Thomas Butler v. Gabriel Duvall. Notes of Counsel

Our views of the case are, that negroes under the control & held in bondage by a white man, must be esteemed slaves until the contrary is established in the manner directed by law. that the object of the Act of Md. relied on in the plea was to fix the place where those held wrongfully in bondage should establish the fact & recover their freedom. That this place must always be the County where the master or the person claiming to be the master has fixed the residence of the person seeking to establish his freedom, & whatever wrongs or inconveniences such negro may be subjected to because of such enactment cannot be remedied by Courts. That in short, a petition for freedom is a local action & that a replication to a proper plea to the jurisdiction must shew   that the action is brought in the right place. The question here, then, is whether Washington County is the place pointed out by the legislation of Washington Maryland to try the right of the to freedom of these negroes held in bondage by Judge Duval in Prince Georges County? Notes of Counsel.