efendant, having been duly
and legally appointed Registrar for said election district, and
having accepted the said office of Registrar and entered upon the
discharge of the duties thereof at the office of registration, to
wit: No. 2004 Market Street, in said city and county of St.
Louis, it became and was then and there his duty to register all
citizens, resident in said district as aforesaid, entitled to the
elective franchise, who might apply to him for that purpose.

The plaintiff further states, that wishing to exercise her
privilege as a citizen of the United States, and vote for
Electors for President and Vice-President of the United States,
and for a Representative in Congress, and for other officers, at
the General Election held in November, 1872: While said defendant
was so acting as Registrar, on said 15th day of October, 1872,
she appeared before him, at his office aforesaid, and then and
there offered to take and subscribe the oath to support the
Constitution of the United States and of the State of Missouri,
as required by the registration law of said State, approved March
10, 1871, and respectfully applied to him to be registered as a
lawful voter, which said defendant then and there refused to do.

The plaintiff further states, that the defendant, well knowing
that she, as a citizen of the United States and of the State of
Missouri, resident as aforesaid, was then and there entitled to
all the privileges and immunities of citizenship, chief among
which is the elective franchise, and as such, was entitled to be
registered, in order to exercise said privilege: yet, unlawfully
intending, contriving, and designing to deprive the plaintiff of
said franchise or privilege, then and there knowingly, willfully,
maliciously, and corruptly refused to place her name upon the
list of registered voters, whereby she was deprived of her right
to vote.

Defendant stated to plaintiff, that she was not entitled to be
registered, or to vote, because she was not a "male" citizen, but
a woman! That by the Constitution of Missouri, Art. II., Sec. 18,
and by the aforesaid registration law of said State, approved
March 10, 1871, it is provided and declared, that only "male
citizens" of the United States, etc., are entitled or permitted
to vote.