Sample Trespass 2

Lucy a woman of color vs. William Graves
Circuit Court Case File 3000
Trespass 1822
St. Clair County, Illinois

Transcription. File Jacket indicates this case is recorded in Record Book D: 20, 26
Paper case file located at the Illinois State Archives, Springfield

Words in [square brackets] are additions or guesses by the transcriber.

[Document 1 – Summons]

“State of Illinois, SS.

The People of the State of Illinois
To the Sheriff of St. Clair County, Greeting.

We command you, that you summon William Graves late of our said county, if he may be found in your bailiwick, so that he be and appear before the Judge of our Circuit Court, next to be holden at Belleville, within and for our said county, on the fourth Monday of March next; then and there to answer unto Lucy Ann a free girl of colour an infant under the age of twenty one years by her next friend Nelson Pendleton a free man of Colour of a plea trespass [-?-]armis and false imprisonment to the damage of the said Lucey Ann a free girl of colour &c the sum of six hundred dollars, before us to be exhibited, and have you then there this writ.

Witness John Hay Clerk of our said Court at Belleville this sixth day of February
in the year of our Lord one thousand eight hundred and twenty two and
of the Independence of the United States the forty Sixth.
John Hay C.C.C.St.C.”

[reverse side Document 1]

I duly Executed this writ on the within named William Graves on the 11th day of February 1822 by reading the same to him on the day above set out~

Serving S— .50
Retg———- .9
[Total]— $.59

William A Beaird Sheriff of St Clair County”

D^m [Damages] $600.00

Ret^ble March Term 1822

This is an action of trespass force & armis and false imprisonment

Lucey Ann a free girl of Colour &c &c
[P.] Shff

[Document 2 – Declaration – side 1 of 3]

“State of Illinois} March Term 1822
St Clair County }
Circuit Court

To witt: Lucy Ann an infant of colour under the age of twenty one years of by her next friend Nelson Pendleton A free man of Colour ~ Complains of William Graves of A Plea of trespass force & arms ~ For that the said defendant on the first day of January in the year of our Lord one thousand eight hundred and twenty with force and arms in the County aforesaid and within the jurisdiction of this Court made an assault upon the said Plaintiff and the said defendant did then and there with fists blows Sticks &c beat bruise & illy treat the said Plaintiff so that her Life was greately despaired of and then and their [sic] imprisoned the said Plaintiff and kept & detained her in Prison there without any Probable or just cause whatever for A long Space of time to wit: from the said first day of January in they year of our Lord one thousand eight Hundred & twenty ~until the first day of January in the year of our Lord one thousand eight Hundred & twenty two and he did then and there during all the time aforesaid with force & armes keep & detain her the said Plaintiff and compeled & forced her to do & Perform the work labour & buisiness of him the said defendant for the full space of time aforesaid to wit: for the space of two years Contrary to the Laws and

[side 2 of 3]
Customs of the People of the state of Illinois and against the will of her the said Plaintiff whereby she the said Plaintiff was then & there not only greatly hurt bruised & wounded but was also thereby then & there greatly exposed & injured in her credit & circumstances And also for that the said defendant afterwards to wit: on the said first day of January in the year of our Lord one thousand eight Hundred & twenty in the County aforesaid with force & armes another assault with fists, clubs &c did make on the said Plaintiff & then & there beat bruised & ill=treated her the said Plaintiff and then & there and on divers other days & times imprisoned her the said Plaintiff & kept & detained her in Prison there without any reasonable or Probably cause whatever for A long space of time to wit: for the space of two years then next folowing the said first day of January in the year of our lord one thousand eight hundred & twenty and the said defendant did then & there during all the time aforesaid with force & arms force & compell the said Plaintiff to do & Perform as the servant of said defendant the labour work & buiseness of the said defendant ~ Contrary to the laws & Customs of the People of the State of Illinois and against the will of her the said Plaintiff and to the damage of her the said Plaintiff of $600.00 six hundred dollars and therefore she brings Suit &c

Lucy Ann by Nelson Pendleton her next friend X his mark

[side 3 of 3]

filed 14^th of March 1822″