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<title>In the Supreme Court of the United States : writ of error to the Supreme Court of the state of South Carolina : John Brownfield, plaintiff in error, against the state of South Carolina, defendant in error : answer of defendant in error, John S. Wilson, attorney for defendant in error.: a machine-readable transcription.</title>
<amcol><amcolname>African-American Pamphlets from the Daniel A. P. Murray Collection, 1820-1920; American Memory, Library of Congress.</amcolname>
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<p>Washington, DC, 1994.</p>
<p>Preceding element provides place and date of transcription only.</p>
<p>For more information about this text and this American Memory collection, refer to accompanying matter.</p>
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<lccn>91-898241</lccn>
<sourcecol>Daniel Murray Pamphlet Collection, 1860-1920, Rare Book and Special Collections Division, Library of Congress.</sourcecol>
<copyright>Copyright status not determined; refer to accompanying matter.</copyright></sourcedesc>
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<projectdesc><p>The National Digital Library Program at the Library of Congress makes digitized historical materials available for education and scholarship.</p></projectdesc>
<editorialdecl><p>This transcription is intended to have an accuracy of 99.95 percent or greater and is not intended to reproduce the appearance of the original work.  The accompanying images provide a facsimile of this work and represent the appearance of the original.</p></editorialdecl>
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<hi rend="bold">THE UNITED STATES OF AMERICA.</hi>
<lb>
<hi rend="bold">In the Supreme Court of the United States.</hi>
<lb>Writ of Error to the Supreme Court of the
<lb>State of South Carolina.
<lb>JOHN BROWNFIELD, 
<hi rend="italics">Plaintiff in error</hi>,
<lb>against
<lb>THE STATE OF SOUTH CAROLINA, 
<hi rend="italics">Defendant in Error</hi>.
<lb>
<hi rend="bold">ANSWER OF DEFENDANT IN ERROR</hi>.
<lb>John S. Wilson, Solicitor, Attorney for Defendant in Error.</p></div></front>
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<head>THE UNITED STATES OF AMERICA.
<lb>In the Supreme Court of the United States.
<lb>Writ of Error to the Supreme Court of the
<lb>State of South Carolina.
<lb>JOHN BROWNFIELD, Plaintiff in Error, against
<lb>THE STATE OF SOUTH CAROLINA, Defendant in Error</head>
<p>The defendant in error herein in answer to the petition for writ of error and the assignments of error therewith, and in obedience to the order requiring it to show cause why the judgment rendered by the Supreme Court of the State of South Carolina against the said plaintiff in error as in said writ of error mentioned, should not be corrected, would respectfully show:</p>
<p>I.  That the plaintiff in error did not prove nor otherwise offer to prove the allegations of facts stated in his written motion to quash the indictment, and that his written motion to do so, although verified by him, was not of itself proof nor offer of proof of such allegations.</p>
<p>II.  That the plaintiff in error did not prove nor otherwise offer to prove the allegations of facts stated in his written motion to challenge the array of grand and petit jurors, and that his written motion to do so, although verified by him, was not of itself proof nor offer of proof of such allegations.</p>
<p>III.  That the two exceptions of the plaintiff in error 
<pageinfo>
<controlpgno>0003</controlpgno>
<printpgno>2</printpgno></pageinfo>upon which his appeal from the Circuit to the Supreme Court of the State was based and set out in assignments of error, do not allege that any such proof was made or offered on either of said motions and that the trial Judge refused the same, but simply assert in general terms that the motions were made on the ground &ldquo;that there was no member of the race to which the defendant belongs either on the grand jury, which found the bill of indictment, or on the petit jury, which rendered the verdict,&rdquo; and that the Judge refused the same on that ground.
<lb>
<hsep>JOHN S. WILSON, Solicitor,
<lb>
<hsep>Attorney for the State of South Carolina,
<lb>
<hsep>Defendant in Error.</p></div></body></text>
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