- Madison County, Alabama. April 21, 1853. - January 30, 1854.
- Court: Chancery
- Salutation: To the Honorable E. D. Townes Chancellor of the Northern Chancery Division of the State of Alabama presiding for the 29th District at Huntsville
In 1839 or 1840, slave owner Elizabeth Jones, of Coffee County, Tennessee, asked her nephew Samuel G. Berry, of Jackson County, Alabama, to become her "agent and advisor" as she was "unlearned, being unable to write or to read writing, unacquainted with figures." In 1840, she sent two of her slaves to work on his farm, and in 1843, she moved to Alabama with the remainder of her slaves, including Nancy, a gift from her father, and Nancy's children. At first she lived in Berry's house, but after eight months, she was asked to move into a nearby cabin. She later sold a slave named Pleasant to William Berry, Samuel's father, and sold a slave named Henderson to Samuel himself. Elizabeth describes Samuel's power over her as "absolute," almost the same "as that of a Master over his slaves" causing her to permit him to use her slaves as laborers on his farm and as hired hands. She contends that, over the years, Samuel grew "cold and morose" towards her. When she attempted to take over the management of her slaves, he implied that the slaves were actually his during her lifetime, by virtue of a document signed by her in 1843; a document she does not remember having ever signed or remembers as being something different that what it is now being purported to be. Elizabeth brings suit against Samuel. She seeks an injunction to restrain him from removing the slaves from the county and asks that he give an account of how he had profited from the use of her slaves.
- Number of petition pages: 7
- Related documents: Affidavit, Elizabeth Jones, 11 April 1853; Bond, 18 April 1853; Exhibit A-Correspondence, Samuel G. Berry to Reverend John Langford, 26 January 1853; Exhibit B-Copy of Indenture, 25 May 1843; Exhibit C- Debt Schedule, Elizabeth Jones to Samuel G. Berry, 4 June 1847; Bond, 21 April 1853; Appointment of Power of Attorney, 11 April 1853; Injunction, 21 April 1853; Summons, Samuel G. Berry, 21 April 1853; Answer of Samuel G. Berry, 22 July 1853; Exhibit E-Appointment of Power of Attorney and Certification, 25 February 1841; Exhibit F-Correspondence, Elizabeth Jones to "Dear Cousin," 14 December 1841; Exhibit G-Indenture and Certification of Filing, 25 May 1843; Exhibit H-Correspondence, Elizabeth Berry or Jones to S. G. Berry, 1 May 1842; Exhibit I-Bill of Sale, Elizabeth Jones to Samuel G. Berry, 17 May 1843; Exhibit K-Bill of Sale, Elizabeth Jones to William Berry, 25 May 1843; Exhibit L-Promissory Note, Elizabeth Jones to Samuel G. Berry, 10 January 1845; Exhibit M-Promissory Note, Elizabeth Jones to Samuel G. Berry, 3 June 1847; Exhibit N-Debt Schedule, Elizabeth Jones to Samuel G. Berry, 1847-1852; Exhibit O-Promissory Note, Elizabeth Jones to S. G. & Terry, 3 April 1852; Agreement for Arbitration, Samuel G. Berry and Elizabeth Jones, 24 October 1853; Appointment of Arbitrator, 19 November 1853; Arbitrators' Decision for Dismissal, 20 January 1854; Order, 30 January 1854
- Pages of related documents: 24
16 people are documented within petition 20185329
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Repository: Madison County Public Library Archives, Huntsville, Alabama
- Records of the Chancery Court, Chancery Record 1851-
- Page: 301-31