STATE OF NORTH CAROLINA
BUNCOMBE COUNTY

IN THE SUPREME COURT SEPTEMBER TERM, 1919

HATTIE HELTON
-VS-
MARION J. HELTON

COMPLAINT

The plaintiff, Hattie Helton, complaining of the defendent, Marion J. Helton, evers and alleges as follows:

I
That on or about the ... day of May, 1919, defendent procured a marriage license formt he Register of Deeds of Buncombe County, and that afterwards to-wit, on or about the 30th day of May, 1919, defendent pretending and claiming to be a white man, induced plaintiff to go through the ceremony of marriage with him, said ceremony being solemnized by Rev. William Bishop, a duly ordained minister of the Gospel of Buncombe County, and the plaintiff and defendent were duly pronounced man and wife by him.

II
That after plaintiff and defendent had lived together as man and wife for a short while, plaintiff discovered that defendant is a half breed indian, when plaintiff seperated herself from the defendent and has lived seperate and apart from the defendant ever since.

III
That plaintiff is advised that under the laws of North Carolina said marriage was illegal and void, and is prohibited under the laws of the State.

WHEREFORE, plaintiff prays the court that said marriage or pretended marriage be declared void; that plaintiff be permitted to again assume her name before this marriage (Hattie Swink) and for all such other and further relief as the facts herein alleged and the law arrising thereon entitled her.

W.P. Brown (Signature)
Attorney for Plaintiff.

Hattie (Swink) Helton first being duly sworn, says: That she has heard read the foregoing complaint and knows the contents thereof, that the same is true of her own knowledge except so much as is alleged and set forth upon information and belief, and as to those matters she believes it to be true.

Hattie Helton (Name is typed)

Sworn to and subscribed before me this the 23 day of July, 1919.

Jnh. H. Cathey, C.S.C.

(Source: Transcribed from original document)