To the Hon John W Colvin Law Commissioner Court of Saint Louis County ~
The petition of William Blackburn Sarah Broadwater
showeth, that William Blackburn he is now a prisoner restrained of his
liberty in the custody of the County Jailor of the
County of Saint Louis in the State of Missouri, upon
the charge or accusation of being a run away slave
or fugitive from service and that such imprisonment and restraint is within the common Jail
of the said County of Saint Louis and the name of
the said Jailor is James A Felps as your petitioner
is informed and verily believes.
Your petitioner further showeth that said Blackburn he is not
imprisoned or restrained of his liberty, upon any
charge, for any reason, or upon any account which
prevents him from applying for and obtaining the
benefit of the writ of Habeas Corpus, as she is informed & verily believes, in or for any cause or reason
specified in the sixth section of the said article
of chapter seventy five of the statutes of the State
of Missouri of 1845, Entitled an act regulating
proceedings on writs of Habeas Corpus.
Your petitioner further showeth that the
annexed paper marked A, is a true copy
of the Process by which he said Blackburn is claimed to be
held in such restraint & confinement as she is
informed & verily believes.
Your petitioner further showeth, that said Blackburn he was
merely arrested & imprisoned upon suspicion of being
a run away slave, and that no person can or
does, to his knowledge or belief claim service from
him, or claim him as a slave, and that he is
not a Slave, but is a free man and entitled
as such to his freedom as she verily believes and that such restraint & imprisonment is illegal, and that such
illegality consists in imprisoning him as a run
away Slave, where in such & in fact he is not
a Slave or a run away Slave but is a free man
and she makes this Petition for and on the behalf of said William Blackburn who is a son in law of petitioner
Therefore your petitioner prays to that said William Blackburn be discharged
from such imprisonment, on your honor being satisfied of the
fact that he is not a run away Slave & is entitled to his freedom, and for the purpose of
determining that question that a writ of Habeas
Corpus may issue to bring him before your Honor
and she prays for such Habeas Corpus accordingly.
Sarah Broadwater her X mark
Filed 11th April 1855 John W. Colvin
