Before her marriage to Andrew Scott, Priscilla Scott owned two mulatto slaves, James and Joshua Perry. In June 1784, she executed to John Hay a bill of sale for the two slaves who were cited in an action of replevin against him. Hay did not pay her for the slaves as he was to return them after he settled his legal difficulties. In 1786, Hay defeated the writ, but did not return the slaves, keeping them, instead, to worm his tobacco. She complains that since then, Hay "pretends and gives out in Speeches" that he is entitled to the two slaves, having paid a considerable sum for them. The petitioners ask the court to invalidate the sale, to compel Hay to return the slaves, and also to order him to pay them the profits earned by the slaves while they worked for Hay. After John Hay's death eight years later, the petitioners revived their bill naming Hay's administratrix, Martha Hay, as defendant. They then amended the revivor adding Hay's children, John and Margaret, as additional defendants. They claim that the elder John Hay transferred the title of James and Joshua Perry to his two minor children, John and Margaret.
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Repository: Maryland State Archives, Annapolis, Maryland
