United States of America,
Circuit Court of the United States for the Seventh Circuit and District of Michigan

On the tenth day of February in the year of Our Lord One thousand Eight hundred and forty nine

DISTRICT OF Michigan

Milton W. Graves Plaintiff in this suit, and who is a citizen of the State of Kentucky, by Pratt L. Crary his Attorney comes into Court, and complains of Stephen Bogue Defendants in this same suit, who is citizen of the State of Michigan, by filing and service of declaration pursuant to the rules of practice of this Court.

For that whereas heretofore, to wit, on the 24th day of April in the year of our Lord one thousand eight hundred and forty seven the said plaintiff, being a citizens of the said State of Kentucky, where slavery is tolerated and established, owned and had in his custody and under his control, in the said State of Kentucky, one person whom he the said plaintiff lawfully held to labor, commonly called an African slave, viz: Perry and in whose labor and service he the said plaintiff had, under the Constitution and Laws of the United States and the Constitution and Laws of the said State of Kentucky, the sole right and interest, to wit, at Kenton county in the said State of Kentucky; which said persons so held to labor by the said plaintiff as aforesaid, afterwards, to wit, on the 24th day of April in the year last aforesaid, without the license or consent of the said plaintiff did depart and escape from his the said plaintiff and from his the said plaintiff's labor and service and from the said State of Kentucky into the county of Cass and state of Michigan where they the said persons so held to labor as aforesaid and by reason of absconding as aforesaid, became and were fugitives from said labor and service, to wit, on the twentieth day of August in the year of our lord 1847 at the County of Cass aforesaid. And whereas also the said plaintiff afterwards, to wit, on the day and year last aforesaid, pursued the said fugitives from labor, so escaping from the plaintiff as aforesaid, to the said County of Cass where the said plaintiff did then and there, to wit, on the day and year last aforesaid reclaim and arrest the said fugitives from labor for the purpose of taking them before a magistrate of the said county of Cass and where said arrest was so made in order to make the necessary proof of said persons so arrested being such fugitives from labor as aforesaid and for the purpose of obtaining from such magistrate his official certificate for removing said fugitives from labor back to the said plaintiff in the said state of Kentucky from whose service and custody they unlawfully fled and escaped as aforesaid; such magistrate having under the constitution and laws of the United States competent power and authority to hear such proofs and make and deliver to the said agents of the said plaintiff such official certificate; whereupon and after the said fugitives from labor had been so proclaimed and arrested as aforesaid, they the said defendants, on the same day and year last aforesaid, at the County of Cass aforesaid, rescued them the said fugitives from labor so reclaimed and arrested as aforesaid, contrary to the provision of the statue of the United States in such case made and provided, and afterwards, to wit, on the same day and year last aforesaid aided and assisted them the said fugitives from labor in making their escaped to some place out of the possession and beyond the reach of the said plaintiff. Whereby and by means of the premises the said plaintiff was prevented from returning the said fugitives from labor to his own service again in the said State of Kentucky as he had the right to do, and as he otherwise would have done. Whereby also and by means of the premises aforesaid the said plaintiff hath lost the said fugitives so to him lawfully held to labor and service as aforesaid, and hath been and is by reason thereof entirely deprived of the labor and services of the said fugitives, which labor and service would have been and was to him the said plaintiff, of great value, to wit, of the value of six hundred dollars. . . .

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Updated 04/26/2007

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