasonable[?] liberty
to attend counsel and the Court as [illegible]
may require[?]. That they be not removed[?]
out of the jurisdiction[?] of the court, and
that they be not subject[?]to any[?] severity[?]
on account of their application[?] for
freedom
St Louis Oct 11th [illegible]

*A. Hamilton [illegible] Jug o[?] 8th Judicial[?] Cir. Mo[?]*
> *Legal Function: Caption*

75
Petiton of Hester[?]
Williams[?] Known[?] as
Hester[?] and Ella
& Priscilla[?]

*Filed October 11th 1853 M. S. Cerre Clk*
Nov. Term 1853. Demurrer to petition filed. 24 p 82. Demurrer[?] sustd[?]
leave to amend[?] on or before the first day of next term[?] 24 p 114. April 2 1854
Declaration under the statute filed. 24 p 128. Cont by Consent 4 p 142
Motion to strike[?] out paper filed & sustained[?] & motion for final order filed & overruled[?] Leave[?] to
to amend on or before the first day of next term[?] 24 p 298. November Term 1854
Amended Declaration filed 24 p 319. Motion to strike[?] out filed
and orvrd with leave[?] to plead. plea filed 24 p 342 contd[?] as on
affidavit[?] of pltf[?] to procure[?] testimony of Fred[?] Norcum 24 p 484. Dedimus[?] to New York . by plaintiff 24 p 497. Oct. 5[?] '55[?] Contd[?] 25 p[?] 206. March 3 '56. April
17. [illegible] & Judgt of freedom plaintiff to pay costs[?] 25 p 372.

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**Page 19** (6872_019.jpg)
> *Legal Function: Affidavit of Milton M. McLean and Motion to Amend Petition*

Court House Papers
St. Louis State of Missouri
County of St. Louis The State of Missouri
M. N. McLean having sworn saith[?] that
Hester[?] Williams and her two children Priscilla[?]
& Ella are in the [illegible] custody[?] of one
Edmond[?] Loyden[?] who he maintains[?] &
believes[?] is the against of A. B. Mc[?] Affe[?] and
Granville & Blakey[?] partners[?] trading in
negros[?] in the city of St. Louis and who has
the[?] said negros[?] in change at the instance
of Frederick[?] Norcum[?]
sworn to &[?] subscribed[?]
before[?] me[?] this 12 Oct
1853.

*B J[?] Hammond Clk[?] M. N. McLean*
> *Legal Function: Motion*

To the Circuit Court of St. Louis
County
M. N. McLean moves[?] to
amend[?] the petition for [illegible] to same[?]
filed[?] on behalf[?]of Hester Williams[?]
& her[?] children[?] against Frederick[?]
Norcum[?] and A B McAfee[?] by[?] adding[?]
thereto[?] the names of Granville[?] C
Blakey[?] & Edmond Loyden[?] the
said Loyden[?] [illegible] being the agent[?] of
McAfee[?] & Blakey[?]

*St. Louis Oct 12 1853 Blackburn[?] & McLean
Attys*

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**Page 20** (6872_020.jpg)

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**Page 21** (6872_021.jpg)
> *Legal Function: Warrant for Hester Williams, Mary Ella Williams, and Priscilla Williams*

State of Missouri
County of St Louis The State of Missouri to the
Sheriff of the County of St Louis Greeting
You are hereby commanded
to seize Hester[?]. Ella & Priscilla known as[?] Hester Williams & her[?] two[?] children[?]
where ever they may
be found and bring them before me at the Court
House in the room of the Circuit Court at the Court House on the 12th
day of Oct 1853 at 9 O'clock [illegible] and to summon
A[?] B McAfee in whose possession they now are to
appear at the same time and place
Given under my hand this 11th
day of October 1853

*A Hamilton Judge 8th Judi-
cial Cir. Mo.*

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**Page 22** (6872_022.jpg)
> *Legal Function: Certificate of Execution*

Executed the within order from the
Honr. Alex Hamilton, by having the within
named parties in court on the 12th day of
October 1853.
AB. Mc.Afee not found.
Fee \$3.00
non est[?] 0.50
\$3.50

*Jn. M Wimer
Shff*

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**Page 23** (6872_023.jpg)
> *Legal Function: Warrant for Hester William, Mary Ella Williams, and Priscilla Willians*

[illegible] State of Missouri
County of St. Louis
Sheriff of St. Louis County To the State of Missouri to the
Greeting
You are hereby Commanded to seize[?]
Hester[?] Ella & Priscilla[?] known as Hester Williams & her
two children where ever they may be found, and bring
them before me at the Court House in the Room of the Criminal Court at the Court house. on the 13th
day of Oct 1853 at 9 O. Clock A. M. and to sieze[?]
[illegible] [illegible] msr A. B. McAfee Granville C. Blakey and Edmond Loyden
Wim C Moore in whose possession they now are to appear at the same
time and place
Given under my[?] hand this 12th
day of October 1853.

*Courthose[?] [illegible] Papers
St. Louis A Hamilton[?]
Jud[?] 8th Ju-
dicial Cir[?]. Mo[?]*

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**Page 24** (6872_024.jpg)
> *Legal Function: Certificate of Execution*

Executed the within order on the 13th of October
1853, by having, Hester , Ella and Priscilla before
the Hon[?] Alex Hamilton, & by summoning Wm[?]
E. Moore to appear in court[?] at 9. 0'clock a.m on this
day- A. B. McAfee. Granville C[?] Blakey &
Edward Loyden not found.
Fee $ 4.00
[illegible] 1.50
# 5.50

*[illegible]. M [illegible]
Shrff*

---

**Page 25** (6872_025.jpg)
> *Legal Function: Defendant's Demurrer to Plaintiff's Petition*

In this circuit court
Novr. Term 1853
Hester[?] Williams
Priscilla Williams &
Ella Williams
against[?]
[illegible] [illegible] [illegible]
Defendant Norcom[?] by[?] his[?] attorney[?] comes[?] and
demurrs[?] to the[?] Plaintiffs' petition[?] filed in the
above[?] entitled[?] cause[?] [illegible] [illegible] that the
facts alleged as stated in said[?] petition[?] are[?]
not sufficient to entitle in behalf[?] authorize
the judgement[?] asked for by the Petitioners

*Willis L Williams[?] pd[?] Court House Papers
St. Louis*

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**Page 26** (6872_026.jpg)
> *Legal Function: Caption*

Hester[?] Williams & others[?]
vs
Frederick[?] Norcum & others[?]
Demurrer[?] to
Plffs petition

*Filed, February 24, 1854 Wm J. Hammond Clk[?]*

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**Page 27** (6872_027.jpg)
> *Legal Function: Plaintiffs' Complaint*

Court House Papers
St. Louis State of Missouri
County of St. Louis St. Louis Circuit
Court
November Term
1854
Ella[?] Williams[?] and
Priscilla Williams by them[?]
next [illegible] for [illegible] [illegible] Early
and Hester[?] Williams Plaintiffs
vs
Frederick[?] Norcum[?]
Granville Blakey[?]
A B McAfee[?] and
William[?] E Moore[?]
Declaration
under[?] the
statute[?] for
Freedom
Ella Williams and Priscilla Williams
minors[?] by their next friend[?] Jordan M[?]
Early[?] and Hester Williams complains
of the above named defendants of a
plea wherefore the said defendants
with[?] force[?] and arms[?] made[?] an assault
upon the said plaintiffs viz on the
seventh[?] of[?] October AD 1853 at St. Louis
on the county and State aforesaid
the said[?] and then & there beat, bruised[?]
& ill treated[?] them & each[?] of them[?] and
then & there imprisoned them & kept &
detained them in prison without[?] any
reasonable[?] or probable cause, whatsoever
for a long[?] time[?] to wit[?] for the space of
ten[?] hours then next following contrary
to the laws & customs of this state the
said plaintiffs then & there being free
and being free for a long[?] space of time
previous[?] thereto viz[?] for the period[?] of
one year, and still being free persons

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**Page 28** (6872_028.jpg)
tho[?] the said defendants held and still hold
plaintiffs in slavery.
And other[?] wrongs[?] to the said plaintiffs then
& there did to the great[?] damage of the
said plaintiffs and against[?] the peace[?]
Wherefore[?] the said plaintiffs say they
have[?] sustained[?] damages[?] in the sum[?]
of one thousand dollars & therefore[?]
they sue

*by Blackburn[?] & McLean
P attys[?]*

---

**Page 29** (6872_029.jpg)
> *Legal Function: Caption*

75
Circuit Court
Hester Williams
& others
vs
Frederick[?] Norcum[?]
& others
Declaration
under[?] the[?]
statute

*B. & McLean[?]
Attys[?]
Filed April 17, 1854 Wm. J. Hammond Clk[?]*

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**Page 30** (6872_030.jpg)

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**Page 31** (6872_031.jpg)
> *Legal Function: Defendant's Motion to Strike Complaint*

Court House Papers
St. Louis In the St. Louis Circuit Court April Term A D 1854
Hester Williams & others[?]
vs
A. B. McAfee
Frederick Norcum &[?] others
1 The defendants move to strike from the record
the paper marked as “filed April 17th 1854” for
the reasons
1. That said paper is not filed in accordance with,
but directly[?] in derogation[?] of the rules of this
Court.
2. The said paper is frivolous[?] and of no sort
of application to the matters[?] in issue.
3. The said paper is not an amendment of the
original petition, nor is it a petition itself
for freedom, as the suit pretends[?] to be.
2[?] Defendants ask the Court to make an order[?]
that the Sheriff deliver the plaintiffs to the
defendant Norcom or his agent, to be
dealt with as his slaves[?] &c.

*Willis[?] [illegible] L. Williams
Atty[?] for Defendants*

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**Page 32** (6872_032.jpg)
> *Legal Function: Caption*

No. [illegible] 119
Hester Williams & others[?]
Vs[?]
A. B. [illegible] McAfee[?].
Motion to strike[?] paper
from the record & for
said order.
Williams[?] Atty pd[?]

*Filed June 27, 1854 Hammond Clk[?] 57[?] 75*

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**Page 33** (6872_033.jpg)
> *Legal Function: Plaintiff's Amended Complaint*

Court House Papers
St. Louis State of Missouri
County of St. Louis Circuit Court of
St. Louis County
April Term 1854
Amended[?] Declaration
Ella Williams[?], Priscilla Williams by
Jordan[?] M .[?] Early their next friend[?] and
Hester[?] Williams[?] persons[?] of color complains
of Frederick[?] Norcum[?] of a plea. For that
the said defendant on the day of
AD 1854 with force and arms[?] &c made an
assault upon the said plaintiffs to wit[?]
at St. Louis in the county aforesaid &
then & there beat, bruised[?] & ill treated[?]
them[?] & each[?] of them the said[?] plaintiffs
& then & there imprisoned them & & each[?] of
them[?] the said plaintiffs & kept &[?] detained[?]
them & each of them in prison there
without[?] any reasonable or probable
cause whatsoever for a long[?] time viz[?]
for the space of twelve[?] hours[?] then next
following[?] contrary[?] to the laws[?] of the said[?]
State and the will[?] of the said[?] plaintiffs
And[?] the said plaintiff avers[?] that
before and at the time of the committing[?]
of the said grievances they were[?] each
one of them and still are free[?] persins[?]
&[?] that the said defendant held & still
holds[?] them in slavery to the plaintiffs
damages[?] damages[?] in the sum of ten
dollars & therefore they[?] pray[?]

*by Blackburn &[?] McLean[?]
Plff Attys*

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**Page 34** (6872_034.jpg)
> *Legal Function: Caption*

75 Circuit Court
Ella[?] Williams[?] &
Priscilla[?] Williams[?]
by[?] their next[?] friend[?]
Jordan[?] M[?] Early[?]
& Hester[?] Williams[?] vs
Frederick Norcum[?]
Amended[?]
Declaration

*B & McLean[?]
Attys Filed Nov. 20th 1854 Wm. J. Hammond clk*

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**Page 35** (6872_035.jpg)
> *Legal Function: Subpoena of Samuel Glover, Thomas Harvey, Phillip C. Morehead, and John C. Richardson*

Court House Papers
St. Louis. County of St. Louis , Ss.
The State of Missouri , To Saml Glover Thos Harvey Phillip C Morehead[?]
John[?] C. Richardson[?] Greeting.
You are hereby Commanded, that, setting aside all manner of excuse and delay.
you appear before our Circuit Court for the County aforesaid, on the 13th
July 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 Williams is
plaintiff and McAfee &[?] Norcum[?] is
defendant on the part of Plaintiff
and herein you are in no wise to fail.

*Witness, William J. Hammond , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in
the City of St. Louis , this 8th
day of July in the year of our Lord
one thousand eight hundred and fifty-five Wm J. Hammond Clerk C. C.*

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**Page 36** (6872_036.jpg)
> *Legal Function: Caption*

Circuit Court 75
Williams
vs
McAfee &[?]
Norcum[?]
Spa[?] for[?]
Saml[?] Glover Esq[?]

*Thos Harvey Esq[?] John C. Richardson Phillip C. Morehead[?] [illegible]*
> *Legal Function: Certificate of Execution*

Executed by reading to J. C. Richardson &
P. C. Morehead[?], in St Louis County February
12/55 S. Glover & Thos Harvey not found.
Fee \$120

*Turner[?] Maddox[?] shff By Chas Picker[?] Dpty*

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**Page 37** (6872_037.jpg)
> *Legal Function: Subpoena of Thomas Harvey*

Court House Papers
St. Louis County of St. Louis , Ss.
The State of Missouri , To Thomas[?] Harvey[?]
Greeting:
You are hereby Commanded, that, setting aside all manner of execuse and delay,
you appear before our Circuit Court for the County aforesaid, on the[?]
ever [illegible] at the City of St. Louis , then and there
to testify, and the truth to [illegible] in a certain matter of controversy now pending in our
said Court, wherein Hester[?] Williams et al[?] are
plaintiff and Fr.[?] Norcum[?] and others
defendant on the part of[?] Plaintiffs:
and herein you are in no wise to fail

*Witness, William J. Hammond , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in
the City of St. Louis , this 12th,
day of Feby in the year of our Lord
one thousand eight hundred and fifty-five Wm J. Hammond Clerk C. C.*

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**Page 38** (6872_038.jpg)
> *Legal Function: Caption*

75
Hester Williams
vs McAfee et al[?]
Thos Henry
pltff[?]
[illegible]
> *Legal Function: Certificate of Execution*

Thos Henry the within named not
found. Feb 12th 1855
Fee 10 cts

*Turner Maddox shff By J. B. Hegdon[?] Dpty*

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**Page 39** (6872_039.jpg)
> *Legal Function: Subpoena of Cicero S. Hawks, William DeWitt, William Smith, B. M. Lynch, and Thomas S. Harvey*

Part House Papers
St. Louis County of St. Louis , Ss.
The State of Missouri , To Cicero[?] S. Hawks, William DeWitt[?] William Smith
& B. M. Lynch & Thomas S. Harvey Greeting:
You are hereby Commanded, that, setting aside all manner of excuse and delay, you appear
before our Circuit Court for the County aforesaid, on the 17th day of April
1856 at the City of St. Louis , then and there to testify,
and the truth to say in a certain matter of controvery now pending in our said Court, wherein
Hester[?] Williams et al. by next friend &c are
plaintiffs and McAfee & others[?] are
defendantss on the part of said[?] plaintiffs
and herein you are in no wise to fail.

*Witness, William J. Hammond , Clerk of our said
Court, with the seal thereof hereto affixed, at office,
in the City of St. Louis , this 15th
day of April in the year of our Lord
one thousand eight hundred and fifty-six Wm J Hammond Clerk C. C.*

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**Page 40** (6872_040.jpg)
> *Legal Function: Certificate of Execution*

De Witt &[?] Smith not found
Executed as to others within name[?]
April 17/56
Fee \$120

*Turner[?] Maddox Shff[?] By Chas Picker[?] Depy*
> *Legal Function: Caption*

75 (119 17 act. Nov. T. 53)
57 Trials[?] Mar. T/56
In Circuit Court
(for April 17th)
Subp'a for Plffs
Hester[?] Williams
vs McAfee[?] &c
Bishop[?] C. S. Hawks
Wm De Smith (on B.T. "Tropic")
Wm Smith (8th bet.[?] [illegible] & Elm)
B. M. Lynch (Locust bet.[?] 4th & 5th)

*Thos S. Harbey [illegible]*

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**Page 41** (6872_041.jpg)
Court House Papers
St. Louis
Upon the evidence[?] in this case[?]
plaintiff is not entitled to recover
[illegible]

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**Page 42** (6872_042.jpg)

Hester Williams, Priscilla Williams, and Mary Ella Williams, by and through Their Next Friend, Jordan M. Early V. Frederick Norcum, Et Al. 1853, St. Louis Circuit Court Historical Records Project, accessed October 9, 2026, https://digitalexhibits.library.washu.edu/s/ccr/item/60969