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+
+*** START OF THE PROJECT GUTENBERG EBOOK 75835 ***
+
+
+
+
+
+ LEGAL ANTIQUITIES
+
+ A COLLECTION OF ESSAYS UPON
+ ANCIENT LAWS AND
+ CUSTOMS
+
+ BY
+ EDW. J. WHITE
+ Editor Third Edition “Tiedeman, on Real Property,” Author
+ of “Mines and Mining Remedies,” “Personal Injuries On
+ Railroads,” “The Law in Shakespeare,” Etc.
+
+ PUBLISHED BY
+ THE F. H. THOMAS LAW BOOK CO.
+ ST. LOUIS, MO.
+ 1913
+
+ Copyright, 1913
+ by
+ EDWARD J. WHITE
+
+ NIXON-JONES PRINTING CO.
+ ST. LOUIS, MO.
+
+
+
+
+TO THE MEMORY OF MY
+
+MOTHER,
+
+WHOSE FAITH IN HUMANITY MADE HER ALWAYS CHARITABLE FOR THE FRAILTIES OF
+THE PAST AND HOPEFUL FOR THE FUTURE; WHOSE TENDER DEVOTION, SACRIFICES
+AND ENCOURAGEMENT ARE THE DEAREST RECOLLECTIONS OF MY LIFE, THESE PAGES
+ARE AFFECTIONATELY INSCRIBED.
+
+
+
+
+TABLE OF CONTENTS.
+
+
+ CHAPTER I.
+
+ Marriage Laws and Customs.
+
+ CHAPTER II.
+
+ Witchcraft and Sorcery.
+
+ CHAPTER III.
+
+ Recall of Judges.
+
+ CHAPTER IV.
+
+ Trial by Battle.
+
+ CHAPTER V.
+
+ Trial by Ordeal.
+
+ CHAPTER VI.
+
+ _Peine Forte et Dure._
+
+ CHAPTER VII.
+
+ Wager of Law.
+
+ CHAPTER VIII.
+
+ Benefit of Clergy.
+
+ CHAPTER IX.
+
+ Privilege of Sanctuary.
+
+ CHAPTER X.
+
+ Ancient Punishments.
+
+ CHAPTER XI.
+
+ Wills, Quaint and Curious.
+
+
+
+
+INTRODUCTION.
+
+
+In this age of ours, distinguished principally for the variety of the
+inventions and the fast and furious pace at which we move; when the motto
+of the Captains of Industry, being paraphrased, is simply, that “Motion
+means Money”; when the politicians vie with each other in their attempts
+to cater to every passing popular fantasy and the great mass of the
+citizenship is too much engrossed in the commercial life of the day, to
+study or analyze the history of our institutions, but the demand of the
+times is for continuous change, in keeping with the moving spirit of the
+age, it is advisable that we should occasionally stop and consider the
+lessons of the past, lest we forget some of the valuable information of
+antiquity.
+
+There was perhaps never a time, in the history of our country, when the
+general feeling of individual unrest has brought about such disrespect
+for our existing institutions.
+
+The development of the great body of our law, from the brutalities of
+a barbarous period, with the ever changing ideas of civilization, to
+meet the needs of the people, and the higher standards obtaining, has
+been gradual but certain. In so far as we have actually progressed,
+therefore, we should be satisfied with the progress made and should be
+slow to return to the customs or remedies which a past civilization found
+unavailing, lest all our progress should prove but a dim phantom of the
+imagination.
+
+A profitable lesson can oftimes be gleaned from a study of the past and
+when an innovation demanded is one that experience has proven fallacious,
+it is puerile to refuse to profit by this lesson, for even “a burnt
+child” will avoid the fire.
+
+Undoubtedly much of the remedial and substantive law of our period needs
+revision, to the end that simplicity may be attained and the interminable
+delays, resulting from the present practice, incidental to too many new
+trials and other objectionable methods, obviated. But this revision
+should be cautiously made, so as not to impair the efficiency of the
+great body of the law that the wisdom of the past has demonstrated to be
+thoroughly consistent with the individual and national welfare.
+
+The first attempt to simplify procedure in the United States, by the
+adoption of the New York Code, was only sixty-five years ago and a
+majority of the States adopted such legislation since the Civil War. The
+common law practice was greatly improved and simplified by this concerted
+action of the States and unquestionably there are many things that can
+yet be improved in the remedial procedure of the present day.
+
+But the prevalent idea that an increased volume of statute law
+will furnish a panacea for all existing evils, is radically wrong.
+The beneficent rules of conduct, crystallized into law, by custom,
+because consistent with the needs of the people, in the evolution of
+civilization, should be jealously preserved against the unscientific
+fragmentary legislation, too often reflecting the unjust and unequal
+demands of an aroused public sentiment, shaped by designing politicians,
+rather than by the “cool examiner of the public pulse,” prompted by
+beneficent objects.
+
+Legislation, of course, is the simplest way of modifying or repealing
+law, but legislators, in our country, frequently act without adequate
+information or legal training and the most salutary rule of conduct, in
+such hands, might be supplanted by the most unequal and unjust law.
+
+All that is old is not necessarily good, but just because it is old,
+is not a sufficient reason for discarding it. Legislation may become
+as limitless as the imagination of the legislator and unless properly
+advised, it would be inimical to the interests of the State or Nation.
+
+When legislation is advised by any considerable number of the leaders of
+any political party, which history has shown in other countries to have
+been productive of the most deplorable consequences, then it is time to
+leave the issues of the present long enough to study the lessons of the
+past.
+
+In conning the “Marriage Laws and Customs” of past ages, we can, in
+some measure, congratulate ourselves that our Marriage Laws are better
+than those of the past centuries, yet when we consider the large class
+of “Predestined Lost” ones, born as a result of diseased and mismated
+marriages, and when we give but a cursory examination to the divorce
+statistics, we can see that we have grave need for better laws on this
+most important of all subjects, the regulation of the relation, through
+which the standards of citizenship are controled.
+
+The Witch-Craze, in Europe and America, which resulted in the wholesale
+slaughter of innocents, through a blind faith by the Courts, in
+the popular standards of the people, whereby unprovable offenses,
+were permitted to be established in utter disregard of the rules of
+evidence, and a vacillating, dependent judiciary helped for centuries,
+to perpetrate the most intolerable outrages against civilization,
+illustrates the necessity of an absolutely independent judiciary, free
+from the dominating influence of the frenzy of the public and a constant
+adherence to the rules of evidence and the proper legal ideals, in the
+administration of the law.
+
+The Judicial Recall, as we see it in ancient history, is another of the
+present popular fantasies to be avoided. Hammurabi tried this system
+2,500 years before Christ’s time, when witches were convicted according
+to their ability to swim a torrent and surgeons were mutilated, by the
+loss of a hand, for an unsuccessful operation. It was also tried in
+ancient Athens and because of some unpopular decision, the “most just
+Judge” of that city, Aristides, was recalled, and some votes were cast
+against him, because the voters were simply tired of hearing him called
+“The Just.” Aristotle’s evidence is to the effect that this law brought
+about the most deplorable consequences, in Greece, Persia and other
+antique nations, where it was in vogue. The old Anglo-Saxon practice
+of preferring the charge of “False Judgment” against the judge whose
+decision was challenged, who was recalled, if this charge was sustained,
+was found inimical to the interest of the Government and since the
+English Judges were emancipated from the narrow groove of an unskilled
+public sentiment and were appointed for life, the majesty of the law has
+been revered in no other country on the face of the earth, as it has
+been in England. This is testimony worth considering, for, judging the
+future by the past, if this practice undermined the judicial institutions
+of other countries, it would also undermine our own judicial system and
+ought to be avoided. The demand, by the ill-formed, for the destruction
+of the independence of the Judiciary, in utter disregard of the lessons
+of the past and the wisdom of our fathers, should be considered,
+therefore, along with this object lesson furnished by ancient history and
+by penetrating into the records of the past centuries, it will be seen
+that to adopt such a law would mean to return to the “Leges Barbarorum”
+of the past.
+
+In the discharge of their impartial functions, the judges of the people’s
+courts, have nothing to do with popular standards; it is with right and
+wrong, according to the just and equal standards of the law that they
+have to deal and it is as true to-day, as when the patriarch Moses,
+admonished the judges of ancient Israel, that, in the prerogative of the
+judgment-seat, “Thou shalt not follow a multitude to do evil; neither
+shalt thou speak in a cause to decline after many, to wrest judgment.”[1]
+
+The work of the judges is in private places; they have no favors to
+bestow, no rewards of office to distribute. It is frequently the business
+of the charlatan to misconstrue and misinterpret their ablest judgments
+and as the courts are the final repositories of the people’s rights,
+when the public clamor is the loudest for the sacrifice of individual
+right, then the true judicial character performs its highest office, in
+withstanding all assaults by the ill-informed, upon the ramparts of the
+Temple of Justice.
+
+With the wide-spread demand for the “judicial recall” we find the true
+modern standard, in this regard, reflected in the recent strong language
+of an upright Texas Judge, who, in the course of his opinion, observed:
+
+ “I have made it the rule of my judicial life, and shall
+ continue to do so, while invested with the authority pertaining
+ to the office I hold, to decide questions as I understand them,
+ after as careful an investigation as my capacity affords,
+ without reference to what public opinion may be. I do and
+ shall continue to regard the law as superior to the ebullition
+ of outraged feeling, when communities are shocked by crime.
+ When cases arising under such circumstances, have reached this
+ court, my voice and my vote shall, in the future, as in the
+ past, be given for the upholding of the law, not bending it to
+ public sentiment. The stability of the institutions of this
+ government depends upon adherence to the law, as it is written,
+ and not on the fluctuating strenuousity of eruptive ebullitions
+ of popular sentiment.”[2]
+
+This course alone is consistent with the attainment of the just idea
+of government, by the judicial department, and peculiarly of this
+department, because the ideals of the unskilled are not always consistent
+with the standards of scientific jurisprudence. A subservient judiciary,
+dependent upon the vacillating ebullitions of an unstable public
+sentiment would bring about a subversion of the important functions of
+this department of government, just as it did when popular sentiment
+controlled the incumbents of the judgment seat, in ancient Babylon, in
+Greece and in the England of old Anglo-Saxon days.
+
+“Trial by Ordeal,” “Trial by Battle,” the dreadful “_Peine forte et
+dure_,” and “Wager of Law,” are all instructive procedures of a past
+civilization, from which important lessons can be drawn.
+
+“Trial by Ordeal,” “Trial by Battle” and “Wager of Law,” as institutions
+of a primitive people, struggling for right, are but expressions of a
+misguided and abortive effort to attain correct judicial ideals, by
+false and inaccurate standards. Before the evolution of the race had
+attained to the ideals, when tribunals for the trial of questions of
+right and wrong, according to the actual facts in each concrete case,
+had been established, such issues were determined by the ability of
+the accused, in criminal cases, or the appellee, in civil suits, of
+a certain character to accomplish certain ordeals, requiring almost
+superhuman strength or fortitude, or to withstand, by individual combat,
+the strength of the opposite party to the issue waged. Of course, with
+such ideals, might alone controled the right and by the “Wager of Law,”
+the other alternative used in the quest for right, the popularity of
+the principal or his ability to secure oath-helpers, to assist him in
+swearing away the given crime or debt, resolved the conclusion upon a
+given issue, into a simple question of the elasticity of the consciences
+of the principal and his friends, who were always able to win their
+cause, after issue waged, by a sufficiently strong and an adequate number
+of oaths.
+
+On the abolition of the “Ordeal,” in the thirteenth century, when the
+accused, in a criminal charge, refused to submit to a “Trial by Battle,”
+the courts were unable to force a plea, without some amendment of the
+procedure and adroit criminal lawyers, for some years, availed themselves
+of this subterfuge, of having their clients stand mute and refuse to
+plead, when their conviction of felony would be certain to result and the
+courts found themselves helpless to avoid a condition, which resulted
+in the crowding of the jails and prisons, with prisoners, afraid to
+submit to the “Trial by Battle” and refusing to plead to the indictments
+filed against them. This, in time, brought about the greatest judicial
+severity in the case of prisoners standing mute and finally the practice,
+in all such cases, came to be to apply a heavy weight upon the chest of
+the accused and to literally “press him to death,” if he persisted in
+his obstinacy. For centuries, in England, this custom continued, and
+thousands were “pressed to death,” for standing mute, when arraigned
+upon a criminal charge. The same practice was followed in the witch
+persecutions in this country, in the seventeenth century and when we
+consider that these abominable customs obtained, until the past century,
+we are, indeed, to be congratulated that our present procedure, with
+all of its imperfections, has risen to the standard where it is able to
+reject such inhuman and barbarous practices.
+
+The “Benefit of Clergy” and “Privilege of Sanctuary,” illustrate the
+attempt of the Church to mollify, as it were, the cruelties resulting
+from the harsh administration of the criminal laws of mediaeval times, in
+England, by the secular courts and had it not been for these beneficent
+institutions—which were frequently utilized to protect criminals of the
+worst sort—there would have been no alleviation for the sufferings of
+the accused, and the large number of innocents who embraced the plea
+of Clergy, or sought the sacred precincts of the protected Sanctuary,
+would, along with the guilty, have paid the penalty for living in a dark
+and benighted age, unable to protect the innocent from the power of the
+mighty, when accused of wrong-doing.
+
+When we read of the “Ancient Punishments” of the past centuries, we can
+but feel a satisfaction that the struggle of our English forefathers
+of mediaeval times, by herculean efforts against those in authority,
+adopted such fixed principles of constitutional law, as we find reflected
+in _Magna Charta_, and the various constitutions of our own country,
+preventing “cruel and unusual punishment.”
+
+Those so fortunate as to avoid the punishments of the past centuries,
+when death lurked in every charge filed against the poor and oppressed,
+must have felt a sort of consolation in being able to run the gauntlet of
+such barbarities and delusions, and to die a natural death, and this is
+no doubt why we find such evidence of jocularity, mixed with a strain of
+pathos running through the “Quaint and Curious Wills” and testaments of
+antiquity.
+
+Some of the great painters of modern times, such as the late Sir Lawrence
+Alma-Tadema, have depicted scenes upon the canvas, in such manner as to
+make antiquity to live again before modern eyes—to resurrect, as it were,
+the men and women of the past centuries and to infuse new life into their
+bodies—so that they seem to again assume real form and being.
+
+This comes from a close study of the subjects and a genius, almost akin
+to a divine gift. No such gift can aid the lawyer, or did in this
+instance, who seeks to reproduce pen pictures of the antique proceedings
+of the past, but study of the subject is of course essential to give any
+tolerable idea of the obsolete laws and customs of other days.
+
+A keen interest in these old proceedings prompted a somewhat painstaking
+study of many antique volumes, as a basis for the presentation of the
+following pages, but the duties of a quite busy professional life have
+prevented the exhaustive investigation that would otherwise have been
+given the subjects treated.
+
+The sources of the information used in the different essays appear in
+notes and references throughout the work and it is to be hoped, if the
+usual modicum of instruction may be lacking, that some of the interest
+felt by the author, in tracing the old laws and customs of previous ages,
+may, in a measure, be shared, by the reader, who is kind enough to peruse
+the work.
+
+Not nearly all the learning or the law upon any one of the subjects
+presented, will be found set forth in the different paragraphs pertaining
+to the various subjects introduced, but a general outline of each topic,
+with frequent illustrations from concrete cases, will appear.
+
+None of the many legal antiquities of the Grecian States or the Roman
+Empire, which could be so profitably discussed, have been attempted, but
+only a few of the antique English laws and customs that have particularly
+attracted the attention of the author. These several subjects were all
+given cursory examinations in the preparation of the data for “Law in
+Shakespeare” and the superficial investigation in connection with that
+work, led to the more minute treatment herein. This is the apology for
+the undertaking and the engrossment of professional duties is the excuse
+for the limited scope of the treatment accorded each subject.
+
+With the era now existing, these old issues and customs are dead and
+buried out of sight and we would not be mad enough to revive them, if we
+could. They played no unimportant part, however, in the pathetic drama
+of the evolution of the race and we ought to erect monuments to their
+memory, as it were, and occasionally wander back to scatter flowers upon
+the monumental shaft, without deserting the live issues and duties at
+present confronting us.
+
+When we contemplate the lessons of the past, as presented in these “Legal
+Antiquities,” we can but realize the plain truth, expressed by William
+Knox, that “We are the same our fathers have been,” for if we had lived
+and moved and had our being in the dark days when these customs obtained,
+we would have considered them in the same light that our fore-fathers
+viewed them and this should make us charitable toward these frailties
+and mistakes of the past; we should be comforted with the reflection
+that such institutions are but mile-stones of the centuries, marking the
+rapid progress of the race, but when we read of these customs of the men
+and women of antiquity, we can but realize the truth of the words of
+Longfellow, that
+
+ “... the world is very old,
+ And generations pass as they have passed,
+ A troop of shadows, moving with the sun.”
+
+
+FOOTNOTES:
+
+[1] Exodus, XXIII., 2.
+
+[2] Judge Davidson, of Texas, in Ex parte Martinez, 145 S. W. Rep. 959,
+1023.
+
+
+
+
+CHAPTER I.
+
+MARRIAGE LAWS AND CUSTOMS.
+
+
+The term marriage was defined, in the Institutes of Justinian, as the
+lawful union of a man and a woman, including an inseparable association
+of their lives.[1]
+
+Written almost fourteen centuries ago, few, if any, of the many
+definitions of marriage, improve upon that given in the Institutes of
+this old philosopher-lawyer-Emperor of the Romans.[2]
+
+As the basis of the marriage contract is the necessity of society for
+some rule for the appropriation of the opposite sexes to one another and
+the protection of that relation, when once established, it is in one form
+or another, the oldest institution of man and the source of our most
+antique laws and customs.[3]
+
+The Chinese inform us that in the beginning, human beings, like other
+animals, without morality or community laws, wandered through the
+plains and forests, using their women in common; that the offspring
+of such unions knew their mothers, but rarely knew who their fathers
+were and that this custom continued among men, until the Emperor Fou-hi
+established the marriage custom.[4]
+
+While the ancient “Heathen Chinese” were thus holding their women in
+common, there is evidence that among the old Teutons and Hindus, the
+“marriage by capture” and “rape marriages” were still recognized by law,
+long before the “bride-sale” or “sale marriages,” so generally obtaining
+in ancient Assyria and Babylon, were established in Germany.[5]
+
+Some historians claim that, in the early days of heathenry, capture was
+the only method used by young men for securing their brides and the
+supply of consorts depended upon the strength of the male, rather than
+the existence of “the tender passion.”[6]
+
+But the pictures of violence obtaining in these ancient days of heathenry
+are so obscured by the mists of the past and such a large field is left
+for the construction of ingenious theories, surrounded by romances of
+connubial bliss, resulting from this early custom of primitive society,
+that notwithstanding the general popularity of the theory of “marriage by
+capture,” some of the most eminent authorities are inclined to deny that
+such a custom ever existed at all.[7]
+
+Some writers maintain that the rights of the individual were never more
+clearly defined in marriage, than by primitive man, and that this is in
+accord with the common tendency of the male, to attribute a religious
+meaning to the ordinary intercourse with woman.[8]
+
+The Biblical theory of the custom, dates from the command to our first
+parents, in Genesis: “Be fruitful, and multiply and replenish the
+earth.”[9]
+
+In the beginning, we find that from the rib, which the Lord had taken
+from Adam, he made a woman “_and he brought her unto the man_.”[10]
+
+From Christian testimony, we have the evidence of the first book of
+Moses, upon the antiquity of this institution, for when Shechem, the son
+of Hamor, after defiling Dinah, the daughter of Leah, longed for her, in
+marriage, his father went to Jacob and his sons and communed with them,
+saying: “The soul of my son Shechem longeth for your daughter; I pray
+you give her him to wife. And make ye marriages with us, and give your
+daughters unto us and take our daughters unto you.”[11]
+
+So according to the Bible story, we find that the institution of marriage
+obtained seventeen centuries before Christ and these old patriarchs were
+plighting the troth of their son and daughter and talking of dowries and
+marriage portions, much as the parents of the twentieth century youth now
+arrange such matters.
+
+There has always been three principal forms of marriage, from the
+earliest historical times, monogamy, or the marriage of one man to one
+woman at a time, polygamy, or the marriage of one man to several women at
+the same time, and polyandry, or the marriage of one woman to two or more
+husbands at the same time.[12]
+
+Since the days of our first parents, according to the Bible story,
+monogamy has been the institution best suited to the progress of society
+and the proper evolution of the human race, for the most progressive
+nations of the world’s history have embraced monogamy as a rule of social
+conduct.
+
+The old Hebrews, however, made wonderful strides while practicing
+polygamy, an institution established by Lamech, in the sixth generation
+after Adam, which grew apace with the progress of the race, until in
+Solomon’s time, the king had acquired a round thousand women, from the
+different nationalities of the world, seven hundred princesses as wives
+and three hundred concubines.[13]
+
+Polygamy was also practiced in Persia and is to-day, in Turkey and other
+Oriental countries, but under Roman rule it slowly died out in the east.
+It was prohibited by Diocletian and other preceding Emperors and except
+in the single instance of the Mormons, in Utah, it has never reappeared
+in any countries subject to either the Roman or Teutonic laws.[14]
+
+Polyandry no doubt had its origin in unfertile regions, in the endeavor
+to limit the population to the resources of the district; it is almost
+an obsolete custom, but is still practiced in parts of India, Thibet and
+Ceylon.[15]
+
+The marriage customs of the Romans furnish the basis for the marriage
+laws of the civilized world, and even the Hebrew and Teutonic influence
+is small compared to that exerted upon this institution, by the Roman
+law. The general conception of the marriage relation, by the Romans, was
+an exalted one, as it was regarded as an equal partnership in the whole
+of life, effecting an equal distribution in both the secular and sacred
+rights of the individuals.[16]
+
+The three forms of marriage, by the early Roman law, were (1)
+_Confarreatio_, consisting of a religious ceremony, ending in the
+sacrifice of an ox, and the distribution of a broken wheaten cake,
+by a priest; (2) _Coemptio in manum_, a conveyance or formal sale of
+the woman, to the man, and (3) _Usus_, or the right of a wife, by
+prescription, arising from the cohabitation of the wife with the husband,
+for one year, without an absence for over three consecutive nights.[17]
+
+If the woman lived with the man without either the religious ceremony
+or the formal sale, she did not become his wife, unless she had lived
+with him for a year, without absenting herself for three consecutive
+nights.[18]
+
+This latter form was called “passing into the hand” of her husband and
+until this Hand power had been created, the property rights of the wife
+remained unaffected by the marriage. Marriages with Hand in an early day
+were almost universal, however, for the women did not prefer the free
+marriage, which would place them, in law, outside the legal family of the
+husband.[19] Marriages within the Levitical degrees were prohibited by
+the early Roman Emperors, and while first cousins might lawfully marry,
+until the end of the Republic,[20] the Emperor Theodosius prohibited
+their marriage under pain of death by burning.[21]
+
+Uncles and nieces and aunts and nephews were prohibited from marrying,
+until the period of the Emperor Claudius, who desired to marry his
+brother’s daughter, Agrippina, and so passed a decree of the Senate
+allowing such a marriage.[22]
+
+Concubinage was a “permitted connection,” under the Roman law, from the
+earliest times, down to the period of the philosopher Emperor, Leo, A.
+D. 887 when it was prohibited by law.[23] The Justinian Code recognized
+the legality of the relation and fixed the legal and property status of
+the concubine and her progeny and various Christian Emperors, in the
+early days of the Empire passed laws regulating the relation known as
+_Concubinatus_.[24]
+
+The woman was left in the same relation as the law found her; she was not
+raised to the level of the husband and while her children were entitled
+to support from the father, they were not legitimate, but could inherit
+from the mother.[25] Under the Roman law, however, children born in
+concubinage, could be legitimated by the subsequent marriage of their
+parents,[26] and this early Roman law was the foundation for the custom
+obtaining in England, France, Germany, Normandy and Scotland, prior to
+the Norman Conquest, of legitimating the children born out of lawful
+wedlock, by the subsequent marriage of their parents. At the wedding of
+a couple having children prior to their marriage, it was the general
+custom, in the countries named, to place the children under a cloak,
+or mantle, which was also spread over the parents, and the children of
+such a union were thereafter known in the law, as “mantle children,” to
+distinguish them from children regularly born in lawful wedlock.[27]
+
+According to Selden, this ceremony was observed, in England, when the
+children of John of Gaunt and Catherine Swinford were legitimated by
+Parliament,[28] and in Normandy, Duke Richard espoused Gunnora, “in
+Christian fashion,” and “the children were covered with the mantle.”[29]
+
+Neither the ancient Hebrews, Greeks, Mohammedans or Romans, regarded
+marriage as a religious ordinance, but the relation could be established,
+according to the laws and customs of all these ancient people, by the
+interchange of consent.[30]
+
+In Cnut’s time, in England, we find that he made laws to prevent the sale
+of a woman to a man whom she disliked,[31] but even at this stage of
+English society, the church approved these sale marriages and condoned
+the old betrothals of the Anglo-Saxons, and preserved the forms of
+ceremonies which still constitute the curious cabinet of antiquities of
+the English church.[32]
+
+The early Christian church, however, did not treat marriage as a
+sacrament; the doctrine that marriage was a sacrament was evolved from
+the Fifth Chapter of the Epistle of St. Paul, to the Ephesians and it was
+not until the Council of Trent, in the year 1563 that the Roman Catholic
+Church required the celebration of marriage to be accompanied by a
+religious ceremony.[33]
+
+In England, as early as the seventh century, the concern of the church
+about all sins pertaining to the flesh, caused it to raise its voice upon
+questions concerning marriage and divorce.[34]
+
+By the middle of the twelfth century according to the laws of England,
+marriage was held to appertain to the spiritual forum.[35]
+
+In the memorable law suit of Richard de Anesty, in 1143, a marriage
+solemnly celebrated by the church, and from which a child had been born,
+was declared to be void in favor of a prior marriage, constituted by a
+mere exchange of consenting words, without the formality of a religious
+ceremony at all.[36]
+
+Soon after this decision, Glanville acknowledged the jurisdiction of the
+ecclesiastical courts upon all issues touching the validity of marriage
+and because of the acknowledged inability of the king’s court to solve
+the issue, where the legitimacy of a litigant had been raised, the canon
+law was subsequently looked to in all such cases.[37]
+
+In 1215, at the Council of Lateran, Pope Innocent III. extended to the
+whole western portion of Christendom the custom of publishing “banns of
+marriage,” calling upon all men to declare any just cause of impediment,
+if any could be urged to the union and from this time on, marriages with
+banns, had certain legal advantages over a marriage without banns, but
+still the unblessed, formless marriage was a marriage, before the law.[38]
+
+During the reign of Henry II., Alexander III. decreed that a marriage by
+mere consent, in terms of a present, existing contract, would be given
+precedence over a later marriage by another man with the same woman,
+duly solemnized in religious form, and followed by physical union.[39]
+It seems a strong case, to give effect to the bare consent, in present
+form, “unhallowed and unconsummated” as against a solemn formal contract,
+followed by a consummated union, yet this decree was consistent with the
+ecclesiastical law, as interpreted from the middle of the twelfth century
+until the Council of Trent, and no religious ceremony or the presence
+of a priest was essential to constitute a valid marriage, before the
+catholic church.[40]
+
+In 1254 the interesting case of William de Cardunville, a tenant in chief
+of the Crown, came before the court, upon an _inquisitio post-mortem_, to
+determine which of two conflicting claimants was his rightful heir. He
+had solemnly espoused one Alice, with whom he had lived for sixteen years
+and had several children, the youngest being a son, four years old, named
+Richard. Long before his espousel of Alice, he had lived with and had a
+son by one Joan, and this son was also named Richard and was twenty-four
+years old at the death of his father. Joan established a common-law
+marriage, without the religious ceremony, and she was adjudged the
+rightful wife of the deceased and her son, the first begotten Richard,
+was awarded the livery.[41]
+
+From an early date, the interpretation of the English Courts, as to
+the validity of a marriage based upon a present mutual consent of the
+parties, was followed in the United States, with the exception of
+Massachusetts, Maryland, West Virginia and Kentucky.
+
+In the year 1810, Chief Justice Parsons, then on the bench of the Supreme
+Court of Massachusetts, rendered a decision, in which he denied that
+according to the common law a valid marriage could be made, by the mutual
+agreement of the parties alone.[42]
+
+Chancellor Kent, however, in 1809, as Chief Justice of the Supreme Court
+of New York, held that:
+
+ “No formal solemnization of marriage was requisite. A
+ contract of marriage, made _per verba de praesenti_, amounts
+ to an actual marriage and is as valid as if made _in facie
+ ecclesiae_.”[43]
+
+This latter exposition of the common law of England has been generally
+followed in the United States, and may be said to obtain, generally, in
+all the states, other than those mentioned above, except where the local
+statutes provide otherwise.[44]
+
+Clearly, by the law of nature, marriage may be constituted by the mutual
+present consent of two competent persons, of the opposite sex, without
+other formality than the performed inclination of the individuals
+concerned and so the common, or unwritten law, recognized the legality
+of such a contract. The law of nature was adopted as the surest guide to
+the law of man, in this relation.
+
+Considerable uncertainty and some confusion resulted in England as to the
+essentials of a valid marriage and the acts necessary to constitute a
+marriage, prior to the eighteenth century, but during the reign of George
+II., in 1753, a statute was passed,[45] requiring all marriages to be
+celebrated by a clergyman and in a church, unless by special dispensation
+by the Archbishop of Canterbury. This statute was repealed in 1836 when a
+purely civil marriage before only a Registrar, was permitted by the law
+of England, in lieu of the ecclesiastical ceremony.[46]
+
+Touching the issue as to the validity of a marriage not solemnized by
+religious ceremony, is the interesting and famous case of The Queen vs.
+Millis,[47] wherein the House of Lords, erroneously decided that such a
+marriage was void, according to the English law, in the year 1843.
+
+The Irish Court of King’s Bench was equally divided upon the issue and
+in the House of Lords, after the decision of the English judges had been
+given against the validity of the marriage at which no clergyman had
+been present, Lords Lyndhurst, Cottenham and Abinger were for holding
+the marriage void, while Lords Brougham, Denman and Campbell, were in
+favor of its validity, but on account of the precise form in which the
+question was put to the House, the effect of the division was to hold the
+marriage void, and thus a mere accident gave the decision in favor of the
+erroneous view that from the earliest time in English law, the presence
+of an ordained clergyman was essential to the celebration of a valid
+marriage, when, as we have seen, from the decisions and history of the
+law, this was not the case, either in England or according to the Roman
+law, until the Council of Trent.[48]
+
+But while both the temporal and spiritual courts recognized the validity
+of marriages based alone upon mutual consent, followed by a physical
+union, the religious ceremony in an early day, was held essential to
+endow the wife with the right to the husband’s land. Bracton tells us
+that the endowment can only be made at the church door, for while the
+marriage may be contracted elsewhere, the bride can only be endowed at
+the door of the church.[49]
+
+This rule, however, was of course inconsistent with the recognition
+of the validity of the marriage and both the ecclesiastic and temporal
+courts went to the extreme limit to legitimize the offspring of
+marriages, not the result of a wilful criminal relation. Retroactive
+and putative marriages were recognized, both in the temporal and
+ecclesiastical courts, when the legitimacy of children depended upon
+such a construction and in cases where the parents had married within
+the prohibited degrees of consanguinity, or if a woman, in good faith,
+married a man already married and believed that he was single and had
+children by him, the children would be held legitimate and capable of
+inheriting, under the law.[50]
+
+The courts, in order to legitimize the offspring of doubtful marriages,
+went the full limit, in upholding the marriage relation from a very
+early day, but the consort who abandoned her husband to dwell with her
+adulterer, was written beyond the pale of the law. By an old statute, of
+the reign of Edward I., a woman who eloped and abode with her adulterer
+was punished by a loss of dower[51] and this statute was enforced, in the
+case of William and Margaret Paynel, which originated in 1302.[52]
+
+These parties petitioned the king for dower that was due the woman, as
+the widow of her first husband, John de Camoys. It was charged that
+Margaret had eloped with William and committed adultery with him. In
+answer, William and Margaret produced a solemn charter, whereby her
+first husband had “given, granted, released and quit-claimed” the said
+Margaret to William. They also introduced evidence to the effect that
+after they went to live together they had been charged with adultery in
+the court Christian, and that by the oath of compurgators, among whom
+were married and unmarried ladies and a prioress, they had successfully
+met this charge and they offered to leave to the decision of a jury the
+issue whether or not they were guilty of adultery in living together. The
+court, however, in a lengthy decree, held that the facts on their face
+constituted adultery and since no reconciliation of the first husband was
+shown, the woman was not entitled to dower, under this statute.[53]
+
+This illustrates the easy morality of the olden times, so contrary to
+our present standards, touching the marital relation, yet this case
+is not a parallel to many which could be cited in the golden days of
+Greece and Rome. So little sanctity was attached to the marital relation
+in Greece, even in the days of Pericles, that men were accustomed to
+loan their wives to their friends and the literature of the period made
+poetry of marital infidelity and fornication and adultery seemed about
+the commonest employment of both individuals and gods and goddesses.
+The Romans had more of the religious tendencies than the Greeks, but it
+is said that the Younger Cato loaned his wife, Marcia, to the orator
+Hortensius and took her back again, after his death.[54]
+
+Such conduct seems almost unbelievable, because so contrary to the
+natural moral instincts, yet the natural selection between two adults
+of the opposite sexes, although in derogation of the rights of the
+life-partner of either, seems hardly so depraved as the consent by the
+natural parents, to the marriage of infants of tender years, which custom
+was so prevalent in England and France in the past centuries.
+
+During the middle ages, in England, the marriages of little children
+were frequently arranged by their parents, for the purpose of avoiding
+wardship and to prevent the children from forming improper attachments,
+or to effect advantageous family connections for the parents.
+
+History records that Thomas, Lord Berkeley, was contracted to Margaret,
+daughter of Gerald Warren, Lord Lisle, in the forty-first year of Edward
+III., when the girl was only seven years old, and because of her tender
+years, it was stipulated that she should remain with her father for four
+years, but on account of sickness in the family, they were married when
+she was eight years old.[55]
+
+Maurice, fourth Lord Berkeley, was knighted at seven years of age,
+to prevent his wardship, and he was married at the age of eight, to
+Elizabeth, daughter of Lord Spencer, when the bride was also but eight
+years old.[56]
+
+Hundreds of similar cases could be mentioned in France and England, and
+in tropical countries, where the women develop at an earlier age, the
+marriages occur at a corresponding earlier age. In Brazil, in the past
+century parents married their children when still in years of infancy
+and the case of a Brazilian traveler, enroute to England, who demanded
+a half-fare ticket for his wife, who was under twelve years of age,
+occurred in the year 1853.[57]
+
+We are also told that the Hungarians of the seventeenth century often
+betrothed their children while still in their cradles, and the marriages
+were celebrated at the earliest possible age.[58]
+
+The law, which can never rise superior to the prevalent sense of right in
+a given community, recognized the validity of these child marriages, in
+these several countries, just as it validated the “sale marriages” of the
+old Saxon days[59] and in early feudal times recognized the validity of
+exactions known as “Maiden-rent,” a sum paid to the Lord of the Manor,
+in the nature of a fine, in consideration of his relinquishment of his
+accustomed right of spending the first night with the bride of his
+tenant.[60]
+
+As the relics of a barbarous age, such licentious customs, like the
+evidences of genius and depravity frequently found co-existent in the
+same individual, are interesting from a historical standpoint, as
+existing facts connected with the given institutions of a past age and
+also because many of the ancient customs, in altered form, furnish the
+basis for the later customs and practices, gradually changed, with the
+passing years, to meet the different conditions and institutions of later
+periods.
+
+The custom of giving a dowry, or marriage portion, which has obtained
+from an ancient period, is no doubt the result of the old practice of
+paying for the wife in money, the presents, land, or sums paid by way of
+settlement being a mere modification of the old sale and purchase of the
+bride by the husband.[61]
+
+In patriarchial days, we find Shechem, the son of Hamer, negotiating with
+old Jacob and his sons, for the marriage of Dinah and he said unto them:
+“Ask me never so much dowry and gift and I will give according as ye
+shall say unto me; but give me the damsel to wife.”[62]
+
+The _donatio propter nuptias_,[63] of the Romans, and the old marriage
+dowry, the source of so much legislation and litigation in ancient
+England, France and other continental countries, is traceable, directly
+or indirectly to this old practice. Indeed, the oldest known laws treat
+of the marriage dowry, as we find that the code of Hammurabi, written
+2250 years before Christ provided for the return of the dowry, in case of
+the divorcement of a barren wife.[64]
+
+Money was given the bride, from an early day in France, and we find
+that when Clovis married the Princess Clotilde, he sent, by proxy, a
+sou and a denier, which became by law, the usual marriage offering, in
+that country.[65] Caesar speaks of the marriage settlement, as a custom
+he found to exist amount the ancient Gauls;[66] it obtained among the
+Hebrews, at an early date[67] and has come to be a part of the marriage
+laws of most of the civilized countries.[68]
+
+Under the old Angle-Saxon law, dower could be assigned only at the church
+door.[69] Speaking on this subject, Littleton says:
+
+ “When he cometh to the church door to be married there, after
+ affiance and troth plighted, he endoweth the woman of his whole
+ land, or of the half, of other lesser part thereof, and there
+ openly doth declare the quantity and the certainty of the land
+ she shall have for her dower.”[70]
+
+Accordingly, we find, when Edward I. married Marguerite of France, in
+1299, he endowed her at the door of Canterbury Cathedral, in order that
+the gift could be witnessed by all the persons who had assembled to see
+the marriage ceremony.[71]
+
+Selden says that the use of marriage rings, grew out of the old custom
+of giving the bride a dowry, the ring being given as a symbol of the
+husband’s good will, in lieu of the dowry money, of previous days.[72]
+
+However this may be, the custom of giving wedding rings to the bride
+dates from an early period. We find that Isaac propitiated the favor of
+Rebekah by presenting her with a massive ear-ring and two bracelets.[73]
+The betrothal ring was used in ancient Rome, and the Christian church no
+doubt adopted the wedding ring, from the pagan custom of the Italians, as
+a convenient sign of marriage.[74]
+
+In the ninth century the ring was used by the Romans for betrothal
+purposes and not as an insignia of marriage;[75] it was used by the
+Anglo-Saxons, on the betrothal of their infant children, the ring being
+placed on the right hand, until the marriage, when it was transferred to
+the left,[76] and thus grew the custom, until finally, it became a part
+of the English law, that a wedding ring should be used at all church
+marriages.[77] This custom is still retained by the Catholics, among whom
+the ring is consecrated by the priest, sprinkled with holy water, in the
+form of a cross and then returned to the bridegroom.[78]
+
+The superstitions of olden times, which attached to the marriage
+ceremony, as celebrated in the early days of “little knowledge,” as
+some writers refer to the antique periods of the human race, are
+also responsible for the present custom of throwing rice, old shoes,
+stockings, bouquets, and such like practices, at marriages.
+
+The custom of throwing rice was no doubt borrowed from the ancient
+Persians, as rice was no inconsiderable portion of the marriage ceremony
+in Persia.[79] Rice was considered an emblem of fruitfulness and the
+contracting parties, after their betrothal, met at midnight, on a bed,
+in the presence of two sponsors. The sponsor for the man, touched the
+woman’s forehead and asked her if she would have the man; the same
+ceremony was gone through with by the sponsor for the woman and the hands
+of the contracting parties were then joined and rice was scattered over
+them and prayers for their fruitfulness were offered.[80]
+
+Rice also constitutes an important part in the marriages of the Hindus,
+the Brahmins, Javanese, the inhabitants of Elba and is quite generally
+used, in other European countries.[81]
+
+The custom of throwing a shoe after the bridal couple, so generally
+followed, in England, Scotland and the United States, as a token of good
+luck, is directly traceable to the old Jewish law, making the shoe a sign
+of renunciation of dominion or authority, as well as a symbol of exchange.
+
+Thus, under the Mosaic law, the brother of a childless man was bound to
+marry his widow and until he renounced his right, she could not marry
+another. If refused, the woman was obliged to “loose his shoe from off
+his foot” and “spit before his face,” as an assertion of her complete
+independence.[82] The custom was followed, according to Bible evidence,
+in the espousal between Ruth and Boaz, for “as it was the custom in
+Israel concerning changing, that a man plucked off his shoe and delivered
+it to his neighbor,” so the kinsman of this famous woman plucked off his
+shoe and gave it to Boaz, as a token of his renunciation of Ruth and of
+Boaz’s right to marry her.[83]
+
+That this custom was later used by the early Christians, would seem to
+be confirmed by the story connected with the proposal of the Emperor
+Vladimir to the daughter of Raguald, for when asked if she would not
+marry the Emperor, she replied: “I will not take off my shoe to the son
+of a slave.”[84] And as a part of the betrothal, in the early Anglo-Saxon
+days, we read that when the marriage was completed, the father of the
+bride took off her shoe and handed it to the bridegroom, who touched her
+on the head with it, as a token of the exchange and of his power over
+her.[85]
+
+Stocking throwing, at weddings, in England, has existed from a very early
+day and is said to be purely a British custom.[86]
+
+A letter describing the marriage, at court, of Sir Philip Herbert, in
+1604, says that “at night there was sewing into the sheet, casting off
+the bride’s left hose, with many other pretty sorceries.”[87]
+
+In Fletcher’s Poems, written in 1656, is a verse descriptive of
+Clarinda’s wedding, referring to this old custom:
+
+ “This clutter o’er, Clarinda lay,
+ Half-bedded, like the peeping day
+ Behind Olympus’ cap;
+ Whiles at her head each twitt’ring girle
+ The fatal stocking quick did whirle
+ To know the lucky hap.”
+
+It is reported that this custom, as well as that of putting the bride
+to bed, was followed at the wedding of Mary, Queen of Scots, to Lord
+Darnley; that the same ceremony was gone through with, at the wedding
+of Mary II. and the sedate Prince of Orange and that this custom was
+followed at nearly all the marriages of the crowned heads during the
+middle ages, in England, until George III. set aside the joyful custom of
+“posset-drinking and stocking throwing,” on his wedding night.[88]
+
+The common law liability of the community property of the wife and her
+husband for the ante-nuptial debts of his wife, gave rise to a peculiar
+custom, in England, known as “Smock-marriages,” or “Marriage in a
+Shift.” This custom obtained from early Saxon days into the eighteenth
+century and the debtor bride often came to the wedding arrayed only in
+a plain white “smock” or “shift,” as a public declaration or warning to
+her creditors that she took no property to her husband, as a basis for
+charging him with responsibility for her debts.[89]
+
+This eccentric custom, known as “marriage in a smock,” in England, under
+which a widow was married with nothing on but a “shift,” or “smock,” upon
+the theory that her second husband would thereby escape liability for the
+debts contracted by her former husband, was also followed in the Colonies.
+
+This notion that a bride who lacked modesty, as well as money could
+throw off her debts with her dress, by going to church in her smock or
+under garment and thus let her creditors “shift” for themselves, finds
+many examples in the English cases during the seventeenth and eighteenth
+centuries.
+
+On October 17, 1714, Anne Sellwood, of Chilters, All Saints, Wiltshire
+and John Bridmore, were united in the holy bonds of matrimony and against
+the record in the parish register occurs the memorandum: “The aforesaid
+Anne Sellwood was married in her shift, without any clothes or head-gear
+on.”[90]
+
+In 1766 a Whitehaven bride also sought to attain the same end, by going
+to church, as became any decent woman, undressing herself to her sole
+under-garment for the ceremony and donning her clothes again as soon as
+the knot was tied.[91] And it is recorded that somewhere between the
+years 1838 and 1844, a Lincolnshire curate officiated at a wedding where
+the bride stood before him, enveloped only in a sheet.[92]
+
+While such attempts evidence a perhaps dishonest effort to evade the law
+of debtor and creditor, these “smock-marriages” nevertheless evince a
+most laudable inclination on the part of such bold brides to save the
+purse of their intended husbands, so while modern husbands would not
+appreciate the entire return to this now obsolete custom, they would not
+object to the effort of brides, while decently clad, in emulation of the
+spirit evinced by these ancient dames of the “shift marriage” period, of
+using their best efforts to spare the pocket-books of the men of their
+choice.
+
+Alice Morse Earle, in her interesting volume, “Customs in old New
+England,” refers to a “smock-marriage” at Westerly, Rhode Island.[93]
+
+The traveler Kalm also describes such a marriage in Pennsylvania, in
+1748, where the bridegroom, with the proper spirit of chivalry, in order
+to save the appearance of his bride and also his credit, met the bride in
+her scant drapery, half way between her house and his own, well provided
+with warm garments which he dressed her in, after formally announcing,
+in the presence of the assembled guests, that the wedding clothes which
+he placed upon her belonged to him and were only loaned to the bride,
+especially for the occasion.
+
+John Gatchell married Sarah Cloutman, while she was clad only in her
+“shift,” or “smock,” in Lincoln County, Maine, in 1767,[94] and in
+accordance with the popular opinion that the creditors of the bride’s
+first husband could not follow her farther than the king’s highway, if
+she was married only in her “shift,” many “smock-marriages” occurred at
+York, Maine, as recorded in the early history of Wells and Kennebunkport.
+The wedding of the Widow Mary Bradley occurred while she was clad only
+in her “shift,” or under-garment, during the cold weather in the month
+of February, 1774; she went to meet the bridegroom, thus thinly clad and
+the minister found her with chattering teeth and shivering from the cold.
+Her groom had not been as thoughtful as the Pennsylvania bridegroom, in
+loaning her clothing for the occasion, so the gallant gentleman of the
+cloth kindly threw his cloak around the freezing bride, to protect her
+from the wintry blasts.[95]
+
+In Hall’s “History of Eastern Vermont,” there is a graphic account of the
+marriage of the Widow Lovejoy to Asa Averill. The widow was not even clad
+in her “shift,” or under-garment, but appeared at the ceremony, in a nude
+condition, hidden behind a curtain, in a recess of the chimney.
+
+Mr. William C. Prime, in his interesting book, “Along New England Roads,”
+gives an account of two such marriages that came under his observation.
+He describes how the widow Hannah Ward, of Newfane, Vermont, was married
+to Major Moses Joy, in 1789, while the bride, perfectly nude, stood in
+a closet. She held her hand out of a diamond shaped hole in the closet
+door to Joy, and the ceremony was thus performed, in the absence even
+of “smock or shift.”[96] Immediately after the ceremony, however, she
+appeared resplendent in her wedding garments, which the gallant Major had
+provided for her, in the closet.
+
+In the other marriage, according to this old custom, as described by Mr.
+Prime, the nude bride left her room by a window, at night and standing on
+the top rung of a high ladder, she donned her wedding garments and thus
+abandoned the old obligations of her widowhood.[97]
+
+One of the most curious variations of this custom, however, is the
+account given, by Gustavus Vassa, of a “smock-marriage” which occurred
+on the gallows, in New York, in 1784. A felon who had been sentenced to
+death was about to be hanged, when he was liberated to wed a woman clad
+only in her “shift.”[98]
+
+This strange belief in gallows matches, that a condemned felon could
+be thus rescued, by marriage to any woman who would take him from the
+gallows, is placed by Barrington in the list of legal vulgar errors.
+But, as suggested by a writer in Chambers Journal, under the subject
+“Matrimonial Curiosities,” it seems doubtful if such a queer idea
+could have taken possession of the popular mind, unless there was some
+foundation for it, in the law.[99] It is perhaps but one of many such
+customs, arising from some isolated case, wherein the Court recognized
+it, which gave it currency and caused it to be followed in other
+instances.
+
+We are told that in 1725 a woman petitioned King George I., for the pardon
+of a convicted felon, in order that she might wed him, under Tyburn
+Tree.[100]
+
+Manningham states that this was the custom, not the law, in olden times,
+in France, and Italy, and that if any notorious strumpet would beg a
+convicted felon, about to be hanged for her husband, her plea would be
+granted, in order that their joint lives might be bettered by so holy an
+action.[101]
+
+Sterill reports a case that he had seen wherein a woman, clad only in her
+smock, or under-garment, begged a condemned person for her husband, with
+a white wand in her hand.[102]
+
+Whatever recognition the law gave this custom, that it actually existed
+in England, and France is evidenced by the many references to the
+practice, in story and rhyme, published during the seventeenth and
+eighteenth centuries.
+
+Montaigne tells a story of a Picardian, who, seeing a lame dame advancing
+toward him, cried out: “She limps, she limps, despatch me quickly.”[103]
+The ballads of Roxburghe also tell, in rhyme, how a merchant of
+Chichester, who had killed a German, after his sentence and last speech
+upon the gallows, was wooed by no less than ten goodly maidens, who thus
+addressed him:
+
+ “This is our law,” quoth they;
+ “We may your death remove,
+ If you, in lieu of our good-will,
+ Will grant to us your love.”[104]
+
+But having left the fixed doctrines of the law governing the relation
+between the opposite sexes, known as marriage, to enter into a study and
+analysis of the vulgar errors in connection with this subject-matter, it
+is high time to bring the chapter to a close.
+
+Of course it was only attempted in this chapter to take a most cursory
+view of the great subject selected and to present but a few of the many
+laws and customs that have sprung up among the various peoples of the
+earth, governing the relation whereby the opposite sexes, in accordance
+with the law of natural selection, appropriate themselves to one another.
+
+In the ultimate days, when human multiplication has done its work—when
+man has become so populous that every square foot of ground upon the
+known earth shall be covered by a man—the law of evolution will no doubt
+have eradicated many of the present marriage laws and customs, based upon
+a false public opinion, and the generation of the species will no doubt
+be conducted along more advanced and scientific lines.
+
+For the next few centuries, however, judging the future by the past,
+the marriage relation will continue in the same crude and unscientific
+condition that has controled it for the past five thousand years, so
+we need not now concern ourselves about any “devastating torrent” of
+children, but leave this vexed problem for succeeding centuries.
+
+In the meantime, like visionary things, mere motes, the atoms known as
+human beings, will continue to be brought into the world, as a result of
+the unnatural laws and customs governing this natural relation,
+
+ “Still wondering how the marvel came, because two coupling mammals
+ chose,
+ To slake the thirst of fleshy love.”
+
+Tossed into the “giant grasp of Life, like gale-borne dust, or wind-wrung
+spray,” the son of man will continue to be “the toy, the sport, the waif
+and stray of passions, error, wrath and fear.”
+
+Empires have perished and nations have risen during the period covered
+by the foregoing pages. Countless millions of human beings have lived
+their little lives, with their tincture of lust; tasted, for a brief
+space, the “joy in an armful of beautiful dust,” as a result of the
+relation established by the laws and customs treated of in these pages,
+and then “step by step, perforce, returned” to “couthless youth, wan,
+white and cold, Lisping again the broken words, till all the tale be
+fully told.” And thus, for successive ages to come, will the “moving
+row of magic shadow shapes,” continue to come and go “Round with the
+sun-illumined-lantern held, in Midnight, by the Master of the Show.”
+
+
+FOOTNOTES:
+
+[1] Institutiones Justinianus, written 527-529, A. D.
+
+[2] Ringrose “Marriage Laws of the World,” p. 10.
+
+[3] Tylor, “Early History of Mankind;” McLennan’s “Primitive Marriage.”
+
+[4] McLennan’s “Primitive Marriage;” Ringrose, “Marriage Laws of the
+World,” p. 7.
+
+[5] Tacitus, Germania, c. 18; II. Pollock and Maitland’s History English
+Law, 364; Johns’ “Babylonian and Assyrian Laws,” etc.
+
+[6] We are told that this rude custom obtains today in “Far Cathay,”
+Blackwood’s Magazine, July-Dec., 1887, vol. 42, p. 671.
+
+E. J. Woods in his book, “The Wedding Day in All Ages and Countries,”
+claims that the old Hebrew expression of “taking a wife,” arose from the
+custom of capture, not common to the Israelites, but common to other
+primitive peoples. (Vol. I., p. 9.) He quotes Plutarch, as authority for
+the custom of the Spartans to carry off their brides by capture. (Vol.
+I., pp. 40, 41.) Refers to the Rape of the Sabines (vol. I., p. 52),
+the “Institutes” of Menu, as providing one of the forms of marriage
+by capture, known to the four classes of India (vol. I., p. 124). He
+claims that “the capture of women prevailed among the aborigines of the
+Dekkan and in Afghanistan.” (Vol. I., p. 137) He maintains that “In New
+Zealand and the Fejee and other islands of the Pacific, the custom of
+capture of women for wives has prevailed from the earliest times of the
+known history of those places.” (Vol. I., p. 191.) “The form of capture
+is observed in the marriages of the Kalmucks, the Nogay Tartars, the
+Mongols, of the Ortous, in Tartary, the Circassians and the people
+generally of the Caucasus.” (Vol. I., p. 210.) He claims that marriage by
+capture obtained in Poland, in the sixteenth and seventeenth centuries
+(vol. I., p. 220), that the seizure of wives by force obtained in Ireland
+(vol. II., p. 50), so if this record is true, since this custom is found
+to obtain in these countries so late as recent historical dates, it is
+not unbelievable that capture was the order of the early barbarous days
+in our own and other countries.
+
+[7] Fison and Howitt, _op. cit._ 259; Curr, _op. cit._ I., 108; Prof.
+Tylor; McLennan.
+
+[8] Crawley’s “Mystic Rose,” pp. 6, 147.
+
+[9] Genesis, I., 28.
+
+[10] Genesis, II., 22.
+
+[11] XXXIV. Genesis, 8, 9.
+
+[12] Ringrose, “Marriage and Divorce Laws,” p. 10.
+
+[13] First Book of Kings.
+
+[14] Bryce, “Marriage and Divorce,” III. Essays in Anglo-American Legal
+History, 784, 785; Euripides, Androm., vv. 173, 180; Tacitus, Germania,
+c. xvi. I.
+
+[15] Ringrose “Marriage and Divorce Laws,” p. 11.
+
+Monogamy was practiced by the Greeks and Romans as far back as our
+records reach. Wood’s “Wedding Day in All Ages and Countries,” vol. I., p.
+33.
+
+Morganatic, or “left-handed” marriages, are peculiar to Germany. They
+occur between men of superior and women of inferior rank and are
+prohibited by the Royal Marriage Law of England.
+
+Ringrose, “Marriage and Divorce Laws of the World;” Wood’s “Wedding Day
+in All Ages,” vol. II., p. 8.
+
+[16] Bryce, “Marriage and Divorce,” III. Essays in Anglo-American Legal
+History, 797; Modestinus in Dig. xxiii, 1, 2.
+
+[17] Ringrose, “Marriage and Divorce Laws,” p. 8. The Twelve Tables fixed
+the period of three nights, to fix a previous custom, no doubt more
+uncertain. Bryce, “Marriage and Divorce,” III. Essays in Anglo-American
+Legal History, 788.
+
+[18] _Ante idem._
+
+[19] III. Essays in Anglo-American Legal History, p. 788.
+
+[20] Tacitus, Ann. xii, 6.
+
+[21] III. Essays in Anglo-American Legal History, 805.
+
+Before the end of the Republic, the _confarreatio_ had practically
+become obsolete and was regarded as an old world curiosity, although
+formerly obtaining generally, in all patrician families. (III. Essays
+in Anglo-American Legal History, p. 789.) The religious ceremony, used
+at the marriage _confarreatio_, is described in Wood’s “Wedding Day
+in All Ages and Countries,” where it is shown that the custom of the
+“bride-cake” is directly traceable to the cake of wheat or barley, used
+at this old religious ceremony. (“Wedding Day in All Ages and Countries,”
+vol. 1, pp. 51, 52, 60, 61, vol. II., p. 224.)
+
+[22] Tacitus, Ann. xii, 5, 7.
+
+[23] III. Essays in Anglo-American Legal History, 807.
+
+[24] Code Justinian, v. 27, 5, 6; _Nov._ xii, 4; _Nov._ lxxxix, 8.
+
+[25] _Novella_, lxxxix.
+
+[26] _Novella_, xii, 4; lxxxix, 8.
+
+[27] II. Pollock and Maitland’s History English Law, p. 397; III. Essays
+in Anglo-American Legal History, p. 808x.
+
+[28] Selden, Diss. ad. Fletam, p. 538.
+
+[29] Beaumanoir, c. 18, Sec. 24; II. Pollock and Maitland’s History
+English Law, p. 398.
+
+The law did not give the marriage any retroactive effect, by reason of
+this custom of throwing a mantle over the children born prior to wedlock,
+but the custom was recognized by the law, to the effect of legitimating
+the children, in the sense that the act of adopting the custom was
+equivalent to a legal adoption of the children, and in spreading
+the cloak over the children, the law was willing to also spread its
+protecting “mantle” over them and thus they became “mantle children,” by
+force of both the law and this old custom of adoption. Although followed
+in Germany, France and Normandy, this custom was refused judicial
+recognition in the reign of Henry II. and Henry III. See Pollock and
+Maitland’s History English Law, p. 398. But for illustrations of the
+application of the custom in the countries above named, see Schroder’s
+“Mantel-Kinder” of Germany, D. R. G. 712.
+
+Discussing the subject of “mantle-children,” in his work “Wedding Day in
+All Ages,” Wood says: “According to the Scotch law, the marriage of the
+father and mother legitimatizes all children previously born, however
+old they may be. An old saying is that ‘all children under the mother’s
+girdle or apron-string’ at the time of the marriage, are legitimate. In
+very early days children born before wedlock used to perform a part in
+the marriage ceremony, by being placed under the veil or mantle of the
+bride or the pallium of the altar, in which position, they received the
+nuptial benediction. And instances have occurred in more modern times,
+where premature offspring have been put under their mother’s apron, and
+had the string tied over them during her marriage.” (Vol. II., pp. 74,
+75.)
+
+[30] Ringrose, “Marriage and Divorce Laws,” p. 8.
+
+[31] Cnut, 74; II. Pollock and Maitland’s History English Law, 365.
+
+[32] _Ante idem._
+
+[33] Ringrose, “Marriage and Divorce Laws,” p. 9. We find from the
+second chapter of the Gospel of St. John that Jesus, himself, attended a
+marriage in Cana of Galilee, but performed no religious ceremony.
+
+[34] II. Pollock and Maitland’s History English Law, 366.
+
+[35] _Ante idem._ vol. I., p. 158; Letters of John of Salisbury, i, 124.
+
+[36] _Ante idem._
+
+Under the Twelve Tables, enacted B. C. 449, a marriage, in Rome, could be
+contracted without any formality, by the consent of the parties alone.
+Bryce, “Marriage and Divorce,” III. Essays in Anglo-American Legal
+History, p. 786.
+
+[37] Glanville, vii, 13, 14; Select Civil Pleas, pl. 15, 92, 109.
+
+[38] II. Pollock and Maitland’s History English Law, p. 371.
+
+[39] Compiliato Prima, lib. 4, tit. c. 6.
+
+[40] II. Pollock and Maitland’s History English Law, 372.
+
+[41] Calendarium Genealogicum, i, 57.
+
+[42] Atlantic Monthly, for 1888, vol. 61, pp. 521, 527.
+
+[43] _Ante idem._
+
+[44] Atlantic Monthly, for 1888, vol. 61, p. 521.
+
+[45] 26 George II., c. 33.
+
+[46] Bryce, “Marriage and Divorce,” III. Essays in Anglo-American Legal
+History, p. 815.
+
+The statute of the 26’ year of George II., enacted that wedding banns
+should be regularly published three successive Sundays in the church of
+the parish where the parties were for the time residing. This statute
+was passed to prevent the evils of the “Fleet marriages,” during the
+year 1616, when the Rector of St. James was suspended and clerical men
+living within the Rules of the Fleet, solicited passers-by for patronage
+and celebrated marriage ceremonies in ale-houses and garrets, without
+the publication of banns, or the existence of marriage licenses. Wood’s
+“Wedding Day in All Ages,” vol. II., page 235.
+
+[47] 10 Clark and Finley, 534.
+
+[48] Pollock and Maitland, in their History of English Law, say that
+this erroneous decision may have pleased the Lords, but the opposite
+holding will be followed by historians of the middles ages. (Vol. II.,
+p. 372.) And James Bryce, in his “Marriage and Divorce,” III. Essays
+in Anglo-American Legal History, says that this “seems to have been an
+erroneous” decision. (Vol. III., p. 815.)
+
+[49] Bracton, f. 92, 304, 305; Note Book, pl. 891, 1669.
+
+[50] Bracton, f. 63; Bliss, Calendar of Papal Registers, i, 254; Year
+Book, 11-12 Edward III., p. 481.
+
+[51] Statute West, II., c. 34; Second Inst. 433.
+
+[52] II. Pollock and Maitland’s History English Law, p. 395.
+
+[53] Rot. Parl. i, 140, A. D. 1302.
+
+[54] Ringrose, “Marriage and Divorce Laws,” p. 9.
+
+If the investigation of Edward J. Wood, in his book, “Wedding Day in All
+Ages and Countries,” is accurate, the Eimauk, of Caubul, “lend their
+wives to their guests”; “the Candyans, of the lower and middle classes
+universally practice polygamy and also lend their wives to their guests”;
+“the Keiaz, of the Paropamisan mountains of India, lend their wives, as
+do also the people of Kamul”; the “Mpongmes, an African tribe, lend their
+wives,” and “the Koryaks, who are polyandrous, and the Chukchi, in the
+north-east of Siberia, lend out their wives, as do also the Aimaks.”
+
+II. “The Wedding Day in All Ages and Countries,” pp. 97, 146, 151, 167,
+237.
+
+[55] Wood’s “Wedding Day in All Ages and Countries,” vol. II., p. 116.
+
+[56] _Ante idem._, p. 116.
+
+[57] Wood’s “Wedding Day in All Ages and Countries,” vol. I., p. 179.
+
+[58] Wood’s “Wedding Day in All Ages and Countries,” vol. I., p. 221.
+
+[59] II. Pollock and Maitland’s History English Law, p. 364; Tacitus
+Germania c. 18. The old Babylonians and Assyrians held a regular market
+day at a public place, for the sale of their daughters. (Wood’s “Wedding
+Day in All Ages and Countries,” vol. I., p. 70.)
+
+The custom of purchasing wives was known to the ancient Greeks and was
+strongly opposed by Aristotle. The payment of money was frequently the
+only form of marriage, in ancient Greece. (Wood’s “Wedding Day in All
+Ages and Countries,” vol. I., pp. 33, 47, 51.)
+
+In Syria every man paid a sum for his wife, proportionate to the rank of
+her father. (_Ante. idem._, p. 72.)
+
+The Arabians bought their wives as they did their slaves. (_Ante idem._,
+p. 82.)
+
+Burckhardt says that among the Bedouins, of Mount Sinai, marriage is a
+mere matter of purchase and sale. (_Ante idem._, p. 85.)
+
+And the same custom obtained among the Mohammedans, Javanese, Ethiopians,
+Circassians, Ostiacs, a Tarter tribe, Laplanders, the ancient Germans,
+Romans and French, as well as our early Saxon ancestors. (Wood’s “Wedding
+Day in All Ages and Countries,” vol. I., pp. 90, 155, 174, 210, 214, and
+vol. II., pp. 3, 173, 247.)
+
+The custom of purchasing wives is perhaps derived from the old Salic law.
+It was known to the ancient Jews, as well as the other nations above
+mentioned and the custom of marriage portions and doweries is no doubt
+the outgrowth of this old practice. (Wood’s “Wedding Day in All Ages and
+Countries,” vol. II., p. 173.)
+
+[60] Bouvier; Cowel; I. Reeves History English Law, pp. 369, 371. In
+legal contemplation, a female was in the custody of the Lord paramount,
+until she reached her majority, and then he was bound to find her a
+proper marriage. His custody continued until her marriage, even after she
+became of age and she could only marry with his consent. She was bound to
+obtain the consent of the Lord, or lose her dower, but it was sufficient,
+if she had the consent of the chief lord, to marry. The custom was based
+upon the fealty which the husband owed the lord and since the woman lost
+her inheritance, if she gave cause of forfeiture, the lord had it in
+his power to exact anything of her, and hence the custom referred to in
+the text, an exaction allowed by way of a punishment for the offense of
+belonging to the frail sex, in an early day. Reeve’s History English Law,
+vol. I., pp. 370, 371.
+
+Shakespeare makes Cade refer to this old barbarous custom, in 2’ Henry
+VI., when he says: “... There shall not a maid be married, but she shall
+pay to me her maidenhead, ere they have it.” (Act IV., Scene VII.; White’s
+“Law in Shakespeare,” Sec. 299, p. 326).
+
+[61] Wood’s “Wedding Day in All Ages and Countries,” vol. II., p. 16.
+
+[62] Genesis, XXXIV., 12.
+
+[63] Smith’s Dict. Greek and Roman Antiquities.
+
+[64] In the first known code of laws ever written, so far as our history
+goes, in the old code of Hammurabi, King of Babylon, who reigned from
+2285 to 2242, B. C., we find that doweries and marriage portions were
+spoken of, just as in modern statutes, and it was provided that if a
+childless woman should be returned to her father, he should return the
+dowry, and if he did not the husband could deduct all the dowry from the
+marriage portion and then return the marriage portion, the house of her
+father.
+
+Code Hammurabi, Secs. 163, 164; Johns’ “Oldest Code of Laws,” pp. 32, 33;
+Johns’ “Babylonian and Assyrian Laws,” etc.
+
+[65] Wood’s “Wedding Day in All Ages and Countries,” vol. II., p. 17.
+
+[66] _Ante idem._, p. 18.
+
+[67] Genesis, XXXIV., 12.
+
+[68] Ringrose “Marriage and Divorce Laws of the World.”
+
+[69] Selden.
+
+[70] Coke, Littleton, 31.
+
+[71] Wood’s “Wedding Day in All Ages,” vol. II., p. 16.
+
+Shakespeare makes frequent reference to the marriage custom of giving
+a dowry to the bride, in his various plays. Thus, in “Love’s Labour’s
+Lost,” (Act II., Scene I), Boyet, in speaking to the Princess, refers to
+Aquitaine as “a dowry for a queen;” King John tells Phillip of France,
+that if his son shall love his daughter, “Her dowry shall weigh equal
+with a queen.” (King John, Act II., Scene I.) Petruchio tells Katherine,
+in “Taming of the Shrew”: “_Pet._ Your father hath consented that you
+shall be my wife; your dowry ’greed on; and will you, nil you, I will
+marry you.” (Act II., Scene I.) Gloster, in 1’ Henry VI., speaking of the
+proffer of his daughter to the King, by the Earl of Armagnac, refers to
+the “large and sumptuous dowry.” (Act V., Scene I.) And the poor Lear, is
+made to ask the duke of Burgundy, in discarding his daughter, Cordelia:
+“What, in the least, will you require in present dower with her?” (Act I.,
+Scene I.)
+
+White’s “Law in Shakespeare,” Sec. 66, pp. 95, 97.
+
+[72] Wood’s “Wedding Day in All Ages,” vol. I., p. 25.
+
+[73] Genesis, XXIV., 22, 53.
+
+[74] Wood’s “Wedding Day in All Ages,” vol. II., p. 131.
+
+[75] _Ante idem._ 130.
+
+[76] _Ante idem._ 133.
+
+[77] During the reign of George I. and George II., the wedding ring was
+placed on the usual finger at marriage and then transferred to the thumb.
+Wood’s “Wedding Day in All Ages,” vol. II., p. 134.
+
+[78] _Ante idem._ p. 135.
+
+[79] Wood’s “Wedding Day in All Ages,” vol. I., p. 94.
+
+The Quakers and Mormons reject the wedding ring, because of its
+heathenish origin. Wood’s “Wedding Day in All Ages,” vol. II., p. 135.
+
+The wedding rings of St. Louis, of France; of Margaret, daughter of the
+Earl of Warwick; of the wife of Duke John, of Sweden; of Martin Luther
+and Catherine Von Bora, his wife; the ring given by Henry VIII. to Anne
+of Cleves; that given by Phillip, to Queen Mary, and by Lord Darnley, to
+Mary, Queen of Scots, are described in Wood’s “Wedding Day in All Ages,”
+vol. II., pp. 145, 149.
+
+Chaucer’s reference to the wedding ring, in his “Troilus and Cressida”;
+Shakespeare’s mention of the gemmal ring, in “Midsummer’s Night’s Dream”;
+and his use of the ring in “Two Gentlemen of Verona,” “Twelfth Night” and
+“Merchant of Venice,” with many traditions of the wedding ring, will be
+found interestingly presented in Wood’s “Wedding Day in All Ages,” vol.
+II., pp. 129, 149.
+
+The custom of placing the ring upon the fourth finger of the left hand,
+according to the opinion of a writer in the British Apollo, in 1708,
+dates from the discovery of the convenience of the left hand for such
+ornament because less employed than the right and the fourth finger,
+less than others, was needed in ordinary use. See Knowlton’s “Origin of
+Wedding Superstitions;” Finck’s “Primitive Love and Love Stories.”
+
+[80] Wood’s “Wedding Day in All Ages,” vol. I., pp. 94, 95.
+
+[81] _Ante idem._, vol. I., pp. 128, 133, 156; vol. II., pp. 44, 224.
+
+[82] Deuteronomy, XXV., 5, 10.
+
+[83] Ruth, IV., 7, 8.
+
+[84] Boston Trans. Aug. 13, 1910; Wood’s “Wedding Day in All Ages,” vol.
+I., p. 16; Hutchinson’s “Marriage Customs in Many Lands.”
+
+[85] _Ante idem._
+
+Wood quotes Michelet, in his “Life of Luther,” to show that the great
+Reformer used the shoe at a marriage ceremony. Wood’s “Wedding Day in All
+Ages,” vol. I., p. 16.
+
+[86] Wood’s “Wedding Day in All Ages,” vol. II., p. 218.
+
+[87] _Ante idem._, p. 216.
+
+[88] _Ante. idem._, pp. 215, 221.
+
+Referring to the custom of stocking-throwing, Rowe, in his “Happy
+Village,” in 1796 says:
+
+ “The wedding-cake now through the ring was led,
+ The stocking thrown across the nuptial bed.”
+
+And in the “Collier’s Wedding,” we read:
+
+ “The stocking’s thrown, the company gone,
+ And Tom and Jenny both alone.”
+
+[89] See Article on “Ancient Marriage Customs,” in Uncle Remus’ Home
+Magazine, June, 1912.
+
+[90] “Matrimonial Curiosities,” Chambers Journal, vol. 48, pt. 2, p. 813.
+
+[91] _Ante idem._
+
+[92] _Ante idem._
+
+[93] “Courtship and Marriage Customs,” p. 79.
+
+[94] Earle’s “Customs in Old New England,” p. 79.
+
+[95] History, Wells and Kennebunkport.
+
+[96] “Along New England Roads,” p. 25.
+
+[97] “Customs in Old New England,” p. 78.
+
+[98] Earle’s “Customs in Old New England,” p. 79.
+
+[99] Chambers Journal, vol. 48, pt. 2, July-Dec., 1871, p. 812.
+
+Discussing the subject of “gallows-matches,” Wood, in his “Wedding Day in
+All Ages,” says: “Formerly was current a vulgar notion that if a woman
+married a condemned man under the gallows, she would thereby save him
+from execution. Certainly this exemption had a quasi-legal existence in
+France in the fifteenth century, as there are instances of it in the
+annals of that country.” (Vol. 2, p. 25.)
+
+[100] Chambers Journal, vol. 48, pt. 2, 812.
+
+[101] _Ante idem._
+
+[102] _Ante idem._
+
+[103] _Ante idem._
+
+[104] Roxburghe Ballads.
+
+
+
+
+CHAPTER II.
+
+WITCHCRAFT AND SORCERY.
+
+
+_Witch_, is taken from the Hebrew word, rendered _venefica_,
+meaning a poisoner and divineress; one who dabbles in spells and
+fortune-telling.[1] In course of time, the term was used to indicate
+those who held communion with evil spirits and derived a super-human
+power from them, whereby they could not only foretell the coming of
+future events, but bring about evil results upon the life, bodies, or
+possessions of individuals. This unnatural power was supposed to be
+acquired by a compact with the devil himself, by which the wizard or
+witch bargained his or her soul to the devil as a consideration for the
+power of enchantment.[2]
+
+From the earliest times, men and women have tried to hold communion with
+superior beings and to pierce the secrets of the future.
+
+In the oldest code of laws in the known world, promulgated by Hammurabi,
+King of Babylon, 2285 years before Christ, the first two sections of the
+code are levelled at the crime of witchcraft, and we find that it is
+there written, that:
+
+ “If a man weave a spell and put a ban upon a man, and has not
+ justified himself, he that wove the spell upon him shall be put
+ to death.”[3]
+
+And the same code provided that the man against whom the spell was woven,
+should plunge into the “holy river” and if the river overcame him, his
+house should go to the weaver of the spell, but if the river made the man
+innocent, he should take the house of the sorcerer and he was to be put
+to death.[4]
+
+According to the photogravure of the blocks of diorite, upon which these
+most antique laws were written, therefore, when King Hammurabi, received
+his law direct from the seated sun-god, Samas,—the judge of heaven and
+earth—the old delusion of witchcraft and sorcery obtained. So prevalent
+was the offense, according to the delusion then obtaining, that the very
+first sections of the code were directed at this crime, established to
+the satisfaction of the judges of that period, by the test of a plunge
+into the “holy river,” in the absence of more direct proof of the
+existence of the offense which existed only in the imaginations of the
+superstitious inhabitants of that misty age.
+
+During the time of Moses, we find that many imposters insulted the
+intelligence of the Supreme Being, by claiming to have received delegated
+powers from on high and hence Moses provided in his law that “Thou shalt
+not suffer a witch to live.” The long persecution of persons convicted
+of witchcraft, by a misinterpretation of this text, was thus justified
+by this Biblical injunction and many conscientious men and women, in
+their inability to understand the science of common things, attributed
+appearances which they could not explain, to supernatural agencies and
+blindly believing in this Mosaic law, proceeded to violate the highest
+laws of God and man, in the fanaticism that a Divine injunction was
+being obeyed, in the punishment of those convicted of witchcraft and
+sorcery.[5]
+
+The Twelve Tables of the early Romans contained penal provisions against
+one who should bewitch the fruits of the earth or conjure away his
+neighbors’ corn, into his own field,[6] and a century and a half after
+the adoption of the Twelve Tables, one hundred and seventy Roman women
+were tried and convicted of poisoning, under the pretense of charms and
+incantations, which led to new laws against such supposed practices.
+
+As the Mosaic law against witchcraft was formerly interpreted, to mean
+the punishment by death of witches who did positive injury to another in
+his person or property, so the Roman laws were directed against those
+supposed to have done positive injury to a person, in his property or to
+have hurt him, physically.
+
+In other words, the mere possession of magic art, in the old heathen
+world, was not, in itself a crime, for while it was dreaded, as being
+liable to be turned to malicious or wrongful purposes, it was also
+recognized as a most beneficial art, through which the religion of
+domestic life and the remedy of healing the sick, was supposed to come.
+
+That this view of witchcraft continued to prevail for many centuries
+after the reception of Christianity, is evidenced by the laws of
+Constantine, in the fourth century, which ordained capital punishment
+for all those who practiced noxious charms against the life or health of
+others, by supernatural power, but exempted from the punishment of the
+law, all those who practiced magical arts for beneficial purposes, such
+as warding off hailstorms, and excessive rains or windstorms, or curing
+cattle or persons afflicted with disease.[7]
+
+The savage laws by the Christian Emperors in the early centuries did
+considerable harm in after ages. The Anglo-Saxons patterned their laws
+against sorcery and witchcraft after the folk-laws of the continent and
+Cnut, even, legislated against the witchcraft which was heathenish.[8]
+
+During the reign of Henry I., criminals who encompassed the maiming or
+sickening of a person by maltreating a waxen image of him—a belief that
+generally obtained from this time until the seventeenth century—were
+either hanged or burnt.[9] And during the reign of this monarch, in
+England, Archbishop Gerard, of York, was accused of necromancy and
+sorcery and when it was discovered that he had died suddenly, and a book
+on the subject of astrology was found under his pillow, his body was
+refused burial in the Cathedral.[10]
+
+After the influence of the Catholic religion had safely extended its
+power over the western world, however, and the fear of a return to
+paganism was looked upon as most improbable, the church was not inclined
+to look with such aversion upon the class of criminals accused of
+dabbling in the black arts. Astrology and necromancy were looked upon
+with considerable admiration by the most powerful of the church and laity
+and even Bishops and Popes tempted the powers of evil, by little harmless
+excursions into the great realm of the supernatural.
+
+This temporizing by the church continued until about the beginning of the
+thirteenth century, when heresy had become so common that the interests
+of the church were threatened and when the church began, in various parts
+of the world, a most stringent prosecution of witches and sorcerers and
+the crowned-heads of Europe, in humble submission to the demands of the
+Pope, used the power of the kingdom in an attempt to rid the church of
+this threatened evil.[11]
+
+From an early day, in France, people were punished for supposed crimes
+resulting from witchcraft and sorcery. Charlemagne frequently ordered
+all necromancers, sorcerers and witches to be driven from the realm and
+with the gradual increase of the crimes attributed to them, he published
+different edicts, preserved at length in the “Capitulaire de Baluse.”[12]
+
+By these edicts, death was decreed against all those who practiced feats
+of sorcery and witchcraft, and those who conspired with the devil to
+afflict either man or woman, with barrenness; who excited tempests,
+or windstorms; destroyed the fruits of the earth, hurt cows, or other
+animals, and afflicted human beings with sores or disease, were to be
+immediately executed, upon their conviction.[13]
+
+From the time of Charlemagne until the eighteenth century, in France,
+England, Scotland and other European countries, the trials for witchcraft
+and sorcery continuously multiplied and it became the common means to
+enable a wolfish monarch to rid himself of a disliked rival or subject,
+upon some trumped-up charge, based upon some trivial circumstance
+connected with an unexplained phenomenon.
+
+The destruction of the Stedinger, in 1234; the persecutions of the
+Templars, from 1307 to the year 1313; the trial and execution of poor
+Joan of Arc, in 1429, the tragedy of Arras, in 1459, and many other
+horrible casualties, during the middle ages illustrate the prevalency
+with which this delusion was used to bring about the death and
+destruction of a large portion of the human race, who were guilty only of
+living in an age of ignorance and cruelty.[14]
+
+At the instance of Pope Gregory IX., the Emperor of Germany, Frederic
+II., pronounced his banns against the valiant Stedinger, in 1233 and a
+crusade was inaugurated against them in all Germany. Eight thousand of
+them were slain upon the field of battle and the whole race extinguished
+and their houses and woods were burned, because they would not embrace
+the Catholic religion, but continued to adhere to their own ideals and
+ideas in religion and government. The Pope charged that they “insulted
+the holy sacrament, consulted witches to raise evil spirits, shed blood
+like water, took the lives of priests and concocted an infernal scheme to
+propagate the worship of the devil.”[15]
+
+The Templars had also offended the Church and in 1307 the charge was
+brought against them that they were in communion with evil spirits and
+had sold their souls to the devil. This charge effected its object
+and they were extirpated, even as the poor Stedinger had been, in the
+previous century.
+
+Philip IV., of France, acting under authority of the Pope, ordered the
+arrest and trial of the Templars and the confiscation of their goods
+and property. Hundreds were put to the rack and when tortured by pain,
+confessed the most unreasonable charges which were lodged against them
+and this only heightened the popular clamor and the persecution against
+them, as a body. Fifty-nine Templars were burned alive, by a slow fire,
+in a field adjoining the city of Paris, after they had been convicted of
+witchcraft and sorcery, and other instances of their persecutions, upon
+this charge, occurred in the different provinces, until the year 1313,
+when the Grand Master of the Order Jacques de Molay was burned to death,
+a fitting climax to this reign of terror, inaugurated by the Pope and
+Monarch, to rid themselves of an odious order—a lasting stigma to the
+memory of the Pope and Monarch responsible for such conditions and an
+ever increasing source of pity to the millions possessing the divine gift
+of a tender fellow-feeling for their own kind.
+
+In 1429 the poor Joan of Arc fell a victim to the charge of witchcraft
+and sorcery and like dual criminals, proceeding hand in hand to
+accomplish the crime, religion and law, not only failed to raise a hand
+to prevent the conflagration that consumed and tortured the sainted
+body of this patriotic victim, but actually consummated the crime, in
+the name of holy order and legal procedure, which will remain eternally
+as one of the saddest and most pitiable spectacles of the weakness and
+criminal blunderings of the Church and State.
+
+In 1459 a devoted congregation of the Waldenses, at Arras, fell victims
+to a charge of witchcraft and sorcery. Many of them, when placed upon
+the rack, admitted their guilt, to escape the torture; prominent rulers
+and people of wealth were involved and many were burned, while others
+were thrown in prison, or paid large fines to escape a worse fate, at the
+hands of the ignorant and intolerant courts, that reflected the hatred
+and persecution of the enraged populace.[16]
+
+In 1487 two old women were arrested for witchcraft, in Switzerland, for
+having caused a tempest. They were placed upon the rack, where people,
+enforc’d do speak anything, and after severe torture they admitted that
+they were in collusion with the devil and were condemned to die, and if
+the criminal register at Constance is to be believed, they were burned at
+the stake, for after the name of each, appears the significant epitaph:
+“_convicta et combusta_.”[17]
+
+Speaking of the great prevalency of this accusation, about this period,
+Florimond, in his work concerning the Anti-Christ, observes:
+
+ “The seats destined for criminals in our courts of justice are
+ blackened with persons accused of this guilt. There are not
+ judges enough to try them. Our dungeons are gorged with them.
+ No day passes that we do not render our tribunals bloody by
+ the dooms which we pronounce, or in which we do not return
+ to our homes, discountenanced and terrified at the horrible
+ confessions we have heard.”
+
+But the _Witch Mania_ in Europe, may be said to properly date from about
+the year 1488, when Pope Innocent VIII., in a determined effort to rid
+the Church of Rome of the stigma and opposition of those supposed to be
+prompted by the devil, appointed inquisitors in every country, armed with
+the apostolic power to accuse and punish this class of criminals.[18]
+
+Following the appointment of this commission and those of successive
+Popes, a wholesale slaughter of innocent men and women, followed this
+crusade of bigotry and ignorance.
+
+Cumanus burned forty-one women in one province alone, in Italy; Sprenger
+burned more than five hundred in a year, in Germany; five hundred were
+burned in Geneva, in 1515 and 1516; in the district of Como, in the
+year 1524 about a thousand people suffered death for witchcraft and for
+several years thereafter the general average in this district was a
+hundred a year and one inquisitor alone, Remigius, took whatever credit
+he was entitled to, for having during a period of fifteen years convicted
+and burned nine hundred poor souls for this imaginary offense.[19]
+
+In 1520 witches were burned in fires that were ever kept burning to
+receive their tortured bodies, in France. In 1561 five poor women of
+Verneuil were convicted of turning themselves into cats and prowling
+around and performing satanic feats, as a result of which they were all
+burned alive.[20]
+
+In 1571 the celebrated sorcerer, Trais Echelles, after his confession,
+was burned at the Place de Greve, in Paris.
+
+In 1573 Giles Garnier, of Lyons, was indicted for being a loup-garou, or
+man wolf,[21] and prowling around at night and destroying children. Fifty
+witnesses testified against him and after being placed upon the rack, he
+confessed the crime he was charged with and was condemned by Dr. Camus to
+be:
+
+ “tied to a stake and burned alive and that his ashes be then
+ scattered to the winds.”[22]
+
+The conditions in England, during the sixteenth century, were about the
+same as in France, Germany and Italy, so far as the persecutions for
+witchcraft were concerned. While rooting out many errors of ignorance and
+superstition, the Reformation made no head-way at all against witchcraft
+and sorcery, the greatest evil of the period and strange to narrate,
+while their followers were persecuted for this crime, Luther and Calvin
+were as firm believers in witchcraft as were the Popes whom they opposed
+and their followers were even as zealous persecutors of the innocents
+accused of this crime as were the churchmen of the old religion.[23]
+
+A few of the English cases will not be found uninstructive as
+illustrative of the prejudice and persecution levelled at those accused
+of witchcraft in that country, during the sixteenth and seventeenth
+centuries.
+
+The celebrated case of the Witches of Warbois, in 1594, is especially
+worthy of mention. The good old Mother Samuel lived in the neighborhood
+of Sir Samuel Cromwell and a Mr. Throgmorton and the latter had several
+daughters and among them a Miss Joan, who was a melancholy girl, whose
+head was filled with stories of ghosts and witches and she conceived the
+idea that poor old Mother Samuel had bewitched her, as she felt sudden
+pains in her limbs and strange sensations, when she went near her. Her
+parents believed her and after a few family casualties the poor old
+woman was arrested upon a charge of witchcraft filed against her by the
+family of Sir Samuel Cromwell, after the death of his wife, as she had
+confessed, upon different persecutions that she had afflicted them with
+pains and fits and turned their milk sour in the pans, prevented their
+ewes and cows from bearing and that she had caused Lady Cromwell’s death.
+She also confessed that her husband and daughter were leagued with her in
+witchcraft and all three were found guilty and hanged on April 7’, 1593.
+
+In Scotland, during the ninth Parliament of Queen Mary, witchcraft
+was made a crime punishable by death, and after this statute, the
+superstition and fear of the people brought frequent accusations against
+different people, many of whom were prominent in Government and social
+circles.
+
+The case against Dr. Fian and his accomplices will illustrate the feeling
+obtaining in Scotland about this period. Gellie Duncan implicated
+Agnes Sampson and when she was put to the torture, she also implicated
+Dr. Fian, Marion Lincup and Euphemia Macalzean, the daughter of Lord
+Cliftonhall. They were charged with having attempted the king’s life,
+through witchcraft and sorcery. It was charged that they had raised a
+fearful storm at sea, to attempt to wreck a ship on which the king, James
+VI., and his bride had sailed. Several of the accused were subjected to
+the torture and finally confessed to the crime and implicated the rest,
+and on June 25’, 1591, Barbara Napier, Gellie Duncan, Agnes Sampson,
+Dr. Fian and twenty-five others were hanged for witchcraft and Euphemia
+Macalzean was “bound to a stake, and burned in ashes, _quick_ to the
+death.”[24]
+
+After this conviction in Scotland, the renown of King James as an enemy
+to witchcraft and sorcery, preceded him to England and when he ascended
+the English throne in 1603, he was ready for a new crusade against this
+obnoxious class of criminals.
+
+The first statute upon witchcraft, in England, was that of 1541, which
+defined the offense and affixed the punishment.
+
+Two statutes were passed in 1551, one relating to false prophesies,
+due no doubt to the machinations of Elizabeth Barton, the “Holy Maid
+of Kent,” and the other was levelled at conjurgations, witchcraft and
+sorcery.
+
+The statute of Elizabeth, in 1562, recognized witchcraft as a crime
+of first magnitude, punishable by death, regardless of whether it was
+exerted against the lives, limbs, or property of the subjects.[25]
+
+On his accession to the throne in 1604 King James passed the statute
+whereby it was enacted that:
+
+ “If any person shall use, practice, or exercise, any
+ conjurgation of any wicked or evil spirit, or shall consult,
+ covenant with, or feed any such spirit, the first offense to be
+ imprisoned for a year and stand in the pillory once a quarter;
+ the second offense to be death.”
+
+The milder punishment was not inflicted, but all convicted under this
+statute were hanged and burned, or burned, without previous strangling,
+“alive and quick.”
+
+This statute continued on the statute books until the year 1736, when
+it was repealed and suffered no longer to disgrace the intelligence of
+the country, after which date witches, conjurers and fortune-tellers
+were only subjected to the jail sentences common to other misdemeanors,
+confinement for short intervals, or the pillory.
+
+We are reliably informed that during the Long Parliament, in England,
+three thousand witches were executed[26] and during the first eighty
+years of the seventeenth century, it has been estimated that five
+hundred people were annually executed for witchcraft, in England, making
+a total of forty thousand who thus met their deaths, during the whole
+period referred to.[27]
+
+One of the rankest weeds in the garden of wild delusions that flourished
+in England, in the seventeenth century was Matthew Hopkins, who prided
+himself upon the title of “Witch-finder General.” About 1644 he made the
+discovery of some moles or other marks on the accused persons, which he
+advertised as “devil’s marks” and he immediately became in great demand
+in helping to hunt down and convict persons accused of this crime.
+
+He had several tests to subject them to, and one of the cruelest was to
+tie the hands and feet of the prisoner together cross-wise, the right
+thumb to the toe of the left foot and _vice versa_. Being thus tied, so
+they could not swim, they were wrapped in a cloth or blanket and placed
+in a pool of water or a river, on their backs. If they sank, they were
+innocent, but drowned for their innocence, and if they floated, they were
+adjudged guilty of witchcraft and hanged or burned.[28]
+
+Another kind of punishment, to extort a confession, was what was called
+“Waking” the witch. An iron bridle or hoop was placed cross-wise of her
+face with four prongs, penetrating the mouth. The hoop was fastened
+to the wall at the back of the head, so that the prisoner could not
+lie down. She was kept in this position sometimes for several days,
+attendants constantly prodding her, to keep her awake.[29]
+
+In 1664 the venerable Sir Mathew Hale, condemned Amy Duny and Rose
+Cullender, to be burned at the stake in St. Edmondsbury, upon the most
+flimsy kind of proof, offered to establish this imaginary crime.[30]
+
+When these two old women went to a shop to purchase herring, their
+ugliness caused them to be insulted, and they resented it. The daughter
+of the owner of the store was afflicted with epilepsy and the women were
+charged with having bewitched her. She was blind-folded and when they
+touched her, her imagination and nervousness was such that she was thrown
+into a fit and this was received as proof positive of her bewitchment
+and the fact that she also was thrown into a fit, when similarly
+blind-folded, when others than the accused persons touched her, was held
+incompetent as evidence in their favor.
+
+Upon the evidence of Samuel Pacey, the girl’s father, Margaret Arnold,
+her aunt, and Thomas Brown, as an expert witness upon Witchcraft, the
+learned Sir Mathew Hale charged the jury to ascertain from the evidence,
+first, whether or not the persons charged were actually bewitched and
+if so, whether or not the prisoners had actually bewitched her. He
+personally told the jury that he had no doubt of the fact that witches
+existed, first because the Scriptures affirmed it and, secondly, because
+the laws of the country recognized it. The jury promptly returned a
+verdict of guilty and the girl and her father called the next morning to
+see Sir Mathew Hale and advised him that the complete recovery of the
+girl followed within a half hour after the verdict of conviction against
+the prisoners.[31]
+
+Eleven cases of witchcraft were tried before Chief-Justice Holt, between
+1694 and 1701, but sentiment was changing toward this offense, by this
+time and this rugged and astute lawyer made such an appeal to the jury,
+in each case, that all the defendants were acquitted.[32]
+
+Jane Wenham, known as the “Witch of Walkerne,” was tried and convicted
+before Lord Chief-Justice Powell, in 1711, upon the most fanciful
+and ridiculous kind of evidence, but she was pardoned, before her
+execution.[33]
+
+In 1716, however, a woman and her daughter only nine years old, were
+tried and convicted of sorcery, at Huntingdon, because they had washed
+their stockings and made a lather of soap and raised a storm and for this
+terrible offense they were both hanged.[34]
+
+But this was the last judicial execution for witchcraft in England,
+although many prisoners were charged with the crime, between this date
+and the year 1736, when the statute of James I. was repealed.[35]
+
+While the delirium of witchcraft was raging in Europe,—until its victims
+numbered tens of thousands and its votaries millions,—the fever spread
+across the ocean and the New England colonists also fell a prey to the
+superstition. The fear of witchcraft and sorcery seized the multitudes in
+the United States, in the middle of the seventeenth century and supposed
+criminals were arrested in such numbers that the prisons were not large
+enough to hold them.
+
+The persecutions at Salem, Massachusetts, lasted from February until
+September, 1692, during which time, nineteen supposed witches were hung,
+fourteen of them being women.[36]
+
+Under the early statutes of New York and Pennsylvania, witchcraft was a
+capital offense.[37]
+
+The good William Penn, who fled from similar persecution in England,
+presided in the “City of Brotherly Love,” at the trial of two Swedish
+women, who were arraigned for witchcraft. The funeral pile had been
+prepared and the flint and tinder were all ready to burn them, but
+fortunately they were acquitted of the charge.[38]
+
+In Connecticut and Massachusetts, the penalty for witchcraft was death
+and the laws of these states were based not only upon the Mosaic code,
+but upon the Common Law of England, as well.
+
+A few trials occurred in Virginia and Maryland and six persons were hung,
+in Connecticut, for witchcraft, during the last half of the seventeenth
+century.
+
+Margaret Jones was executed for witchcraft, in Boston, in June, 1648;
+Mary Parsons, of Springfield, Massachusetts, was tried and convicted, in
+1651; Mrs. Ann Hibbins was executed in Boston, in 1656, and Goody Glover
+was executed at the same place, in 1688.[39]
+
+The history of the persecutions at Salem, Massachusetts, has furnished
+the basis for several books, presenting the harrowing details of the
+trial of the several victims of the crusade against the delusion of
+witchcraft, at that place.[40]
+
+The Salem persecutions began with the delusions of a party of young
+girls, who imagined they were bewitched. Elizabeth Parris, aged nine,
+the daughter of Rev. Samuel Parris, her cousin, Abigail Williams, aged
+eleven, Ann Putnam, aged twelve, the daughter of the parish clerk, Mary
+Walcott, Mercy Lewis, Elizabeth Hubbard and several other girls furnished
+the evidence upon which these persecutions were begun.
+
+After reading of witchcraft and magic, these children, who had worked
+themselves into a state of nervous excitement, began to cut queer
+antics, such as hiding in holes; crawling under chairs; assuming odd
+postures and uttering loud and incoherent expressions, all of which they
+attributed to the supernatural power exerted over them by three women
+of the neighborhood, Sarah Good, Sarah Osburn and an Indian woman named
+Tituba. Acting under the license of witchcraft, these girls disturbed
+religious worship, at will and performed other little misdemeanors,
+which their doting parents laid to the door of the witches, instead of
+correcting them, as they should have done.
+
+Finally the three women were arrested and arraigned for the crime of
+witchcraft. They were unpopular and uncomely women, as Mrs. Upham shows,
+Mrs. Good having been abandoned by her husband and Mrs. Osburn being
+a poor unhappy woman, bed-ridden and suffering from nervousness and
+melancholia.[41] Tituba, the Indian woman, believed in witchcraft herself
+and had told the children stories of evil spirits until they firmly
+believed in her unnatural power.
+
+On March 1’, 1692, the trial was begun at the meeting house in Salem,
+before Esquires John Hathorn and Jonathan Corwin. Sarah Good was first
+examined and denied any communion with evil spirits and affirmed her
+service of God. No counsel was allowed the prisoners, as this was the
+custom according to the common law, in capital cases, unless the Court
+was in doubt, as the Judge was supposed to be the counsel for the
+prisoner.
+
+After having been tormented for some time, and believing her escape
+to lie only in the conviction of someone else, Mrs. Good accused her
+co-prisoner, Mrs. Osburn, and she was remanded to jail and Mrs. Osburn
+was brought before the court. Frail in body and feeble in her intellect,
+this poor woman, when interrogated by the pompous oracles of the law,
+could only protest her innocence and deny any communion with evil
+spirits, or any knowledge of the offense charged against her by her
+alleged accomplice.
+
+After this travesty of a trial, she was again committed to prison, where
+she was kept heavily chained, from March 7, until May 10’, when she died,
+her innocent soul being thus forever released from the unnatural and
+inhuman affliction heaped upon her body by her fellow-beings. The Indian
+woman, when she was examined, did not deny that the children had been
+bewitched, but she laid it all to the door of her co-defendants, Mrs.
+Good and Mrs. Osburn.
+
+The girls, when brought before the supposed witches, fell down and
+shrieked, in their excitement; if the prisoners clasped their hands, they
+screamed that they were pinched; when they bit their lips, they in turn,
+asserted that they were being bitten; they produced pins, which they said
+the witches had pricked them with and worked upon the morbid imagination
+of the assembly so that the trials of the witches were little less than a
+burlesque.[42]
+
+Martha Corey was arrested on the 19’ of March, 1692, and the evidence
+of her husband was used against her, to the effect that she had taken
+his saddle to keep him from attending church; that she sat up late at
+night and frequently kneeled on the hearth, as if in prayer, but uttered
+no word; that certain of his cattle had been afflicted and that one of
+their cats had had a fit. On such evidence as this, this good woman, was
+adjudged guilty and was one of the eight persons executed on the 22’ of
+September.[43]
+
+On April 19’, 1692, when he was over four score years of age, poor old
+Giles Corey was arrested for witchcraft, at Salem, and his case furnishes
+the only instance in the United States, where to avoid the attainder of
+his blood and the forfeiture of his estate, a prisoner obstinately stood
+mute and was “pressed to death.”
+
+His unfriendly course toward his wife and the attitude of two of his
+four sons-in-law in testifying against his wife, no doubt so worked upon
+his mind as to cause him to make a terrible expiation. He deeded all
+his property to his two favorite sons-in-law, William Cleeves and John
+Moulton, and decided to then stand mute and refuse to plead and let the
+law take its course.
+
+Of course he knew that the gates of justice were closed to him and that
+he would be convicted, although he was innocent, but he determined
+to defy the multitude and to withhold his plea, in order to save his
+property for his sons-in-law and to show his courage, in the supreme test.
+
+Longfellow, in his “New England Tragedies,” has described this feeble old
+man, withstanding the exhortations of his friends, in his determination
+to die the death of a martyr in an unjust cause, and one cannot read the
+graphic and realistic account of this tragedy, without feelings of the
+greatest compassion and admiration for this grand old stoic, of our own
+soil, who bravely suffered his body to be pressed until all life was
+extinct and whose soul took its flight from the open field, near the
+Howard street burial ground, in the village of Salem, on September 19’,
+1692.[44]
+
+In the case of the gentle Rebecca Nurse, even after her acquittal, by
+a jury, regularly empaneled and charged to try her for witchcraft, the
+frenzied populace “recalled the decision” and she was sentenced by the
+Court, to meet the demands of the mob; she was carted to the summit of
+Gallows hill, and hanged, on July 19’, and her case furnishes one of the
+most unjust instances of the “recall of a judicial decision” and one of
+the grossest travesties upon justice in the history of any country.[45]
+
+Because John and Elizabeth Proctor had absented themselves from the
+meetings, during the trials for witchcraft, they were finally accused
+and thrown in prison. He made a manly appeal for a trial at Boston, in
+a letter dated July 23’, 1692, addressed to Mr. Mather, Mr. Allen, Mr.
+Moody, Mr. Willard and Mr. Bailey, but all to no avail. His friends
+petitioned the Court; one of the girls who testified against them made
+a statement that she “must have been out of her head,” when she gave
+her evidence, as it was not true, but nothing could stem the tide of the
+current of rapidly rising prejudice and resentment prevailing, so after a
+farcical trial, he was convicted and executed on August 19’, 1692.
+
+His fearless defense of his good wife saved her life and two weeks after
+his death, she bore a baby in prison and it was no doubt due to her
+pregnant condition that she too, escaped the fury of the mob.[46]
+
+The trials of Bridget Bishop, Mary Easty, a sister of Rebecca Nurse, the
+Jacobs family, Martha Carrier and Philip and Mary English, Elizabeth
+How, Rev. George Burroughs, Sarah Wildes, Susanna Martin, John Williard,
+Alice Parker, Ann Pudeater, Margaret Scott, William Reed, Samuel Wardell
+and Mary Parker,[47] are all interesting and present the details of the
+most stirring tragedies the courts of justice in this country have ever
+enacted, but space in this chapter will not permit the detailed account
+of these various trials.
+
+From the earliest times, a great deal has been written upon the subject
+of witchcraft and sorcery, in the different languages of Europe. The
+delusion has furnished a theme for long and arduous treatises by
+scientist, divine and philosopher and the poet and novelist, has found it
+a fruitful source of inspiration for song and story.
+
+The works of Dr. Joseph Glanvil, chaplain-in-ordinary to Charles II., and
+R. Baxter, in his “Certainties of the Works of Spirits,” as vindications
+of the superstitions of witchcraft and sorcery, did much to spread the
+delusion, during the popularity of the superstition.
+
+Balthazar Bekker, a reformed Dutch clergyman, was the first to strike
+at the very foundation of the delusion, near the end of the seventeenth
+century; Hutchinson, in his historical essay on Witchcraft, in 1718,
+also took a skeptical view of the subject, and these men, with Weier and
+Reginald Scot, along with the sturdy advocates who defended the prisoners
+charged with witchcraft, and such judges as Lord Holt, in England, did
+much to discourage and overcome the belief in the fallacy.
+
+Burn’s lines to the “De’il” aptly express the popular notion of the time
+when the belief in spooks and evil spirits obtained:
+
+ “Ae dreary, windy, winter night,
+ The stars shot down wi’ sklentin light,
+ Wi’ you, mysel, I got a fright
+ Ayont the lough;
+ Ye, like a rash-bush, stood in sight
+ Wi’ waving sough.
+
+ The cudgel in my nieve did shake,
+ Each bristled hair stood like a stake,
+ When wi’ an eldritch stour, ‘quaick, quaick’,
+ Among the springs
+ Away ye squatter’d, like a drake,
+ On whistling wiggs.”
+
+The notion of the devil then was that he was a large, ill-shaped, hairy
+sprite, with long tail, horns, cloven feet and wings, as we so often see
+him pictured in the old representations.
+
+Before Milton’s time, he was believed to be a mere mischievous, ugly and
+petty spirit, who played fantastic tricks upon humanity, but Milton made
+of him the paragon of evil, not merely grotesque, but a fiend, whose
+power was all used for evil.[48]
+
+ “The other shape,
+ If shape it might be call’d that shape had none
+ Distinguishable in member, joint or limb;
+ Or substance might be call’d that shadow seem’d,
+ For each seem’d either,—black it stood as night,
+ Fierce as ten furies, terrible as Hell,
+ And shook a dreadful dart; what seem’d his head
+ The likeness of a kingly crown had on.
+ Satan was now at hand.”[49]
+
+From the history of Demonology and Witchcraft, as given in the works of
+Bodin, Bekker, Leloyer, De Lancre, Garinet, Mackay, Lecky, Nevins, Upham,
+Benson, Goodwin and Sir Walter Scott, demons of both sexes had existed
+in the world, ever since the fall of Adam. They increased and multiplied
+with wonderful rapidity; inhabited the air and had no fixed residence or
+abode, and when they congregated, windstorms, hurricanes and earthquakes
+resulted. They were supposed to delight in destroying the beauties of
+nature and the possessions of man and entered the bodies of individuals
+with their breath and caused pains and sickness and bad dreams. All
+these demons were at the command of any person who would barter his soul
+to them and his or her evil purpose was then accomplished, but no good
+action would be undertaken.
+
+In France and England the witches were supposed to ride astride
+broom-sticks, while in Italy and Spain, the Devil, himself, in the shape
+of a goat, carried them on his own back.[50]
+
+This belief prevailed for many centuries all over Europe and in certain
+sections of the world the belief in witchcraft and sorcery is not
+entirely eradicated today.[51]
+
+In 1627, a ballad entitled the “Druten Zeitung,” or “Witches Gazette”
+was quite popular in Germany. The sufferings of the witches burned at
+Würzburg, Bamberg, Franconia and other cities and provinces of the German
+Empire, were minutely described, by the poet, who grew quite witty in his
+descriptions of the contortions produced by pain, when the flames brought
+forth shrieks from the poor wretches who were burned alive.[52]
+
+The “Amber Witch,” by William Meinhold, being the most interesting
+trial for witchcraft, of Mary Schweidler, is one of the most exceptional
+and interesting of the books of fiction, based upon the delusion of
+witchcraft.
+
+But let us draw the curtain upon this continuous human tragedy enacted
+for two and a half centuries, in Europe, in the name of the law,
+cataloguing the long list of judicial murders, upon the stage where
+superstition and delusion alone held sway.
+
+It is sad, in the extreme, to contemplate the long list of human beings
+whose lives were forfeited, in the early days of “little knowledge,” by
+those who thus:
+
+ “Hoped to merit Heaven, by making earth a Hell.”
+
+And it is doubly sad, to contemplate that the Temples of Justice were
+peopled by these fears of fantasy and the imagination—like some of the
+fetishes that modern critics of our present judicial system erect in
+some places—and that the high priests of the temples blindly followed
+the mad cry of the mob and laid aside the scales of justice to interpret
+the unjust ideals of an intoxicated public sentiment, following only the
+red flag of murder. These jurists of the past centuries who participated
+in this wholesale slaughter of individual right, may have feared their
+recall, if they withstood the frenzy of a wrought-up public clamor, and
+in this a lesson can be learned, of the danger of following the demands
+of public sentiment, in courts of justice, instead of the proper ideals
+of equality and justice.
+
+It is fortunate that only the small percent of the densely ignorant
+now-a-days, account for the misunderstood facts and phenomena of nature
+by the fears and delusions of witchcraft and sorcery and that in the
+progress of the race, the delusion of witchcraft has been crowded into
+the dark, remote and rugged sections where alone the foot of civilization
+can find no resting-place.
+
+There are few, if any, more deplorable episodes, in human history than
+that of the persecutions for witchcraft. They illustrate to what an
+extreme degree of relentless cruelty human nature will go, when fanned
+to a fever-heat of excitement by some fanatical delusion. On the other
+hand, the history of the persecutions for witchcraft show how little
+reliance can be placed upon the credibility of witnesses, influenced
+by some general excitement, or acting under a mistaken belief of duty,
+based upon the attainment of some popular object. Thousands of witnesses
+who appeared against the poor victims charged with this hated crime of
+witchcraft and sorcery, honestly believed in the fantastical delusions
+and tricks of fancy that they described as actual occurrences, which in
+fact had no better foundation than their own fervid imaginations.
+
+Regarding man’s self, alone, it is difficult to reconcile the beneficent
+laws taught by the church, with the sad “scope and scheme” of things,
+as disclosed by the pathetic facts of history, in connection with this
+subject. And yet:
+
+ “You cry ‘the cruelty of things’ is mystery to your purblind eye,
+ Which fixed upon a point in space, the general project passes by.
+ ...
+ The dreadest sound man’s ear can hear, the war and rush of stormy wind
+ Depures the stuff of human life, breeds health and strength for
+ humankind.
+ And thus the race of Being runs, till haply, in the time to be,
+ Earth shifts her pole, and Mushtari men another falling star shall see.”
+
+
+FOOTNOTES:
+
+[1] II. Mackay’s “Memoirs of Delusions,” pp. 169, 170.
+
+[2] _Ante idem._
+
+[3] Johns’ “Oldest Code of Laws,” 1; Scheil’s “Tome IV. Textes
+Elamites-Semitiques,” etc., Johns’ “Babylonian and Assyrian Laws,
+Contracts and Letters.”
+
+[4] _Ante idem._
+
+[5] II. Mackay’s “Memoirs of Delusions,” p. 169; Exod. XXII. 18. As
+Mackay shows, the sublime hope of immortality, in the early days of
+“little knowledge” became the source of a whole train of superstitions,
+from which fount a deluge of blood and horror poured over Europe, for two
+and a half centuries. “Memoirs of Delusions,” vol. II., p. 168.
+
+[6] Niebuhr’s Lecture, Roman History (English Tr.), vol. I., pp. 295,
+319; George Long’s article “Lex,” in Smith’s Dictionary of Greek and
+Roman Antiquities; Mommsen’s History of Rome (English translation), vol.
+I., book I., ch. II. and book II., ch. 2.
+
+[7] _Codex Justin. lib. ix, tit. 18._
+
+The “Dialogue on Witches and Witchcraft,” published by the Percy Society
+from the literature of the middle ages, presents the reasons and basis
+for the belief in Witchcraft, “in which is layed open how craftily the
+divell deceiveth not onely the witches, but many other, and so leadeth
+them awrie into manie great errours, By George Giffard, Minister of God’s
+word, in Malden, published in 1603.”
+
+In this Dialogue, Daniel quotes Christ’s words, as reported by Marke,
+that his name is “Legion, for we are many,” as evidence of the existence
+of “multitudes and armies of divels, as we see in the Gospel.” The
+command of the Mosaic law “Thou shalt not suffer a witch to live,” is
+quoted as a sufficient reason for rooting them out; the words of Moses
+are quoted that the Lord would cast out those nations that hearkened unto
+soothsayers and diviners, pronouncing that every one that does those
+things are an abomination to the Lord; that the Lord not only declared
+that such as practiced witchcraft and sorcery were an abomination before
+the Lord, but that they should “also bee rooted out.” (Percy Society Pub.
+vol. VIII., 24, 40, 42, 52, 72.)
+
+The belief that cats were bewitched to do the bidding of the devil, which
+formed such a large part of the delusion of witchcraft, as practiced in
+the middle ages, is also touched on, in the “Dialogue on Witches,” in the
+above interesting publication, from the literature of the middle ages
+which can be read with much amusement and entertainment, because it gives
+in realistic hue, a vivid pen picture of the old delusion, just as it
+existed in the early days of the seventeenth century.
+
+[8] Cnut, II., 4; Lea. _op. cit._ iii. 420; Brunner D. R. G. ii. 678; II.
+Pollock and Maitland’s History English Law, p. 553.
+
+[9] Leg. Hen. 71; II. Pollock and Maitland’s History English Law, 553.
+
+[10] II. Pollock and Maitland’s History English Law, p. 553.
+
+[11] II. Pollock and Maitland’s History English Law, p. 553.
+
+[12] Garinet’s “Histoire de la Magie en France.”
+
+[13] _Ante idem._
+
+[14] Dr. Sprenger, in his “Life of Mohammed,” computes the entire number
+of persons who were burned as witches, during the _Christian epoch_, as
+about _nine million_.
+
+Tasso attributed the belief in magic and witchcraft to the Crusaders, but
+M. Michaud, in his “History of the Crusades,” denies that the Crusaders
+believed in witches. However, the edicts of Charlemagne demonstrate quite
+conclusively that Tasso was right, for the Crusaders, in common with the
+millions of their contemporaries who were votaries of the delusion of
+witchcraft and sorcery, attributed the misunderstood facts in the natural
+world about them, to supernatural powers of magic.
+
+[15] Mackay’s “Memoirs of Delusions,” vol. II., p. 186.
+
+[16] Monstrelet’s Chronicle.
+
+[17] II. Mackay’s “Memoirs of Delusions,” p. 194.
+
+[18] Mackay’s “Memoirs of Delusions,” vol. II., p. 195.
+
+[19] _Ante idem._, p. 197; Danaeus, “Dialogues of Witches.”
+
+[20] Mackay’s “Memoirs of Delusions,” vol. II., p. 199.
+
+[21] The ignorant Canadian French still believe in the Loup-garou, just
+as the French did in the centuries gone by.
+
+[22] Mackay’s “Memoirs of Delusions,” vol. II., p. 201.
+
+[23] Hutchinson, on Witchcraft.
+
+In the year 1670 a number of women were condemned by the Parliament of
+Normandy, for riding broom-sticks to the Domdaniel. Louis XIV., commuted
+their sentences to banishment for life, when the Parliament of Rouen
+presented to him a memorial, insisting that he set aside the order for
+their commutation, but the wise King stood firm and refused to let them
+be judicially murdered in his kingdom. (For this memorial in full, see
+II. Mackay’s “Memoirs of Delusions,” pp. 289, 298.)
+
+[24] II. Mackay’s “Memoirs of Delusions,” p. 226.
+
+[25] Very severe statutes were passed during the reign of Elizabeth,
+against the imaginary crime of witchcraft and sorcery. The statute 33
+Henry VIII. c. 8, was repealed by I. Edward VI., c. 12 and as this left
+no law in force to punish this class of offenders, it was enacted by
+5 Elizabeth, c. 16, that if any person used or practiced witchcraft,
+enchantment, charm or sorcery, whereby any one shall happen to be killed
+or destroyed, it shall be felony, without clergy. And if anyone thereby
+be wasted, consumed, or lamed, in body or member, or any of his goods
+destroyed or impaired, such offender shall be imprisoned for a year, and
+stand in the pillory once a quarter, during that time for six hours. (V.
+Reeve’s History English Law, p. 349.)
+
+[26] See “Butlers Hudibras,” edition by Dr. Zachary Gray (vol. II).
+
+[27] Mackay’s “Memoirs of Delusions,” vol. II., p. 237.
+
+[28] Lecky’s “Rationalism in Europe,” vol. I.
+
+[29] Lecky’s “Rationalism in Europe,” p. 146, vol. I.
+
+[30] II. Mackay’s “Memoirs of Delusions,” p. 248.
+
+[31] II. Mackay’s “Memoirs of Delusions,” pp. 253, 254.
+
+[32] _Ante idem._
+
+[33] II. Mackay’s “Memoirs of Delusions,” p. 255.
+
+[34] II. Mackay’s “Memoirs of Delusions,” p. 258.
+
+While this hideous record of blood and murder, in the name of the law,
+was being recorded in England, during the seventeenth century, a similar
+record was being written, in the criminal courts of Spain, Italy,
+Scotland and Germany. Thousands of innocent people lost their lives under
+this charge in these countries, during this century.
+
+As an illustration of this mad carnival of death, in Würzburg, alone in
+the two years following 1627, one hundred and fifty-seven people were
+burned, in twenty-nine burnings, averaging from five to six people at a
+burning. The wealthy and the paupers, old and young, the ungainly and the
+comely, all alike suffered in this unholy crusade.
+
+Of the list there were three play-actors; four innkeepers; three
+councilmen; fourteen vicars; the burgomaster’s lady; an apothecary’s wife
+and daughter, the wife, sons and daughter of the councillor Stolzenberg
+and Gobel Babelin, “the prettiest girl in the town,” thirty-two vagrants
+and a large number of little innocent children, who were guilty of
+no offense or crime other than that of living in a period when their
+innocence was considered a crime. (Hauber’s “_Acta et Scripta Magica_.”)
+
+[35] II. Mackay’s “Memoirs of Delusions,” p. 258.
+
+[36] Upham’s “Salem Witchcraft, in Outline”; Nevin’s “Witchcraft in Salem
+Village.”
+
+[37] Upham’s “Witchcraft in Outline,” p. 6.
+
+[38] Upham’s “Witchcraft in Outline,” 6.
+
+[39] The trial of Mary Dyer, Quaker, is presented in “Two Letters of
+William Dyer,” 1659-1660.
+
+[40] Upham’s “Salem Witchcraft”; Nevin’s “Witchcraft in Salem”; Moore’s
+“History of Witchcraft in Massachusetts.”
+
+[41] Upham’s “Salem Witchcraft,” pp. 25, 26.
+
+[42] Upham’s “Salem Witchcraft,” pp. 44, 45; Nevin’s “Witchcraft in
+Salem,” 46, 69.
+
+[43] Upham’s “Witchcraft in Outline,” 61.
+
+[44] _Ante idem._, p. 69.
+
+[45] Rose Terry Cooke, in her, “Death of Goody Nurse,” thus describes the
+death of this good woman:
+
+ “They hanged this weary woman there,
+ Like any felon stout;
+ Her white hairs on the cruel rope
+ Were scattered all about.”
+
+[46] Upham’s “Salem Witchcraft,” p. 87.
+
+[47] Upham’s “Salem Witchcraft,” pp. 142, 143; Nevin’s “Witchcraft in
+Salem,” pp. 70, 253.
+
+[48] See article on “Demonology,” in Foreign Quarterly Review, London,
+1840.
+
+[49] Paradise Lost, book ii, Line 666.
+
+[50] II. Mackay’s “Memoirs of Delusions,” p. 178.
+
+[51] Many of the ignorant Canadian-French still believe in the delusions
+of the loup-garou, or man wolf, and in the southern portion of Nigeria,
+as recently shown by P. Amaury Talbot, superstition and witchcraft
+lurk in all the forests and lakes of the country. Describing these
+superstitions, in a recent article in the London Telegraph, Mr. Talbot
+says:
+
+“The bush with its soft green twilight, dark shadows, and quivering
+lights, is peopled by many terrors, but among these ‘Ojje’, or
+witchcraft, reigns supreme. The bird which flies in at your open door
+in the sunlight, the bat which circles round you at night, the small
+bushbeasts which cross your path while hunting, all may be familiars of
+witch or wizard or even the latter themselves, disguised to do you hurt.
+Sometimes the terror of witchcraft will scatter a whole town.”
+
+And for belief in witchcraft, among the southern darkies, see Journal of
+American Folk Lore, vol. III., p. 205; Bruce’s “Plantation Negro as a
+Freeman”; and Jones’ “Negro Myths from the Georgia Coast.”
+
+[52] II. Mackay’s “Memoirs of Delusions,” p. 277.
+
+
+
+
+CHAPTER III.
+
+RECALL OF JUDGES.
+
+
+ “Of all the virtues, Justice is the best,
+ Valour without it is a common pest.
+ ...
+ All other virtues dwell but in the blood,
+ That in the soul, and gives the name of good;
+ Justice, the queen of virtues.”—Waller.
+
+Judge is the generic descriptive name given to one who is invested with
+the power of judging and deciding causes in the courts of law. The
+recall, as applied to the judiciary, is the withdrawal of the power given
+a judge to decide causes.
+
+As justice has always been the great interest of man, on earth, we find
+that the virtue has ever been extolled, as one of the greatest blessings
+of the human race and among the earliest institutions of which we have
+any knowledge, we find that courts were constituted, for the distribution
+or enforcement of justice, through the medium of judges.[1]
+
+The great law-giver, Moses, having learned the hard lesson from the
+book of human life, early grasped the truth that man’s nature needed
+protection from its own impulses and passions, and that an exalted
+rule of conduct, commanding what was right, to be effective, must be
+enforced and interpreted, by a wholly disinterested guiding influence. He
+accordingly established the administration of justice, among the ancient
+Israelites, by choosing “able men, out of Israel, such as feared God,
+men of truth, hating covetousness; and made them heads over the people,
+rulers of thousands, rulers of hundreds, rulers of fifties, and rulers
+of tens; and they judged the people at all seasons; the hard causes they
+brought unto Moses, but every small matter they judged themselves.”[2]
+
+Grasping, even at this early day at the exalted standard, later realized,
+in the Horatian ideal, “of the just man, who, firm in the consciousness
+of right, disdains, with equanimity, the frowns of a tyrant and the
+clamors of a mob,” we find this old patriarch, fifteen centuries before
+Christ, admonishing the judges of the Israelites:
+
+ “Thou shalt not follow a multitude to do evil; neither shalt
+ thou speak in a cause, to decline, after many, to wrest
+ judgment.”[3]
+
+Admonishing the judges, further, in regard to being swayed in their
+decisions, by the fickle winds of public sentiment, Moses said:
+
+ “Ye shall not respect persons in judgment, but ye shall hear
+ the small as well as the great; _ye shall not be afraid of the
+ face of man_; for the judgment is God’s; and the cause that is
+ too hard for you, bring it unto me and I will hear it.”[4]
+
+And not content with warning the judges of the danger of fearing the
+people, in the act of pronouncing judgment, he also warned the people of
+the duty of respecting the judgments of the courts, in the following wise
+commands:
+
+ “And thou shalt come unto the Priests and Levites, and unto
+ the Judge that shall be in those days and inquire; and they
+ shall shew thee the sentence of judgment. And thou shalt do
+ according to the sentence, which they of that place which the
+ Lord shall choose, shall shew thee; and thou shalt observe to
+ do according to all that they inform thee. According to the
+ sentence of the law which they shall teach thee, and according
+ to the judgment which they shall tell thee, thou shalt do;
+ thou shalt not decline from the sentence which they shall shew
+ thee to the right hand, nor to the left. And the man that will
+ do presumptuously, and will not hearken unto the priest that
+ standeth to minister there, before the Lord thy God, _or unto
+ the Judge_, even that man shall die and thou shalt put away the
+ evil from Israel. And all the people shall hear and fear, and
+ do no more presumptuously.”[5]
+
+It thus appears that the ancient Israelites appreciated the virtue known
+as Justice and more nearly approximated the cultivated ideal existing
+in more recent times, for they understood, or Moses did, that it was
+indispensable, in the act of dispensing justice, for the incumbent of the
+judgment seat, to rise superior to the popular standards of justice and
+equality and that the due and orderly realization of the virtue could
+only be realized by a proper regard and respect for the judgments of the
+courts when they were pronounced.
+
+In this respect, the old patriarchs were in advance of the ancient
+Babylonians and Athenians, for while attempting the distribution of
+justice, through the medium of disinterested judges, they did not seem to
+grasp the necessity for an independent judiciary, but upon unjust grounds
+they permitted the recall and debasement of their wisest judges.
+
+In the oldest Code of Laws in the known world, the code of Hammurabi,
+King of Babylon, 2285 B. C.,[6] who claimed to have received his laws
+from the seated sun-god, Samas, the “judge of heaven and earth;”—an old,
+Mosaic bearded king, as represented to us, from the dark ages, upon
+the black block of diorite, presenting also his Code of Laws; known to
+history as the Babylonian king, who conquered the four quarters of the
+earth; who enriched Ur (Father Abraham’s birthplace), the humble, the
+reverent, who clothed the gravestones of Malkat with green; the warrior
+who guarded Larsa and renewed Ebabbar; the Shield of the land who united
+the scattered inhabitants of Isin; who firmly founded the farm of Kish;
+the White Potent one who penetrated the secret cave of the bandits; one
+who recognizes the Right and who Rules by Law; who humbles himself before
+the great gods[7]—this valiant one of the misty ages of long ago, in his
+Code, after providing for the death of the man who should weave a spell
+or put a ban upon another man, in the fifth section of his Code of Laws,
+provided for the recall or removal of the judges of his courts, by the
+following provision:
+
+ “If a judge has judged a judgment, decided a decision, granted
+ a sealed sentence, and afterwards has altered his judgment,
+ that judge, for the alteration of the judgment that he judged,
+ one shall put him to account and he shall pay twelve-fold the
+ penalty, which was in the said judgment, and in the assembly
+ one shall expel him from his judgment seat, and he shall not
+ return, and with the judges at a judgment he shall not take his
+ seat.”[8]
+
+Petitions and motions for a rehearing were thus interdicted by Hammurabi,
+regardless of the mistakes entering into the judgment, which could only
+be righted by a rehearing, or a new trial, and if a new trial were
+granted, the judge was publicly disgraced and recalled and was never
+allowed to sit in judgment again.
+
+So unalterably opposed were the ancient Babylonians to the granting of
+a new trial, that if a decision for the infliction of a penalty were
+set aside, the judge had to pay it twelve-fold to him from whom it was
+exacted and for any new trial granted by him, the judge was publicly
+deposed from his office and expelled from his seat of judgment and no
+longer permitted to sit with the judges. According to the strict letter
+of the Code, it was no justification for the judge to be able to show
+that the new trial was granted to prevent a miscarriage of justice, for
+as the law reads, a judgment once pronounced was irrevocable, for that
+judge, at least.[9]
+
+But let us look more minutely into the procedure, governing the right of
+litigants in the days of Hammurabi. It was the prerogative of the King,
+during the First Dynasty, to send to the local judges his own decision of
+a cause, or to simply send the case to them for trial.
+
+Trials were held in the great temple of Ebabbarim, at Sippara, where
+copies of his code had been set up by Hammurabi, at the temple of
+Merodach in Babylon, at the temple of Sin, at Larsa, or the temple of
+Ishhara. Witnesses, it seems, were sworn, before God and the King, to
+swear to the truth, touching the controversy, and documentary evidence
+was used, much as it is today, to establish a right or title by written
+evidence, or the agreement of the parties.[10] Having ascertained where
+the right resided, it was the peculiar province of the judge to “cause
+them to receive judgment”; the strife was accordingly quieted and the
+judgment passed into an irrevocable decree, which the judge himself
+could not set aside, without thereby working his own disgrace and
+recall.[11] The decision was drawn up by the scribe and placed upon a
+tablet, sealed by the judge and some of these irrevocable tablets, as
+imperishable conclusions of these ancient law-suits have come to us,
+after thousands of years, to tell their tale.[12]
+
+This recipient of the wisdom of the sun-god, Hammurabi, did not stop
+with humiliating and degrading the upright judge, who, to right a wrong
+judgment was willing to admit his error to the advantage of a wronged
+litigant, by granting a new trial, but in keeping with such a mistaken
+standard, the Code of this ancient ruler of the Babylonians also punished
+the unsuccessful surgeon, by removing the hand that performed an
+unsuccessful operation;[13] by penalizing the unsuccessful veterinarian,
+who lost his neighbor’s cattle or horse;[14] the builder was made liable
+for all damages resulting from the fall of a building he had erected[15]
+and, in general, it was the policy of this strict king, to raise the
+standards of public duty, by punishing the incumbents of public office
+and penalizing the members of the learned professions and vocations,
+rather than cultivating the higher standards of the professions, by the
+elimination of the unskilled therefrom.
+
+The ancient Greeks also practiced the recall and ostracism of their most
+eminent judges and other powerful public officials, who incurred the
+ill-will of the populace, because of some unpopular decision, or the
+envy of any considerable number of citizens, because of some alleged
+undemocratic performance.
+
+This ostracism, or recall, in Greece, is said to have been established by
+Cleisthenes after the expulsion of the Peisistratidae[16] and the nature
+and object of the recall, as then obtaining, is thus explained by the
+philosopher Aristotle:
+
+ “Democratical states _used to_ ostracise and remove from the
+ city for a definite time, those who appeared to be preeminent
+ above their fellow citizens, by reason of their wealth, the
+ number of their friends, or any other means of influence.”[17]
+
+The removal and ostracism of public officers, in Greece, does not seem
+to have been used as a punishment for any crime or particular unfitness
+developed by the official removed, but rather as a precautionary measure,
+to dispense with the services of those who became so powerful as to
+excite the fear or attract the envy of their contemporaries.[18]
+
+The procedure whereby the recall or ostracism of a judge or other public
+official was accomplished, in ancient Greece, was as follows: A space
+was enclosed by barricades, with ten entrances, for the ten tribes. The
+tribesmen entered the enclosed space, by these ten entrances, each with
+a shell, or piece of earthenware, on which he wrote the name of the
+official he wished recalled or degraded. The casting and enumeration of
+the vote was regulated and supervised by the presidents dents of the
+Senate and by the nine archons, and if as many as 6000 votes against any
+one official was polled, this _ipso facto_ removed him from office and
+he was obliged to leave the city of his residence within ten days from
+that date; but if the total number of votes cast against him did not
+equal 6000 he was not removed from office.[19] Because of the shell, or
+piece of earthenware, upon which the vote was cast against the official
+removed from office, the proceeding came to be known as the “earthenware
+scourge.”[20]
+
+By this proceeding, in ancient Greece, some of the most distinguished
+men of the nation were removed, or ostracised, but when it was found
+that their services were indispensable to the public welfare, they were
+recalled to office. Cimon, Alcibiades, Themistocles, Aristeides and
+many other prominent citizens suffered this degradation in Athens and
+other democratical states, in Greece, for the recall was considered as a
+necessary precaution to ensure absolute equality among the citizens of
+the various commonwealths.
+
+As a concrete illustration of the application of the recall to the
+judiciary, in Greece, we will take the case of Aristeides, known as
+“Aristeides the Just.” There is authority for the statement that the
+judicial integrity and ability of this old Greek patriot was so generally
+recognized, in Athens, that during the presentation of one of the
+tragedies of Eschylus, when one of the characters was referred to as
+a man who “cared more _to be just_, than to appear so,” all eyes were
+instantly turned toward Aristeides, as the one man, who, of all other
+Greeks, most merited the title of “The Just,” and from this time on
+this truly royal, or divine appellation, according to Plutarch, was, by
+universal consent, attributed to this virtuous man.[21]
+
+This remarkable distinction aroused envy against Aristeides and it is
+reported that Themistocles circulated a rumor that by determining and
+judging causes in private, he was undermining the courts of judicature
+and was secretly making way for a monarchy in his own person, so the
+jealousies of the populace were so aroused against him that it was
+decided to recall this upright judge. Plutarch relates the pathetic
+circumstance, connected with the degradation and ostracism of this
+Just Judge, that while the voting was taking place, in the railed
+market-place, Aristeides was approached by an illiterate citizen, who
+handed him his _ostracon_, or sherd and directed him to write his own
+name upon the shell. Without disclosing his identity, Aristeides asked
+the man if the Judge had ever done him any injury, when the voter
+replied: “None at all, neither know I the man; but I am tired of hearing
+him everywhere called _The Just_.”[22]
+
+Aristeides made no reply to the man, but wrote as he directed and
+returned the sherd to him, with his name written upon it. The six
+thousand votes, necessary to procure his removal, or recall, having been
+polled, he departed from his beloved Athens, praying, with uplifted
+hands, that the Athenians might never have occasion to remember
+Aristeides.[23]
+
+The ostracism of Aristeides did not last for the ten years, for which his
+punishment was decreed, under the Grecian law, however, for three years
+later, when the Persian king, Xerxes, invaded Greece, Aristeides returned
+and when the Persians were overcome he was completely reinstated in the
+good graces of his countrymen and took a leading part in the affairs of
+the government of Athens, without resentment, for he sought no other
+gratification than that of serving his country with fidelity and honour.
+
+Themistocles was another of the great citizen jurists of Athens to suffer
+the recall or ostracism, by popular vote, while this ancient law obtained
+in Greece.
+
+As an index to the character and uprightness of this distinguished
+Athenian, it is reported that before entering upon the trial of a cause
+in which the poet Simonides, of Ceos, was interested, when requested,
+by his friend, to overlook the underlying principles of the law, in the
+consideration of the cause, this virtuous judge replied:
+
+ “Simonides, you would be a bad poet, if your lines ran counter
+ to the just measure and rules of your art, nor should I be a
+ good magistrate, if, for favor, I made false law.”[24]
+
+Notwithstanding the signal and loyal services of this patriotic citizen
+in the war with the Persians and his long service as a magistrate, when
+Themistocles finally erected his temple of Diana of Best Counsel, with
+himself represented by a figure in the temple, the Athenians also became
+envious of him and made use of the law providing for the recall and
+ostracism in order to humble his eminence and authority, as they usually
+did with all those whom they believed to have grown too powerful, for
+the equality deemed requisite in a popular government, for, as said by
+Plutarch:
+
+ “The ostracism was instituted not so much to punish the
+ offender, as to mitigate and pacify the violence of the
+ envious, who delighted to humble eminent men, and who, by
+ fixing this disgrace upon them, might vent some part of their
+ rancor.”[25]
+
+According to Aristotle, the law providing for the recall or ostracism of
+public officials, by popular vote, in Athens, soon became mischievous,
+for:
+
+ “Men did not look to the interests of the community, but used
+ ostracism for party purposes.”[26]
+
+The last person against whom this old law was enforced at Athens, was
+Hyperbolus, a demagogue of low birth and mean habits; the Athenians
+considered that in applying this law to such a person, their own dignity
+had been compromised, so the law providing for ostracism or recall, by
+popular vote, in Athens, was discontinued.[27]
+
+The law providing for the recall or ostracism of public officers, by
+popular vote, known as “Petalism” among the Syracusans, was borrowed from
+the Athenian law of ostracism. This species of recall, took its name from
+the petals or leaves of the olive, on which was written the name of the
+person whom the citizens voted to recall.[28]
+
+Under the law of the Syracusans, known as “petalism,” the removed officer
+or judge was banished for a period of five years only, as this was
+considered a sufficient length of time to humble the pride and destroy
+the hope of the degraded one.
+
+Historians tell us, however, that this law of recall known as “petalism,”
+by which the Syracusans voted to recall their distinguished men, by
+writing their names upon the corolla, or leaf-part of the olive, did
+not long continue in effect, since the fear of this “degradation or
+humbling,” deterred the best qualified among the citizens from taking
+any part in public affairs, and the degeneracy and bad government which
+resulted from the selection of only the lowest types of demagogues for
+public officers, led to the repeal of the law, B. C. 452.[29]
+
+In the early Roman days the custom also obtained of submitting to the
+people, by popular vote, the determination of accusations against judges
+and other public officers, as matters of general public interest and
+the _judicia publica_ of later times owed its existence to this antique
+custom. Preators, or those invested with judicial functions were no
+exception to the general rule, but all classes of public servants were
+directly responsible to the Roman people and were liable to be called
+upon, at any time, to answer to a charge which might mean banishment or
+death.
+
+In the early days of the Republic, every act of a citizen which was
+deemed injurious to the State, or its peace, was called perduellio,
+and the offender (perduellis) was tried before the forum of public
+sentiment (_populi judicio_) and, if convicted of any violation of the
+obligations he owed to the State, he was put to death.[30] The crime
+known as _Majestas_, corresponding to the English charge of treason, was
+apt, at any time to be preferred against the most upright public servant
+and the opinions of the populace were found frequently at variance with
+the justice of the cause. Justice was not always found to be consistent
+with the expressed will of the multitude of Roman citizenship, for
+their opinions were not always shaped or controled by the most exalted
+standards of equality. Unpopular officials were frequently condemned,
+regardless of the reason for the unpopularity, while the able orator or
+popular citizen, was usually successful in his cause.[31]
+
+Under the empire, judicial magistrates, such as Preators, were removed,
+at the will of the Emperor, and we find that while Julius Caesar had
+appointed sixteen, to settle the disputes of the Romans, Augustus
+peremptorily removed four and thus reduced the number to twelve.[32]
+
+The early Anglo-Saxons, like the Israelites of patriarchial days, while
+recognizing that the power of distributing or enforcing justice, was
+primarily lodged with the people, as a whole, constituting the great body
+of society, understood the impossibility of administering justice, in
+the concrete, by delegating the performance of such important functions,
+without investigation or the understanding of correct ideals, to the
+great unskilled mass of the people, in their collective capacity, so apt
+to be carried away, in such matters, by variable sentiments, or whims
+or caprices, based upon impulses, not always consistent with the proper
+standards of right.
+
+In order to insure the rendition of justice to every individual, or to
+approximate as nearly as might be, to this object, this important power
+was committed, therefore, at a very early day, in England, to specially
+selected magistrates, possessing peculiar skill and fitness to hear and
+determine causes in courts of law and qualified, by study and training to
+discharge these difficult public functions with certainty and expedition,
+according to correct standards.
+
+Following the beneficent policy, illustrated by the old Mosaic code, of
+bringing justice home to every man’s door, as nearly as may he, it was
+the general plan of Anglo-Saxon society, as designed and shaped by the
+great King Alfred and other early kings, to have such a system of courts
+as would speedily dispense justice to all the people, under the various
+conditions of society. Anglo-Saxon courts did not have the means of
+compelling obedience to their mandates for the majesty of the law was not
+the rule implicitly followed by all classes, in the beginning, but before
+many centuries, following King Alfred’s time, we find that it had become
+the fixed rule of life.[33]
+
+From the early _gemot_, of the Anglo-Saxon period, we soon find the
+regular county court and hundred court, where poor and rich alike were
+entitled to receive justice, without price and without delay.[34] The
+expeditious court of _piepoudre_, (the dusty foot court)—which dispensed
+justice as speedily as dust falls from the foot[35]—furnished speedy
+justice for small cases, while the _curia regis_, established by William
+the Conqueror, held in the royal palace, presided over by the king
+himself and his chief justiciar, with court barons, presided over by
+the lords of the realm, furnished, for many centuries a complete system
+of judiciture for the hearing of the ordinary causes in the realm.[36]
+The King was the fountain of justice and it was his business to see
+justice done, where the litigant failed to get his cause heard in the
+jurisdiction of his own hundred. Of course as a natural result of such
+a policy, the right of dispensing justice and receiving the profits
+thereof, under the Normans, soon became hereditary rights, passing to
+successive lords, whose judgments were supreme, unless the King himself
+ordered the entering of a certain judgment.[37] The Court of King’s
+Bench, the Court of Common Pleas and the High Court of Chancery, by
+gradual processes of time, succeeded to the principal places among
+the courts of later centuries, with the establishment by Henry II., A.
+D. 1176, of the _justices itinerant_, who divided the realm into six
+circuits and afterwards followed a fixed judicial system.[38]
+
+From the reign of William the Conqueror, until that of King John, the
+administration of Justice was still kept in the hands of the king, who
+was regarded as the source of all justice and law; after the conquest,
+the various prerogatives of the crown were increased and it was during
+this precarious state of the law that the subjects were obliged to
+purchase the favor of the sovereign, in order to obtain justice in the
+king’s courts.[39]
+
+So dependent upon the will of the sovereign was the tenure of the judge,
+during the reign of Richard I., that we find William de Longchamp, chief
+justiciary and chancellor, was removed from his office, by the intrigue
+of John, Earl of Morton, the king’s brother.[40]
+
+Judges were then but the servants of the king and he could move them
+about as mere pawns upon the chess board of his own expediency,
+or dismiss them, at a moment’s notice, if they refused to do his
+bidding.[41] Hubert de Burgh succeeded Hubert Walter and Geoffry Fitz
+Peter, as Chief Justiciar, but he seldom sat on the bench and was
+removed in 1232,[42] when the Chief Justiciarship was committed to a
+lawyer, named Stephen Segrave. The latter was disgraced and dismissed by
+the King, in 1234, just two years after his appointment and from this
+period until 1258, or until the revolution, the justiciarship was in
+abeyance.[43]
+
+In lieu of an appeal, or writ of error, which challenged the sufficiency
+or correctness of a record or judgment, instead of the judge himself,
+we find that from the time of Cnut, until the reign of Henry I., if a
+judgment was challenged the proceeding was what was known as that of
+“false judgment,” growing out of the practice of early Saxon days, when
+a litigant who was dissatisfied with a decision or “doom,” charged the
+doomsman who uttered it with falsehood.[44]
+
+Until the thirteenth century the exception to a given judgment or decree
+of an inferior court was tested by the charge of “false judgment.” The
+record was transferred from the inferior tribunal to the superior one by
+certain knights, appointed for the purpose. Frequently, these knights
+would challenge the litigant questioning the correctness of the judgment
+to trial by battle, to test the correctness of the decree[45] but if this
+were not done, and the issue upon the legality of the finding of the
+lower court thus determined, the justices of the king’s court proceeded
+to examine the record.
+
+If the King’s Justices found, on an examination of the record that the
+judgment of the county, the hundred or the manor, were wrong, a fine
+was assessed against the judge rendering the erroneous judgment and by
+a finding of “false judgment” a Lord lost forever the right to hold a
+court.[46]
+
+Here was a method of recall, almost as bad as that existing under the
+Babylonian Empire, for instead of removing the judge who attempted to
+right a wrong, he was removed before having been given the opportunity to
+get right.
+
+As late as the year 1219 we find that the justices in eyre were brought
+before the justices of the Court of King’s Bench, upon a charge of
+“false judgment,” for having unlawfully condemned a man to death and
+upon examination of the record by the Council, their judgment was set
+aside and they were amerced with a fine for having entered such a “false
+judgment.”[47]
+
+It is little wonder, with this harsh rule obtaining, that by the time of
+Edward I. history records that his justices had become extremely cautious
+men, unwilling to decide nice points of law but referring every close
+question to the Council for instruction.[48] The penalty of a mistake
+or “false judgment” to them meant not only a fine, but disgrace and the
+recall, if the King saw fit to so punish them, so this was not only
+calculated to make a man cautions, but to prevent those of skill and
+dignity from risking the expression of their judgment, when the penalty
+for a mistake was such that it might forever ruin the future life and
+hopes of the judge pronouncing judgment. The strange thing is that with
+such a system, any self respecting man could be found to undertake the
+performance of functions such as those required of a judge, when his
+behavior was the means of ruining his future life, regardless of his pure
+intentions in the performance of his official duty.
+
+The tenure of office of the English judge continued for centuries, to
+be at the pleasure of the Crown, and under the Plantagenets and the
+Tudors, a Chief-Justice even, might be removed, like any other officer
+of the King, at the pleasure of the sovereign,[49] and during this whole
+period we find that the standards of the judiciary were in keeping with
+this servile and undignified conception of the duties of such an office,
+for the judges, with but few exceptions, during this period of servile
+attachment to the Crown, were men of but mediocre ability, willing to
+prostitute their high offices, to hold the esteem and favor of their
+patron.
+
+It was thus found, by experience, in England, that the proper discharge
+of the impartial duties of the courts was consistent only with the
+maintenance, at all times, of their dignity and independence, hence, it
+was enacted, by statute, (13 William III., c. 2) that the commissions of
+judges were to be held, not as formerly, during the mere pleasure of
+the king, but so long as they should conduct themselves uprightly. They
+can only be removed from office, upon the address of both houses of
+Parliament and since the reign of George III., the commissions of judges
+are not terminated with the death of the king, but they continue to
+hold their office, notwithstanding the demise of the king, during their
+good behavior, or until removed by the joint action of both houses of
+Parliament.[50]
+
+And not only did the English law raise the incumbent of the judgment seat
+to a plane where he could view, with disdain the frowns of the tyrant
+in the performance of his official functions, but that he might also be
+free from the clamors of the populace, he was exempt from indictment for
+any judicial act honestly done, or omitted, while sitting as a judge. In
+other words, while acting in a judicial capacity, judges were not liable
+for an honest mistake, but only for fraud or corruption.[51]
+
+The judge is criminally and civilly liable, by the English common law
+for judicial acts willfully and maliciously done; for acts clearly in
+excess of his proper jurisdiction and for the wrongful exercise of a
+mere ministerial act, whether honestly done or not,[52] but this was the
+full limit of his liability and for honest mistakes in the performance
+of his duty, he was responsible to no one and could be troubled only by
+an accusing conscience for a mistake in the performance of a proper
+judicial function.
+
+Since the placing of the English judiciary upon this high plane where the
+courts are wholly above and beyond the spoils of party or the favoritism
+or fears of sovereignty, the respect paid to the majesty of the law
+in that country, has challenged the admiration of the world. English
+procedure is the pattern for the best governed countries on the earth
+and the decisions of her courts have come to be ideals to be followed by
+courts of other nations, seeking the attainment of justice.
+
+The patriot fathers, familiar with the mistakes of the ancients and
+the reasons for the establishment of the judicature of England, upon
+an independent foundation, in the establishment of the judicial system
+in the United States, adopted the method that history had commended to
+England, of life tenure, with the power of removal for actual misfeasance
+in office.
+
+It was therefore provided in the Federal Constitution that judges of
+the courts of the United States should hold their offices during good
+behavior and they were subject to removal, only by impeachment, like
+other civil officers of the Government.[53]
+
+The first Congress, in 1789, enacted the first federal judiciary act,
+formulated by Oliver Ellsworth, a member of the convention which framed
+the Constitution and afterwards Chief Justice of the Supreme Court.
+
+Speaking of this earnest patriot, Mr. Webster said that he was “possessed
+of the clearest intelligence and deepest sagacity as well as the utmost
+purity and integrity of character.”
+
+Upon the relative functions of the different branches of government and
+the necessity for an independent judiciary, Chief Justice Ellsworth said:
+
+ “If the general legislature should, at any time, overleap their
+ limits, the judicial department is a constitutional check. If
+ the United States go beyond their powers; if they make a law,
+ which the Constitution does not authorize, it is void; and the
+ judiciary power, the national judges, who, to secure their
+ impartiality, _are to be made independent_, will declare it
+ to be void. On the other hand, if the States go beyond their
+ limits, if they make a law which is a usurpation upon the
+ general Government, the law is void, and upright, _independent
+ judges_ will declare it to be so.”
+
+This, by the gentleman who reported the bill in Congress for the
+organization of the judicial department of the general Government,
+demonstrates that those who formed our Government and framed our
+Constitution, realized not only that the judgment seat should be
+dominated by “the cold neutrality of an impartial judge,” but that this
+essential prerequisite to the administration of justice, could not be
+obtained by a cringing judiciary, depending upon a vacillating public
+sentiment, as an index to its opinions, but would be effectuated only
+through the untrammeled judgment of an independent court.
+
+Next to Oliver Ellsworth, the man most active in the establishment of our
+Federal Judiciary, was perhaps Alexander Hamilton, and upon the reasons
+for an absolutely independent judiciary, this great lawyer, soldier and
+patriotic statesman, observed:
+
+ “This independence of the judges is equally requisite to
+ guard the Constitution and the rights of individuals from
+ the effects of those ill-humors which the arts of designing
+ men or the influence of particular conjunctures sometimes
+ disseminate among the people themselves and which, though they
+ speedily give place to better information, and more deliberate
+ reflection, have a tendency, in the meantime, to occasion
+ dangerous innovations in the Government and serious oppressions
+ of the minor party in the community.”[54]
+
+It was also clearly the object of the original thirteen colonies to
+remove the judiciary from politics and thereby establish the independence
+of the State Judiciary, as well as that of the Federal Government,
+for the Constitutions of each of the original colonies provided for
+an appointive judiciary.[55] Georgia alone set the bad example of
+providing for an elective judiciary, by direct vote of the people, for
+a short term, a practice that historians believe has caused much of the
+degradation and humiliation of the state courts, in the past century.[56]
+
+In most of the other states in the United States, the medium was
+selected, between the life tenure and the complete independence of the
+judiciary upon the one hand, and the recall and disgrace of the judge,
+without the formality of a trial, upon the other, and it was provided for
+the election of judges, for short terms of office, subject to impeachment
+by the legislative branch of Government, in cases of misfeasance in
+office.[57]
+
+In one state alone was the English method adopted of appointing the
+judges for life, or during good behavior, although four other states have
+the appointive judiciary, and it is not strange that in this one state
+we find the strongest state court in the United States and the one whose
+judgments are received by the various courts of the other states with the
+highest degree of respect.[58]
+
+By both the Federal and State Constitutions, in the United States, the
+judiciary has always been regarded as an equal and co-ordinate branch of
+government, with the legislative and executive. It was accordingly held,
+within the past century, that neither the President nor the Governor
+could remove a judge, during the term of office for which he was elected
+or appointed,[59] but the only way to remove or recall a judge, was by
+impeachment for criminal or corrupt conduct.[60]
+
+It is thus a serious question whether the experience of the past century,
+in the United States, has vindicated the method followed in so many
+states, of selecting judges, for a moderate term, by an elective system,
+subject to impeachment for positive misfeasance in office. Many protests,
+other than the growing demand for a popular recall of judges, may be
+directly or indirectly traced to this method of selecting judges and as
+the demands and protests come from states where the tenure to office is
+for the shorter terms, it seems that this general policy, when applied
+to the judiciary, is condemned both by the examples of history and the
+practice and experience of the past century, in the United States.
+
+There is little doubt but that the great Chief Justice Marshall would
+have been recalled, after his decision against the Government, in the
+trial of Aaron Burr, for treason, if the recall of judges by popular
+vote had then obtained, in the United States. The power of Jefferson’s
+administration was used, unsparingly, to obtain Burr’s conviction, and
+he was already convicted in the forum of public sentiment, for the
+populace believed him guilty. The Chief Justice, however, firm in the
+consciousness of right, with the true judicial poise, disdained, with
+equanimity, the clamor of the populace and refused to sacrifice the
+individual, to appease the public wrath.[61] No wonder that through the
+genius of this patriot, the Court he presided over was “placed upon a
+pedestal of imperishable granite and has become the admiration of the
+publicists throughout the civilized world.”[62]
+
+If such a system had then obtained, the country would have been denied
+the genius and ability of this just man, for he would never have been
+responsible to the fickle flames of a vacillating public sentiment for
+the correctness of his opinions. Addressing himself upon the necessity
+for an absolutely independent judiciary, Chief Justice Marshall said:
+
+ “It is to the last degree important that he should be rendered
+ perfectly and completely independent with nothing to control
+ him but God and his conscience.”
+
+Strange, is it not, that the opinions of our patriot fathers should so
+nearly approach the views of the patriarchs of the Mosaic period, upon
+the qualifications of the judge, for they too, believed that the courts
+should be presided over by “able men out of Israel, such as feared God,
+men of truth, hating covetousness” and when appointed to judge between
+the alleged rights of the ancient Hebrews, they were admonished by the
+Great Law Giver: “Ye shall not be afraid of the face of man, for the
+judgment is God’s.”[63]
+
+Right well did Moses warn the ancient judges of the Israelites against
+the fear of men in the prerogative of the judgment seat, for public
+sentiment has ever proven variable and the proper and just ideals do not
+always govern the multitude. We have seen them to-day cry “Hosanna” and
+to-morrow “Crucify Him.” And since the day when Pilate released Barabas
+and delivered the Nazarene to the multitude, because it was popular for
+him to do so, the judge who feared “the face of man” has been deemed
+unworthy of the trust and dignity of the judgment seat.
+
+The millions burned at the stake, during the witchcraft craze, in Europe,
+were convicted before judges whose independence had not been established
+by the laws of the realm and they simply followed the expressed will of
+the multitude in the act of pronouncing judgment.[64]
+
+In our own country, during the spread of this delusion, in Salem,
+Massachusetts, before the courts were presided over by judges appointed
+for life, there were nineteen innocent persons burned or hanged for
+witchcraft in less than one year, and of these fourteen were women.[65]
+
+In the case of the gentle Rebecca Nurse, hanged on Gallows Hill, on July
+19, 1692, after her acquittal by a jury, because the people demanded her
+blood, and a subservient judiciary bowed in humble submission to the
+_vox populi_, we find one of the most unjust instances of the “recall of
+judicial decisions” in the history of any country and one of the grossest
+travesties upon justice that has been produced.[66]
+
+The fear of the recall of judges, in France, during the provisional
+Republic, following the French Revolution, caused the judges to send a
+poor weak woman to the guillotine, because she possessed the foibles
+of her sex and the flower of the aristocracy of the country was sent
+innocent to their death, because a wrought up multitude demanded their
+slaughter. Oh, for the glory of an independent judiciary, in such a
+crisis and what a valuable lesson history affords against the precedents
+made by public sentiment.
+
+The courts alone protect the rights of the minority, for the legislative
+and executive are subservient to the expressed will of the majority.
+In the courts, however, the property of the rich and the poor alike is
+protected from the might of the powerful and the will of the majority,
+because the law of the land, in recognition of the right of the minority
+to enjoy life, liberty and property, in this free land of ours, has
+provided that no property can be taken, however popular it might be
+to appropriate it, without just compensation, after a trial, upon due
+process. But when the judges were but the servants of the majority, of
+course the wishes of the majority controlled them, hence the necessity of
+making them independent of both the majority and minority.
+
+We have seen how the recall of judges by popular vote, in Babylon
+and Greece weakened and destroyed their independence and made them
+subservient tools of the popular and great leaders of the majority;
+that in time the respect of the community for the judges so situated
+was completely destroyed and that the fear of humiliation and disgrace
+prevented gentleman of dignity and ability from seeking such a precarious
+place and the whole judicial system was thereby perverted and deranged.
+
+Commenting upon the condition which the recall of judges by popular vote
+brought about in Greece, we have the valuable testimony of Aristotle who
+said:[67]
+
+ “Those who have any complaints to bring against the magistrates
+ say: ‘_Let the people be judges_’; the people are too happy to
+ accept the invitation and so the authority of every office is
+ undermined. Such a democracy is fairly open to the objection
+ that it is not a constitution at all, for where the laws have
+ no authority there is no constitution.”
+
+The framers of our constitution were familiar with the experiments of
+ancient Greece and the mistakes of the early Anglo-Saxons, and this is
+why the Constitution guarantees to “every state in the union a Republican
+form of government.”[68]
+
+Shall the illuminating precedents of history, ever be forgotten; shall
+the land-marks of the fathers and the light-houses, planted upon the
+shoals upon which other ships of state have floundered, be torn away? Are
+the secrets of the old dooms day books of the Anglo-Saxons, to be read in
+vain and the mistakes of the law of ostracism of the Athenians and the
+discarded and condemned law of petalism, of the Syracusans, to be adopted
+in the United States, in the twentieth century?[69]
+
+If the day shall ever come, in the United States, when this mistaken
+custom of the Babylonians and the ancient Athenians shall be generally
+established, and the disappointed suitor and political demagogue can
+gather his associates and bid the judge come down from his judgment seat
+to answer the excited multitude for the correctness of his judgments,
+then the safeguards of the Constitution, guaranteed to us by the patriot
+fathers will be trampled under foot; this will cease to be a Government
+of law and become a mere aggregation of people, where law is not the rule
+of life.[70]
+
+The statesmen of ancient Greece found that the judge could not be safely
+tried by political methods, for the elements of personal ambition,
+favoritism, money interest, envy and divers other equations, were
+likely to be used in passing upon the qualifications of the judge, when
+arraigned before the forum of a wrought up public sentiment. Nor would it
+be different in any other country, under similar conditions.
+
+In the days of Hammurabi, when the courts were so much concerned about
+the trials of those supposed to “weave spells over a man” and his guilt
+or innocence was determined by his survival of the torrent of the “holy
+river;” when the standards of justice were such that the surgeon, who was
+unsuccessful in an operation, lost his hands; when the veterinarian paid
+for all the stock he could not cure; the builder, or artisan, all damages
+resulting from a house he had built afterwards falling down. When, in
+all the relations of life—save that of the royal prerogatives—the test
+of human action was the exalted ideal of infallibility, then the judge
+who set aside a judgment was humiliated and disgraced and peremptorily
+removed from office. All morality was on a par with such ideals of the
+exalted virtues like justice, and brides were auctioned off by their
+fathers to the highest bidder and all human action was in keeping with
+such dark days of superstition and delusion.
+
+The behavior of the judge of the time of Cnut, in England, when he was
+liable to be fined and removed for entering “a false judgment,” was in
+strict accord with the low standards of justice then obtaining and from
+this degraded position of the judiciary, to that of the exalted notion
+of an absolutely independent judiciary, there was the same difference in
+the quality of justice administered, that obtained between the generally
+ignorant men selected to parcel out the right, for remuneration, in those
+dark days and the pure and scholarly jurists, who, for centuries have
+made the administration of the law, in England, the admiration of the
+civilized world. The history of the judiciary, in England, has certainly
+demonstrated the wisdom of an independent judiciary, for no country
+pays the same high regard to the majesty of the law and in none are the
+correct ideals in legal standards more nearly approximated, than in
+England.[71]
+
+One does not have to become an Anglo-Maniac to feel a just pride in
+the stability and perfection of an institution, such as the English
+judiciary, for all who make law a rule of life, can but revere the
+approximation of an ideal where its reign is supreme.
+
+In the consideration of this antiquated and condemned institution, known
+as “Judicial Recall,” space has forbidden that we should do more than
+merely touch upon the centuries as mile-stones, in hurrying through the
+ages. From the facts of history presented, however, it seems strange that
+in the evolution of the race, amid the cultivated ideals of our twentieth
+century civilization, so many of our states would seemingly refuse to
+profit by the mistakes in the Leges Barbarorum of the dark ages; that
+they would apparently turn aside from the sad picture of the early
+struggle for law and—defying the axiom that we can but “judge the future
+by the past of man”—indulge the vain hope of utilizing the popular recall
+of judges as a panacea for all the social evils of modern times.
+
+The patriot fathers, profiting by the accumulated wisdom of the past,
+builded an edifice in this free land of ours, bottomed upon the solid
+foundation of constitutional principles, sufficiently enduring to
+withstand the most tempestuous seas of partisan politics, because they
+profited by the record which history recorded of the stranded wrecks
+of states upon the shores of time. Our fathers and their children
+have occupied this temple for over a century and we should have a care
+how we undermine the walls or remove the high priest of our liberties,
+with rough hands, from the sacred altar. Many a hearth-stone in this
+and future ages will need the protection guaranteed by the fundamental
+principle of government, which perpetuates the independence of the
+judicial department and the statesmen of the present age, without
+thinking of the permanence of their work, are making right and wrong for
+succeeding ages and by tampering with the institutions that time has
+approved, they may incur the everlasting condemnation of the citizens of
+succeeding commonwealths.
+
+
+FOOTNOTES:
+
+[1] Speaking upon the antiquity of courts and judges, John, in his
+“Babylonian and Assyrian Laws,” says: “Partly because specific reference
+to judges and legal processes are not necessarily to be expected in
+historical inscriptions, and partly because we do not really know which
+are the earliest monuments of the human race, it is impossible to decide
+when law-courts first came into existence. It is generally admitted,
+however, that the stele of Manistusu is one of the earliest known
+monuments. There we read of Galzu, a judge. There also we find many of
+the officials, who later acted as judges upon occasion. Hence it may
+fairly be said that judges were to be found in ancient Babylonia from
+time immemorial. They must have decided what was right when there was no
+written law to which to appeal.”
+
+“Babylonian and Assyrian Laws,” c. v. p. 80.
+
+[2] Exodus, c. 18, 26.
+
+[3] Exodus, c. 23-2.
+
+[4] Deuteronomy, 1-17.
+
+[5] Deuteronomy, 17-9, 12.
+
+[6] John’s “The Oldest Code of Laws in the World.”
+
+[7] New York Independent, Vol. 55, pt. 1,—January-March, 1903—p. 67;
+John’s “Babylonian and Assyrian Laws.”
+
+[8] John’s “The Oldest Code of Laws in the World,” p. 2; Code of
+Hammurabi, sec. 5; John’s “Babylonian and Assyrian Laws,” p. 44.
+
+A notable case of the recall of judges as late as five hundred years
+before Christ occurred among the Medes and Persians, who boasted of their
+unalterable decrees, once rendered by the incumbent of the _dangerous_
+judgment-seat.
+
+Herodotus tells the thrilling story of the striking example furnished by
+King Cambyses, in his final recall of the unjust judge, named Sisamnes.
+He caused him to be killed and flayed and the judgment-seat to be covered
+with his skin. He then appointed the son of Sisamnes to be his successor,
+but charged him, while sitting in judgment, to remember the fate of
+his father. This example might be resorted to by the agitators for the
+judicial recall, as a more terrible example to an unjust judge than the
+mere recall and degradation.
+
+[9] John’s “Babylonian and Assyrian Laws,” p. 82. Whether the reversal of
+an erroneous judgment was provided for by appeal, does not appear, from
+the Code.
+
+[10] John’s “Babylonian and Assyrian Laws,” p. 90.
+
+[11] _Ante idem._
+
+[12] _Ante idem._ p. 92.
+
+“Shamash-bel-ili sues Nidnusha concerning a house bought by him of her.
+The judges grant him two sheckels of silver. Hammurabi I.”
+
+“Shi-lamazi sues her brothers for a field and wins her case.”
+
+“Zariku was put to the oath and replied to Erib-Sin. He was told that as
+his domicile was at Sippara, he must not make his appeal to the judges of
+Babylon, so his case was dismissed. Hammurabi 28.” This was a case of the
+wrong venue and hence, a lack of jurisdiction over the subject-matter.
+
+“Ilushu-abushu hired a pack-ass, of Ardi-Sin and Silli-Ishtar and lost
+it. The judges awarded them sixteen sheckels of silver as compensation.
+Apel-Sin. 5.”
+
+“Mar-ersitim left a female slave, Damiktum, to Erib-Sin. His wife and
+brother disputed the legacy. The judges inspected a document by which
+Erib-Sin had granted the slave to his wife, so they return her to the
+wife. Hammurabi.”
+
+“A slave, Bariki-ilu, was pledged for twenty-eight sheckels to Ahinuri,
+in the thirty-fifth year of Nebuchadnezzar. In the next year we find him
+in possession of Piru, his wife, Gaga, and a cousin, Zirra. They sold him
+for twenty-three sheckels to Nabu-Zer-ukin. He must have fled from his
+new master, for four years later the same people pledged him. He was not
+a satisfactory pledge, for next we find that Gaga’s daughter, about to
+be married, this slave was set down as a part of her marriage portion,
+and she gave him to her husband and his son, and he remained in their
+possession, but when his mistress died, he was handed over to the great
+banker, Itti-Marduk-balatu. During the reign of Nabonidus, the slave,
+Bariki-ilu, attempted to establish his freedom, by pretending to be the
+adopted son of Bal-rim-ani, but was made to confess that he had twice run
+away from his master and had been many days in hiding, so it was adjudged
+that he must return to servitude.” John’s “Babylonian and Assyrian Laws,”
+p. 181.
+
+[13] Code Hammurabi, Sec. 215; John’s “Babylonian Laws,” p. 63.
+
+[14] _Ante idem._ Sec. 225; John’s “Babylonian Laws,” p. 63.
+
+[15] _Ante idem._ Sec. 229; John’s “Babylonian Laws,” p. 64.
+
+[16] Diod. Sic. xl, 55; Aelian, V. H. xiii, 23; Smith’s Greek and Roman
+Antiquities.
+
+[17] Polio, iii, 8.
+
+[18] Smith’s Dictionary of Greek and Roman Antiquities, _sub nom._
+_Banishment_.
+
+[19] Schol. in Aristotle, Equit. 865; Smith’s Greek and Roman Antiq.
+_supra_.
+
+[20] _Ante idem._
+
+[21] Plutarch’s Lives.
+
+[22] Plutarch’s Lives.
+
+Aristeides, from the history of the man, as given us by Plutarch was to
+be classed with that altruistic lot of patriots:
+
+ “Who cared not to be great
+ But as they serve or save the State.”
+
+[23] Plutarch’s Lives.
+
+[24] Plutarch’s Lives.
+
+[25] Plutarch’s Life of Themistocles.
+
+[26] Aristotle, c. 7, p. 135; Smith’s Dictionary of Greek and Roman
+Antiquities.
+
+[27] Plutarch’s Life of Aristeides; Smith’s Dictionary of Greek and Roman
+Antiquities.
+
+[28] Smith’s Dictionary of Greek and Roman Antiquities.
+
+[29] Niebuhr, “History Rome,” i, 504; Diod. Soc. xl, c. 87; Smith’s
+Dictionary of Greek and Roman Antiquities.
+
+[30] Livy, ii, 41; _idem._, vi, 20.
+
+[31] Gaius, i, 2; _idem._, 20; Tacitus, History, i, 84.
+
+[32] Niebuhr, History Rome; Livy, Sallust, Tacitus, Arnold, Gibbon.
+
+[33] I. Pollock and Maitland History English Law, p. 37.
+
+[34] _Ante idem._, p. 42.
+
+[35] Coke, 4 Inst. 272.
+
+[36] I. Reeve’s History English Law, 264; I. Pollock and Maitland’s
+History English Law, 40, 45.
+
+[37] I. Pollock and Maitland’s History English Law, pp. 72, 73; Memoirs
+de la Societe des antiquaires de Normandie, vol. xv, pp. 196-197.
+
+[38] I. Reeve’s History English Law, 273.
+
+[39] I. Reeve’s History English Law, pp. 283, 465, 466.
+
+[40] I. Reeve’s History English Law, 280.
+
+The conditions existing before the Barons exacted from King John the
+various guaranties of the Great Charter are known to all readers of
+English History. The reasons why they stipulated that “Right shall
+not be sold, delayed or denied”; that the king should only appoint
+“justiciaries, sheriffs and bailiffs, of such as know the law of the land
+and are disposed duly to observe it” is emphasized by a consideration of
+the many highhanded proceedings that the people of that long suffering
+country had been subjected to before this Great Charter of liberty was
+exacted from King John. (I. Reeve’s History English Law, 471, 472.)
+
+[41] I. Pollock and Maitland’s History English Law, p. 204.
+
+[42] _Ante idem._ p. 204.
+
+[43] _Ante idem._
+
+[44] Cnut, ii, 15, sec. 2; Edgar 1, 3; Brunner, D. R. G. ii, 356, 365;
+II. Pollock and Maitland’s History English Law, 666.
+
+[45] II. Pollock and Maitland’s History English Law, 667.
+
+[46] Note Book, Pl. 1412; Glanvill, viii, 9; Edgar, iii, 3; Cnut, ii, 15;
+Leg. Will. I., 39, sec. 1, II. Pollock and Maitland’s History English Law,
+p. 667.
+
+[47] Note Book, Pl. 67; Note Book, Pl. 1166; II. Pollock and Maitland’s
+History English Law, p. 668.
+
+[48] II. Pollock and Maitland’s History English Law, p. 672; Bracton, f.
+186.
+
+[49] Verplanck.
+
+[50] I. George III., c. 23.
+
+It has long been axiomatic, in England, that the Crown even, cannot
+interfere with the disinterested performance of its powers, by the
+judiciary. 2 Hawk. P. C. 2.
+
+[51] Yates vs. Lansing (N. Y.), 5 Johns xx. 282; Hamilton vs. Williams,
+26 Ala. 527.
+
+[52] State vs. Graves, 8 Mo. 148; 40 Am. Dec. 131; Stone vs. Augusta, 46
+Me. 127; Revill vs. Pettit, 60 Ky. 314; Reed vs. Conway, 20 Mo. 22; Gault
+vs. Wallace, 53 Ga. 675; Cope vs. Rainey, 49 Tenn. (2 Heisk.) 197.
+
+[53] U. S. Con. Art. III., sec. 1.
+
+[54] See Paper “The Judiciary and Public Sentiment,” read before Mo. Bar.
+Assn. at St. Joseph, Mo., September, 1906, Proc. 24’ Annual Meeting of
+Association.
+
+[55] See interesting article on “Recall of Judges,” by Albert Fink, in
+North American Review, vol. 193, p. 680.
+
+The Massachusetts Bill of Rights, adopted in 1780 declares:
+
+“It is the right of every citizen to be tried by judges as free,
+impartial and independent as the lot of humanity will admit.” Would that
+more of the States had followed this lead of the Great Commonwealth of
+Massachusetts.
+
+[56] Upon this subject, Dr. Fiske observed: “It was Georgia that, in
+1812, set the bad example of electing judges for short terms by the
+people, a practice which is responsible for much of the degradation that
+courts have suffered in many of our states and which will have to be
+abandoned before a proper administration of justice can ever be secured.”
+
+[57] Thorpe’s American Charters, Constitutions and Organic Laws.
+
+[58] Massachusetts and New Hampshire judges are appointed and hold during
+good behavior, but in New Hampshire the judge is subject to recall by the
+Legislature and on four different occasions, judges have been removed in
+that state by this method.
+
+[59] United States vs. Guthrie, 58 U. S. (17 How.) 284; State, ex rel,
+Vail, vs. Draper, 48 Mo. 213.
+
+[60] Evans vs. Foster, 1 N. H. 374; McDowell vs. VanDusen, 12 Johns. 356.
+
+[61] From Address delivered by Judge John F. Philips, December 22’, 1912,
+at Omaha Club, Omaha, Nebraska, upon the “Judicial Recall.”
+
+[62] _Ante idem._ The great Wirt was asked, after the Burr trial: “Why
+did you not tell Judge Marshall that the people of America demanded a
+conviction?” And his reply showed not only the high-minded, professional
+gentleman that he was, but the patriotic citizen as well. It was: “Tell
+him that? I would as soon have gone to Herschel and told him that the
+people of America insisted that the moon had horns as a reason why he
+should draw her with them.”
+
+[63] Deuteronomy, 1-17.
+
+[64] Dr. Sprenger, in his “Life of Mohammed” says 9,000,000 were burned.
+
+[65] Upham’s “Salem Witchcraft in Outline”; Nevin’s “Witchcraft in Salem
+Village.”
+
+[66] Upham’s “Salem Witchcraft in Outline.”
+
+[67] North American Review, Article by Albert Fink, vol. 193, p. 690.
+
+[68] North American Review, vol. 193, p. 673, for decisions holding
+that a Republican form of Government is one where the whole people are
+represented by their representatives.
+
+[69] Mr. Rome G. Brown, in his interesting paper before the Minnesota Bar
+Association, confidently asserts that the United States Supreme Court
+ought to hold the judicial recall, in the United States as contrary to
+the Federal Constitution, because a denial of the Republican form of
+Government, guaranteed by this immortal document.
+
+[70] See Excellent Paper of Judge John F. Philips, read at Omaha Club,
+Feb. 22’, 1912.
+
+If such a custom generally prevailed, it is probable that in the due
+course of time we would indeed have:
+
+ “Red ruin and the breaking up of laws.”
+
+[71] It is a just source of pride to Englishmen that not a single
+lynching has occurred for three-quarters of a century, in a country
+governed by the English law.
+
+Illustrative of the complete independence that for centuries has
+characterized the English judiciary, it is reported that when accosted
+by King James I. and asked how he expected to decide a given case,
+pending in his court, Sir Edward Coke, then Lord Chief Justice of England
+replied: “When that case shall come before me, I will decide it as a good
+judge ought to decide it, in accordance with the law and the evidence.”
+Percy’s Anecdotes on Justice.
+
+
+
+
+CHAPTER IV.
+
+TRIAL BY BATTLE.
+
+
+Trial by battle, sometimes called “wager of battel,” or “battile,” as
+Bouvier refers to it, could be claimed in appeals of felony and in
+certain civil cases and was of frequent use in affairs of chivalry and
+honor.[1]
+
+No tradition can tell us just when the trial by combat first came into
+existence.[2] Wager of battle was a natural accompaniment of the state
+of society existing when men were accustomed to take the law into their
+own hands and test the right by the might that could back it up. Battle
+has always been the law among the lower animals and in the evolution of
+the species, before society had developed the standards of our present
+civilization, the males of the human species, in barbarous nations, won
+the females much oftener through the law of battle, than by the display
+of intellectual attainments.
+
+Trial by battle, therefore, may be traced to the most ancient period.
+Sacred writ gives an analogous contest, in the memorable battle between
+King David and Goliah, and the destinies of nations, instead of the
+rights of individuals, were made to depend upon the outcome of the
+combat. Goliah challenged the Israelites:
+
+ “Choose you a man for you, and let him come down to me. If he
+ be able to fight with me and to kill me, then will we be your
+ servants; but if I prevail against him, and kill him, then
+ shall ye be our servants and serve us.”[3]
+
+And, as the principals in the trial by battle always relied upon the
+grace of God to further the righteousness of their cause, so King David,
+in his battle, relied upon the God who had saved him from the lion and
+delivered him from the paw of the bear, to bring to a successful issue,
+his contest with the giant. He went to the fight in the name of the “Lord
+of Hosts,” the God of the armies of Israel, and proclaimed that it was
+“His battle,” and he fought not with sword and spear, but would deliver
+the Philistines into his hands.[4]
+
+The soldier and historian, Paterculus, is authority for the statement
+that during the first half of the first century, when Quintilius Varus
+attempted the settlement of disputes among the Germans by law, he
+discovered that their custom had been to decide all such controversies
+by single combat.[5]
+
+Neilson[6] refers to the traditional statement of King Frotho the Third
+in the misty age of Denmark, that he “deemed it much fitter to contend
+with weapons than with words,” in the settlement of private disputes,
+and he shows how this sentiment found firm lodgment in the breast of the
+Norseman, whose supreme God was Odin, the God of war, for valor was the
+jewel of his soul.
+
+Selden states that the decision of suits by appeal to the God of battle
+is said to have been invented by the Burgundi, one of the northern of the
+German clans that flourished before the subjugation of the Gauls by the
+Romans. And it is true, that the first written injunction of judiciary
+combats that we meet with is in the laws of Gundibald, A. D. 501, which
+are preserved in the Burgundian code. It was not a mere local custom of
+that particular tribe, however, but was the common usage of all those
+warlike people, from the earliest times.[7]
+
+Judicial duels, or combats by individuals, according to forms of law,
+obtained among the ancient Goths, in Sweden,[8] and this form of
+“searching out hidden truths,” as Selden observes, was practiced by the
+Russians, Hungarians, Almains and Normans.[9]
+
+History records that the Emperor Otho, A. D. 983, at Verona, held a diet
+at which were assembled many lords and princes from France, Germany
+and Italy and in order to discourage perjury in judicial trials, the
+convention substituted the trial by battle in all cases, in lieu of the
+oaths or testimony of witnesses.[10]
+
+In the early feudal ages, “when knighthood was in flower,” chivalry
+played no small part in the growth and development of the fixed rules
+governing the trial by battle.[11] Chivalry has always been in the
+world, but it finds expression according to the customs obtaining in the
+different stages of man’s growth and development. Because fighting was
+then the order of the day, in the olden times, knights were sacrificed
+by personal combat, for their ladies faire. When trial by battle was
+on the decline, Sir Walter Raleigh expressed the spirit of chivalry of
+that period, by spreading his cloak upon the ground for his queen to
+walk upon. And in this our twentieth century, with the progress of the
+race,—be it ever recorded to the credit of the manhood of the period—this
+same spirit was exemplified by the splendid lesson of hundreds of noble
+men heroically accepting the terrors of a mighty sea, in order to rescue
+the women and children from a sinking ship.[12]
+
+The deeds of knighthood, in the England of the middle ages, came to be
+gauged according to fixed and settled rules and customs and finally
+the _Court of Honor_, was recognized, the same as the court of civil
+procedure, for the trial of affairs of honor, for, says Blackstone: “This
+court of chivalry, can order reparation at the point of honor.”[13]
+
+The proceedings of this court were by petition, in a summary manner, and
+the trial, instead of by a jury, as at the present day, with witnesses,
+was by individual combat.[14]
+
+The _Court of Honor_ was not a court of record and it could not imprison,
+but the marshalling of arms, was then the pride of the best families of
+the kingdom and the success in these affairs of honor, because of the
+spirit of chivalry of the times, was just as much guarded as was the
+attainment of justice through the procedure of the civil courts. Heralds
+and knights seconded and backed up the appeals of the principals in such
+encounters and the sacrifice of the individual in these mortal combats
+was regarded as a trifle, compared to the preservation of the family name
+and honor and since his attainder and the corruption of his blood and
+family name depended upon his success in the combat, the wager of battle
+was welcomed, as the only vindication of one’s manhood and honor.
+
+The trial by battle, therefore, at a very early day, proceeded according
+to fixed, settled rules of law and was a recognized mode of legal
+procedure, just as much as was the trial by judicial proceedings. In this
+it differed from duelling, in that the latter was the fighting of two
+persons, at an appointed time and place, in the absence of law and order.
+In other words, the trial by battle was a mode of legal procedure, while
+duelling was a crime, in that the duel was not conducted according to
+legal rules and precedents, but the participants took the law into their
+own hands.[15]
+
+Trial by battle was introduced into England, among other Norman customs,
+by William the Conqueror. The right could only be claimed in three
+classes of cases, i. e., military, or in the court martial, or court
+of chivalry or honor;[16] criminal, or in appeals of felony,[17] and
+civil, or upon issue joined in a writ of right, the last and most
+solemn decision of real property.[18] The reason why battle was allowed
+in “writs of right,” was said to be on account of the inability of
+establishing one’s title by action at law, in case of the death of
+witnesses or the absence of other evidence.
+
+In the criminal practice the one exercising the right to wager of battle
+was called the “Appellee,” from the French word “Appeller,” meaning “to
+call,” the term being used because of the practice of calling the parties
+before the court.[19]
+
+The points of difference between a trial by combat, under the writ
+of right and one for treason, are noted by Neilson, in his “Trial by
+Combat” and principal among them are, that the trial at law could be
+fought before any judge, while the trial for treason had to be before
+the King, Constable or Marshal, or a special deputy; the forms of oath
+were different; the duel at law was fought on foot, while for treason, it
+was fought on horse-back; the weapon of the trial at law, was the baton,
+while that for treason, was the sword and spear; the position of the
+combatants, in a writ of right, was north and south, while in a trial for
+treason, it was east and west, and in the battle under a writ of right,
+since the trial itself was the judgment, there was no right to stop the
+trial, but in a trial for treason, the king, or his representatives could
+stop the trial, if he so desired.[20]
+
+In the appeal of felony, the prosecutor was bound to offer combat with
+his own body, but in the writ of right, the demandant could either
+participate in his own behalf, or through the medium of his champions’
+services.[21] But even in the Norman days, when battle was in vogue,
+“battle did not lie” unless there was a charge of crime and at least
+ten shillings’ worth of property was in dispute.[22] In civil cases,
+professional pugilists were commonly employed and perjury became so
+common that the form of the compurgator’s oath was changed to prevent the
+wholesale commission of this crime.[23] The commonest cause of battles
+were those urged by an “approver,” or convicted criminal, whose pardon
+was conditional upon his ridding the kingdom of some half dozen or more
+of his associates, by his “appeals.” This custom, however, began to
+decline so rapidly, that in Bracton’s day the annual average of battles
+did not exceed twenty.[24]
+
+The old books indicate that in appeals of felony, the custom was for
+the combatants to have their heads shaved, not to prevent the opponent
+from catching hold of the hair, but because it was an old religious
+custom.[25]
+
+In discussing the trial by combat, in finance, Neilson shows how, during
+the reign of Henry II., large sums were paid to crown officers, for the
+privilege of the duel; for refusal to fight, or absence, and for fines
+for wrongfully claiming the right to the duel, and the same thing was
+true in the reign of Richard I.[26]
+
+During the reign of Edward III. the trial by battle was discouraged by
+the legislation of the period and trial by jury was encouraged. The right
+of trial by battle was taken away in the case of an appeal for breaking
+the king’s prison, and the right was also denied to one “taken with the
+manner.”[27] And during the reigns of Edward V. and Richard III., the
+trial by battle in criminal cases had become so obnoxious to the people
+of England that it came to be established that if a valid indictment
+was pending for the offense charged, the right of trial by battle was
+denied.[28]
+
+In the reign of Henry VI., Priscot, Chief Justice, and Needham, one of
+the Justices, held that in an appeal for treason, the battle could only
+be had before the constable and marshal.[29]
+
+Wager of battle had been but seldom invoked in actions of debt, and
+in the thirteenth century, it was no longer allowed in this class of
+actions.[30]
+
+A generation after the Norman conquest, Henry I., by Charter to the City
+of London,[31] granted exemption from the trial by battle to citizens
+of London, or peers of the realm, in certain cases, and a woman, a
+priest, an infant, a man of sixty or over, or one maimed, lame, or blind,
+was entitled to refuse the wager of battle and insist upon a trial by
+jury.[32]
+
+In civil combat, upon issue joined in a writ of right, the tenant or
+defendant had to try the issue by combat, until the reign of Henry II.,
+when the Grand Assize was provided for, and then he had his election
+either to try the issue by combat or by the jury trial, provided for by
+this king in this class of cases.
+
+Glanville,[33] who wrote during the reign of Henry II., after the tenant
+was given his election to try his writ of right either by combat, or by
+the Grand Assize, thus describes the procedure then obtaining under the
+rule of civil combat:
+
+ “Both parties being present in court, and the demandant
+ claiming the land in question, the tenant may require the view
+ thereof: but as to this, there is respite to be made, to the
+ end it may be known, whether the defendant have not more land
+ in that town than what is in question; and if he have not, then
+ he shall not be allowed any respite; but if he have more, he
+ shall; and likewise have assignation of another day; and, when
+ he shall be so departed out of the court, at three reasonable
+ essoins,[34] the defendant may recover anew; and the shireeve
+ of the county wherein the land lieth shall have a writ directed
+ to him to send freeholders of his county to view the land.
+
+ “Then, after three reasonable essoins, concomitating the view
+ of the said land, and both demandant and tenant appearing again
+ in court, the demandant setteth forth his claim in this manner:
+ ‘I do challenge against T. H. half a knight’s fee, or two
+ carucates of land in that town, as my right and inheritance;
+ and whereof, my father, or grandfather, was seised in his
+ demesne, as of fee, in the time of King Henry I., or after the
+ first coronation of the King that now is, and whereof he hath
+ taken the profits, to the value of 10s. at the least, viz.,
+ in corn sowed, and other commodities; and this I am ready to
+ try by this my freeman N.; and if any mischance shall befall
+ him, then by that other person who hath seen and heard this.’
+ Or thus,—‘And this I am ready to try by this my freeman, S.
+ unto whom his father, on his death-bed enjoined, upon the duty
+ wherein a son is obliged to a father, that if at any time
+ he should hear of a suit for that land, he should adventure
+ himself, by combat for it, as that which his father had seen
+ and heard.’
+
+ “The claim and demand of the demandant being thus made, it
+ shall be in the choice of the tenant, either to put himself
+ upon trial for the same by _combat_, or to put himself upon
+ the _great assize_ of our lord, the king, and to require a
+ recognition which of them hath most right in that land.
+
+ “And if he will defend it by _combat_, he is then obliged to
+ defend the right of the demandant word to word as he sheweth
+ it against him, either by himself or some other fitting
+ person; but note, that after the _combate_ shall be thereupon
+ waged, it behoveth him who holdeth the land, to defend it by
+ _combate_, and thenceforth not to put himself into the _great
+ assize_; and, after the _combat_ waged, he may again reasonably
+ essoins himself thrice, as for his own person, and thrice for
+ the person of his champion. All which essoins being made, as
+ they rightly ought to be, it is necessary that, before the
+ _combat_ be begun, the plaintiff do appear in court, and have
+ his champion there in readiness to fight; nor may he bring any
+ other champion than one of those, upon whom he did put the
+ trial of his cause; neither may he change another for him,
+ after the first waging of the battle....
+
+ “And if the defender (i. e., the champion) shall happen to be
+ vanquished, his lord shall lose the land by him claimed, with
+ the profits and commodities thereof, at the time of the seisin
+ found in that fee, and shall never after be heard in court
+ again for the same; but whatsoever things shall be determined
+ by combat in the court of our lord the king are to remain firm
+ forever; and thereupon there shall be a precept directed to
+ the shireeve, that the victor shall have the land which was in
+ dispute....
+
+ “This, if the demandant shall prevail in the combat; but if
+ he be overthrown by the vanquishing of his champion, then the
+ tenant shall be acquitted from his claim without recovery by
+ the demandant.”[35]
+
+Selden describes the ceremony governing the civil combat, upon issue
+joined upon a writ of right,[36] as follows:
+
+ “A piece of ground is in due time set out of sixty feet square,
+ enclosed with lists; and on one side, a court erected for the
+ judges of the court of common pleas, who attend there in their
+ scarlet robes; and also a bar is prepared for the learned
+ serjeants at law. When the court sits, which ought to be by
+ sun-rising, proclamation is made for the parties and their
+ champions, who are introduced by two knights, and are in a
+ coat of armour, with red sandals, bare-legged from the knee
+ downward, bare-headed, and with bare arms to the elbows. The
+ weapons allowed them are only _batons_, or staves of an ell
+ long and a four-cornered leather target, so that death very
+ seldom ensued this civil combat ...
+
+ “When the champions, thus armed with batons, arrive within the
+ lists or place of combat, the champion of the tenant then takes
+ his adversary by the hand and makes oath that the tenements in
+ dispute are not the right of the demandant; and the champion
+ of the demandant then taking the other by the hand, swears in
+ the same manner that they are; so that each champion is, or
+ ought to be, thoroughly persuaded of the truth of the cause he
+ fights for. Next an oath against sorcery and enchantment is
+ to be taken by both the champions in this or a similar form:
+ ‘Here this, ye justices, that I have this day, neither eat,
+ drank, nor have upon me neither bone, stone, no grass nor any
+ enchantment, sorcery, or witchcraft, whereby the law of God
+ may be abased, or the law of the devil exalted, so help me, God
+ and his saints.’
+
+ “The battle is thus begun, and the combatants are bound to
+ fight till the stars appear in the evening; and if the champion
+ of the tenant can defend himself till the stars appear, the
+ tenant shall prevail in his cause; for it is sufficient for
+ him to maintain his ground, and make it a drawn battle, he
+ being already in possession; but if victory declares itself for
+ either party, for him is judgment finally given. This victory
+ may arise from the death of either of the champions, which
+ indeed, hath rarely happened, the whole ceremony, to say the
+ truth, bearing a near resemblance to certain rural athletic
+ diversions, which are probably derived from this original; or
+ victory is obtained, if either champion proves _recreant_;
+ that is, yields, and pronounces the horrible word of _craven_,
+ a word of disgrace and obloquy rather than of any determinate
+ meaning: but a horrible word it indeed is, to the vanquished
+ champion, since, as a punishment to him, for forfeiting the
+ land, of his principal, by pronouncing that shameful word, he
+ is condemned as a recreant _amittere liberam legem_; that is,
+ to become infamous, and not be accounted _liber et legalis
+ homo_ being supposed by the event to be proved foresworn, and
+ therefore never to be put upon a jury, or admitted as a witness
+ in any cause.”
+
+Combat in criminal cases was allowed, according to Selden[37] not only in
+cases of treason but
+
+ “For the trial of a particular objected misdeed, cognizable
+ by the ordinary course of the common law; and of these the
+ justices of the king’s bench have the imposition; it is
+ likewise permitted for the purgation of an offense against
+ military honor, which the high court of chivalry is to marshal
+ by the law of arms.”
+
+The military form of trial by combat, on a criminal charge was as follows:
+
+ “First a bill of challenge is, together with a gauntlet,
+ delivered unto the court by the appellant. The defendant
+ denieth the point of the bill, and excepteth the gauntlet.
+
+ “Then, if the appellant have no witnesses to prove the matter
+ of his appeal, the marshal prefixes a day, within forty, for
+ deraigning the combat, taking pledges of both parties, to
+ appear at the day, and to do battle between sun-rising and
+ sun-set.
+
+ “The place appointed for the combat is a hard and even
+ ground, railed within certain lists, sixty feet in length
+ and forty feet in breadth; and without the lists are certain
+ counter-lists, without which the marshal’s men come, as well to
+ attend any extraordinary accident, within the lists, as to keep
+ off the press of the people without.
+
+ “Their weapons are appointed, a glaive, a long sword, a short
+ sword, and a dagger. At the day the appellant doth appear and
+ come to the east gate of the lists, where he is admitted to
+ enter by the marshal himself, together with his arms, weapons,
+ victual and also his council with him; and then is brought to a
+ certain place, within the lists, where he attends the coming of
+ the defendant.
+
+ “The defendant, if he appear not, is called by three
+ proclamations, made by the marshal of the king of heralds of
+ that province wherein the battle is deraigned. The marshal’s
+ clerk doth enter into his register their coming, the time of
+ their coming, and the manner, whether on horse-back or on foot;
+ the fashion of their arms and their weapons; the colour of
+ their horses and the like.
+
+ “The marshal doth measure their weapons; and then the marshal
+ hath a clerk ready, who brings forth the crucifix and a mass
+ book, whereupon both the appellant and defendant do take their
+ oaths.
+
+ “The bill of challenge of the appellant and the answer of the
+ defendant, is read unto them by the marshal’s clerk; and then
+ they take their oaths; First, that their appeal and defense is
+ true; Second, that neither has advantage of other by weapon;
+ Third, that either would do his best endeavour to vanquish his
+ enemy.
+
+ “Then proclamation is made at every corner of the lists, for
+ the clearing and voidance of the lists. Then the combatants,
+ being ready, the constable and marshal, sitting at the king’s
+ feet, pronounce these words, with a high voice: ‘_Lesses
+ les aller, lesses les aller, lesses les aller et faire leur
+ devoir._’
+
+ “In the fight, if either of the parties do give any sign of
+ yielding; or if the king, being present, do cry ‘_Hoe_,’ the
+ constable and the marshal do part them, and observe precisely
+ who hath advantage or disadvantage, either of other at that
+ instant; for if they should be awarded to fight again, they
+ are to be put in the same posture as they were before. If the
+ king take up the matter, they are brought honorably out of
+ the lists, neither having precedency before the other. If the
+ battle be performed, and one party be vanquished, then, in
+ case of treason, the rails of the lists are broken down, and
+ the party vanquished is drawn out at a horse-tail and carried
+ presently to execution by the marshal.”[38]
+
+The older books abound in many illustrations where the appellee, when
+charged by a formal accusation, with some felony, claimed the wager of
+battle to establish his innocence.[39]
+
+Neilson refers to the single combat between Corbis and Orsus, fought
+in the presence of Scipio, for a principality in Spain.[40] And the
+traditional combat, in prehistoric Roman days, between the Horatti and
+the Curiatti is also cited, to show that the institution of trial by
+combat was not unknown to the Romans, at an early day.[41]
+
+Geoffrey of Monmouth, describes the battle between King Arthur and
+Flollo, the Roman Tribune, at the siege of Paris, to determine who would
+be the master of the realm, and this realistic story of the battle, on
+horses, with fixed lances and the interesting narration of how King
+Arthur, after his horse was killed under him, drove his sword through the
+helmet of Flollo and cut his head in two, reads like some story from the
+works of fiction.[42]
+
+Neilson notes[43] that in Mediaeval Germany, disputes between men
+and women were settled by combat, for chivalry does not seem to have
+penetrated into the warlike confines of this sturdy nation, at this
+period, although some notion of equalizing the contests between the
+weaker combatant and the stronger, obtained. The male was handicapped, in
+such contests, by placing him in a tub, sunk waist deep in the ground,
+with one hand tied behind his back. The woman was allowed a paving stone,
+sewed in the end of the long sleeve of her shift, or under garment and
+she was accorded the privilege of manouvering around her antagonist, at
+will, until she found a vulnerable point of attack.[44]
+
+Perhaps the earliest reference to the trial by battle, among the
+adjudicated English cases, is that of Wulfstan vs. Walter, of which Lea
+reports that the witnesses who saw the trial stood ready to prove their
+assertions regarding it, by “oath and battle.”[45]
+
+The mandate of the Conqueror’s law, that the mutilated trunk, of the
+defendant, convicted of treason, by combat, should remain as an evidence
+of his crime, in order to deter others from this hated offense, was
+exemplified, in the year 1096, in the case of William of Eu,[46] who,
+after trial by combat, had his eyes torn out and thus bereft of his
+sight, was sadly left to wander alone and despised through the world, a
+living example of the vengeance of the Lord, for the offense that he had
+been convicted of, by this hap-hazard method.
+
+The battle between Henry, Earl of Essex and Robert de Montford, in the
+year 1163, on an island in the Thames, near the Abbey, is well attested
+by the history of that period. The charge of treason was preferred in
+Parliament and the combat was adjudged, because of the alleged cowardice
+of the Earl of Essex, during the Welsh war of 1157, in precipitating
+a panic, during a decisive engagement in a narrow pass, by throwing
+down his banner and giving the alarm that the king had been slain. De
+Montford was victorious in the battle which followed and though Essex
+made a fierce attack upon him, his blows were warded off and the Earl was
+defeated and left for dead upon the field of battle. His body was given
+to the Monks of Reading, for burial and he was revived and allowed to
+become a Monk himself.[47]
+
+“Hobbe-the-Werwede,” an approver, much spoken of in the old books
+discussing trial by battle, in the fourth year of King Henry III. defeated
+“Walter-in-the-Grove,” but Hobbe soon afterwards faced another opponent
+and like many of our modern pugilists, went down to defeat, in his last
+battle.[48]
+
+On October 4’, 1350, Sir John de Visconti fought Sir Thomas de la Marche,
+before King Edward III., within the bounds of the royal palace, at
+Westminster. Sir John had charged Sir Thomas with taking bribes from the
+infidel Turks and betraying the Christian army. The combatants were clad
+in armour, but their helmets were guarded, at the visor, with small bars
+of steel. Sir Thomas had taken the precaution to wear steel knuckles,
+with which he soon broke the bars of steel covering the visor of Sir
+John’s helmet and thus having the advantage, he punished him so severely,
+by repeated blows in the face, that Sir John was compelled to yield.
+Because of the compliment paid to the English King, in fighting this duel
+in his presence, when Sir Thomas returned to France, he was tried by his
+brother, the King, upon the charge of treason, and beheaded.[49]
+
+The celebrated trial between the Dukes of Hereford and Norfolk, made
+immortal by Shakespeare, in his Richard II., occurred at Coventry, on
+September 16’, 1398. Hereford appealed the Duke of Norfolk of high
+treason, in Parliament, in the use of words tending to the king’s
+dishonor. Armour and coats of mail had been procured from Germany and
+Milan, for the warriors. Hereford, who was the people’s favorite, came to
+the lists mounted on a white horse, barbed with blue and green velvet.
+Norfolk’s horse was draped with crimson velvet. Ten thousand armed
+knights were in attendance, to prevent an affray and a large concourse
+of the populace attended, to cheer their respective favorites. When the
+combatants faced each other, the King, fearful, no doubt, that Hereford
+would prevail, banished both the combatants. Norfolk soon afterwards
+died, in Venice, but Hereford returned the following year to wrest the
+crown from the weak king and proclaim himself King Henry IV.[50]
+
+A lawyer entered the lists, in the year 1431, when John Upton, a notary,
+accused John Downe of treason, in attempting to accomplish the death of
+the king. The duel was fought in the presence of the king, on the 24’
+of January and the writ, providing for the barriers and the making of
+the lists; the levelling and sanding of the ground and the removal of
+the stones, is fully set forth in Coke, on Littleton.[51] There was a
+fierce fight, but the king pardoned both contestants, before the final
+termination of the trial.[52]
+
+The battle between the armourer’s servant, John Davy and his master,
+William Catur, described by Shakespeare, in the second part of Henry
+VI., was actually fought, on January 31’, 1447. The armourer’s body was
+stripped of its armour and left upon the field of battle and the penalty
+of treason was inflicted, and the trunk was mutilated and the head set up
+on the London Bridge.[53]
+
+The case of Thomas Whithorn, in the year 1455, reported by William
+Gregory, Mayor of London, is not without interest. Whithorn was a
+convicted thief and in accordance with the custom of the period, to save
+his own life, he made a number of appeals against reputable citizens,
+some of whom, because of his physical prowess, were unable to stand up
+against him and were hanged, after unsuccessful trials by battle, with
+him. He finally charged crime against one James Fisher, who, to save his
+life, concluded to fight the thief. Both contestants were clad in white
+sheep’s leather, over their legs, head, face, hands and bodies and they
+fought with green ash staves, three feet long, with an iron ram’s horn
+on the end. Fisher broke his weapon early in the fight and the constable
+then took the approver’s away too and after that they fought “teeth and
+nail.” Fisher finally got the thief’s nose between his teeth and his
+thumbs in his eyes and he so tortured him that he cried “craven” and was
+hanged, “for he was fals unto God and unto hym.”[54]
+
+One of the last battles judicially fought upon English soil was that
+between Sir James Parker and Sir Hugh Vaughan, before Henry VII., in
+1492. The battle was the result of a quarrel about certain arms given by
+the King to Vaughan. The fight occurred at Richmond and resulted in the
+victory of Vaughan over Parker. The former’s spear penetrated the helmet
+of Sir James and cleaved his tongue from his mouth and he died in a short
+time from the wound inflicted.[55]
+
+The last trial by battle that was waged in the court of common pleas at
+Westminster,[56] occurred in the thirteenth year of Queen Elizabeth, A.
+D. 1571. This was the celebrated case of Lowe vs. Paramour, reported by
+Sir James Dyer[57] and also by Sir Henry Spelman,[58] who was himself a
+witness of the trial. The battle occurred in Tothill-fields, Westminster,
+“_non sine magna juris consultorum perturbatione_,” reports Sir Henry
+Spelman.[59]
+
+In the last English case wherein the right of trial by battle was
+recognized, two citizens of the laboring class elected to decide their
+cause by the wager of battle, in 1818. The case was that of Ashford vs.
+Thornton.[60] The facts giving rise to the appeal by Abraham Thornton,
+in 1817, are briefly told. Mary Ashford, of Warwickshire, was drowned,
+under circumstances directing suspicion of foul play, against Thornton.
+He was arrested for her murder and tried and acquitted by a jury,
+but public sentiment was so aroused against him that the dead girl’s
+brother, instituted an appeal for murder against Thornton, and while
+this proceeding, after a jury trial, was quite unusual, the court held
+that the proceeding was proper. Thornton demanded the right of trial by
+battle, and the court held that he was entitled to such a trial, but
+before the trial, in April, 1818, the appeal was withdrawn and Thornton
+was discharged. Upon the legality of the proceeding of trial by battle,
+however, the case proceeded to judgment, before the Court of King’s Bench
+and Lord Ellenborough, for the court, decided that:
+
+ “The general law of the land is in favor of the wager of battle
+ and it is our duty to pronounce the law as it is and not as we
+ may wish it to be; whatever prejudice, therefore, may justly
+ exist against this mode of trial, still, as it is the law of
+ the land, the court must pronounce judgment for it.”
+
+That this judgment was right, few, if any, lawyers would question, as the
+repeal of existing laws is a legislative, not a judicial function; it
+is the province of the courts to expound and apply, not to repeal laws
+regularly enacted and recognized by the legislative branch of government
+and although an absurd law may remain unenforced, because over-looked,
+it is none the less a law, although not enforced, until repealed by the
+proper department.
+
+It was the judgment of the court, in the above case, however, that
+brought about the repeal of the right of trial by battle, in England, by
+the 59’ George III., c. 46.[61] By this statute it was enacted that:
+
+ “Appeals of murder, treason, felony and other offenses, and the
+ manner of proceeding therein, have been found to be oppressive;
+ and the _trial by battle_, in any suit, is a mode of trial
+ unfit to be used; and it is expedient that the same should be
+ wholly abolished.”
+
+Accordingly, the act proceeded to abolish all appeals, in criminal cases
+and,
+
+ “In any writ of right now depending, or hereafter to be
+ brought, the tenant shall not be received to wage battle, nor
+ shall issue be joined, or trial be had by battle in any writ of
+ right.”
+
+Trial by battle was abolished in France, in 1260, by the good Saint
+Louis, for the reason that it often happened that in the contests between
+a rich man and a poor man, the former hired all the champions, and left
+the latter without help.[62] The right to a trial by battle was last
+recognized, in Scotland, near the close of the sixteenth century,[63] so
+it survived in England, after it had long ceased to exist, as a mode of
+judicial proceeding, in the other European countries.
+
+Trial by battle has ever been an interesting theme in English literature.
+And it is little wonder that this sturdy struggle for justice, according
+to the light then obtaining, should be selected as the climax of the
+vivid plots, by the masters of poesy and fiction, depicting the chivalry
+of the age “when knighthood was in flower.”
+
+If human interest were lacking in this antique procedure of the past
+as we read of it in the unadorned details of the trials of the period,
+certainly no one can fail to entertain the deepest concern for the fate
+of the principals we meet with in this struggle for justice, as portrayed
+by the poets and novelists of English literature. And instead of being
+overdrawn, such representations are often but true portrayals of many of
+the concrete cases that have come down to us, of the trials by battle, of
+the past centuries.
+
+The song of Roland, chanted at the battle of Hastings, in the eleventh
+century, was really attuned to the theme of wager by battle, and from
+the appeal, to the conclusion of the duel, between Pinabel and Thierry,
+before Charles the Great, resulting in the punishment of the treason of
+Ganelon, for the fall of Roland, the legal procedure of wager by battle
+of chivalry is truthfully presented, even as the law writers of the
+period would reproduce the history of such a trial.
+
+Chaucer, in his pure and antique style, uses the trial by battle as the
+expression of the chivalry and knighthood shown by Palamon and Arcite,
+in their battle with their hundred chosen warriors, before Theseus, for
+the love of the beautiful Emelye, and accurately portrays the different
+points of law, governing the trial by battle, in his description of this
+combat, from the assembling of the knights,
+
+ “Armed for lystes, up at alle rightes,
+ All redy to derrayne hire by bataylle,”
+
+to the final conclusion of the trial, by the conquering of Palamon and
+his knights.[64]
+
+That the immortal Shakespeare was familiar with the exact details of the
+procedure in trials by battle, is apparent from a perusal of the various
+plays where he introduces this method of trial.[65]
+
+In King Richard II., Thomas Mowbray and Bolingbroke, as “accuser and
+accused,” are introduced, in all of their habiliments of war, into the
+presence of the king, “face to face, and frowning, brow to brow.”[66]
+
+In the same play, a Lord offers the gage to the Duke of Aumerle, in the
+following challenge:
+
+ “_Lord._ From sun to sun, there is my honor’s pawn;
+ Engage it to the trial, if thou dar’st.”[67]
+
+The Duke of Surrey, is likewise made to offer battle, in Richard II., to
+Lord Fitzwater, in the following words:
+
+ “_Surrey._ In proof whereof, there is my honor’s pawn,
+ Engage it to the trial, if thou dar’st.”[68]
+
+Vernon and Bassett implore the right of trial by battle, in 1’ Henry
+VI.,[69] and the details of the trial by battle between the master,
+Horner, and his apprentice, Peter, are set forth, with precision, in II
+Henry VI., much as the details are given in the case from which this scene
+is actually taken by the Poet.[70]
+
+Edgar and his bastard brother, Edmund, are made to try their cause by
+the wage of battle, in King Lear, and the rule of Knighthood, then
+obtaining, is adverted to, giving the challenged one the right to decline
+the combat, if the right were not equal and the wronged Edgar truthfully
+asserts “Yet am I noble as the adversary, I came to cope withal.”[71]
+
+Sir Walter Scott has added the zest of human interest, commonly felt for
+the innocent, wrongfully accused, to the uncertain fate of the gentle
+and lovely Rebecca, falsely accused of sorcery and witchcraft, by the
+valiant and fearless, but selfish, amorous and vacillating Brian de
+Bois-Guilbert, in Ivanhoe, and the trial by battle is utilized as the
+instrument of justice whereby the innocence of this gentle Jewess is
+established.
+
+True to the faith of her fathers, and charitable, out of the goodness
+of her heart, Rebecca ministers to the wants of the peasant and then,
+because she turns a deaf ear to the importunities of the faithless
+Templar, she is arraigned and tried for sorcery and the practice of
+witchcraft, and would have been left without a champion, but for the
+chivalrous conduct of Wilfred of Ivanhoe, who, though sick and maimed,
+placed his implicit faith in the righteousness of his cause and the
+assistance of Divine aid, and the wicked de Bois-Guilbert is stricken by
+a power from on high, because he fought upon the side of an unrighteous
+cause.
+
+From the time that Rebecca offers the gage of battle, until the close of
+this interesting trial, by her tardy champion, who hazarded his life in
+her defense, against such fearful odds, in the tilt-yard of Temple stowe,
+we can but see that the author of this humanly interesting story had
+accurately studied the details of these trials by battle, as given in the
+older books.
+
+After the evidence of the witnesses to her sorcery, had been taken, the
+accused demanded her right of trial by battle, through the service of a
+champion, in “respect of lawful essoine of her body.” The author uses
+the exact words, given by Glanville, whereby she invokes the preliminary
+delay to prepare for trial. The herald opened the court and made
+announcement of the pending issues, in the usual manner; the court was
+regularly adjourned to a day certain for the trial. On the appointed day,
+the details of the trial are presented, just as such trials obtained in
+the courts of chivalry and honour of the period depicted. The accused,
+in the presence of the court, was interrogated, from her black chair,
+placed near the funeral pile, as to her readiness for the combat. She
+begged the indulgence, which the law granted to her, of a short delay,
+after invoking the aid of Divine wisdom, for her deliverance. Her
+champion appears in true knightly fashion at the last moment and after
+gaining the recognition of the court, and permission to do battle for
+his fair principal, he throws the customary words of defiance into the
+very teeth of the false Bois-Guilbert and the battle proceeds, until
+the death of Bois-Guilbert, pronounced by the Court, in accordance with
+the superstition of the times, as a consummation devoutly to be wished,
+because it was, in fact, “the judgment of God.”
+
+In “The Fair Maid of Perth,” Scott also describes the trial by battle as
+used to decide the destinies of the Clan Quhele and the Clan Chattan,
+assisted by the volunteer Henry Wynd, upon the field of North Inch,
+whereat the whole tribe of the Clan Quhele was annihilated in the combat
+with the race of the “Cat-a-Mountain.”[72]
+
+Thackeray had also studied the procedure of trial by battle, for he
+introduces it into his plot in his realistic story of “Henry Esmond”
+and Crockett, in his “Black Douglas,” makes the Earl William and James
+Douglas, of Avondale, enter into a legal trial by battle, just as the law
+of Scotland in the fifteenth century governed such trials.
+
+But it is not the purpose of this chapter to treat extensively of trials
+by battle, as presented in the literature of England, but only to trace
+the rise, growth and decay of this mediaeval institution, as evidenced
+by the law writers of the past and illustrated by the works of poetry
+and fiction, portraying this ancient mode of trial, which was superceded
+by the fairer method of jury trial and with the other barbarous customs
+of the dark, misty past, has faded away, with the generations that have
+crept to rest, before the dawn of our modern jurisprudence.
+
+
+FOOTNOTES:
+
+[1] Herbert’s Antiquities, pp. 110, 130; Coke, Lyttleton, sec. 294.
+
+[2] Neilson says: “Trial by combat came into existence—no tradition knows
+when.” Neilson’s “Trial by Combat,” p. 1.
+
+[3] 1 Samuel, XVII., 8, 9.
+
+[4] The Mirror (C. 3, Par. 23) states that the trial by battle was
+allowable upon the warranty of the combat between the Shepard King of the
+Israelites and the Giant of the Philistines, but Pope Nicholas I. quite
+seriously decides this precedent to be inconclusive. (Decret. Par. 2,
+Caus. 2, qu. 5, c. 22.)
+
+The belief that the Deity would interfere on the side of the right, in
+these combats, originated with the institution itself, for we are told,
+that when King Gundobald, in the year 501, decreed the trial by battle as
+an antidote to perjury, he replied to the remonstrances of the churchmen
+by the argument that “The event both of national wars and private combat
+is directed by the judgment of God and Providence awards the victory to
+the juster cause.” (II. Gibbon, ch. 38; Esprit des Lois, book 28, ch. 17;
+Neilson’s Trial by Combat, p. 6.)
+
+Neilson rejects the suggestion that trial by battle was divinely
+instituted when David, with his Sling, slew the mighty man of war of
+the Philistines, as did Pope Nicholas First, in the year 867. Neilson’s
+“Trial by Combat,” p. 2.
+
+[5] Velleius Paterculus, ii, ch. 117; Tacitus, Germania, ch. 10; Neilson,
+“Trial by Combat,” p. 4.
+
+[6] Neilson, “Trial by Combat,” p. 10.
+
+[7] Selden, on Duels, ch. 5; Herbert’s “Antiquities of Inns of Court,”
+pp. 109, 115; Bl Com.
+
+[8] Stiernh. de jure Sueon, I. 1. c. 7.
+
+[9] Herbert’s “Antiquities of Inns of Court,” p. 109, 115.
+
+[10] Henrion de Pansey, _Auth. Judic._ Introd. E. 3.
+
+Some historians trace the origin of trial by battle to the fact that
+perjury became so prevalent that this procedure was resorted to to avoid
+the evil effects of this crime. (I. Pollock and Maitland’s History
+English Law., p. 50.)
+
+It is rather to be accounted for by the fact that it originated in the
+customs of a warlike race, where force and superstition were a part of
+the habits and customs of the people. (Lea. “Superstition and Force,” 4
+ed. p. 409.)
+
+The Burgundian and Lombard rulers, in accordance with the natural
+fighting tendency of their subjects, were brought to recognize the trial
+by battle, because it combined the physical joy of battle with the higher
+ideals of an approved formal procedure, whereby the virtue known as
+justice was supposed to be attained. In other words, the trial by battle
+was the natural expression of the inclinations of both ruler and subject
+of the period when it was established and crept into the established
+procedure of the period, just as naturally as did the superstitions of
+the past centuries,—the belief in witchcraft and ghosts,—find expression
+along with the gems of literature of the same and a later period. The
+institution was a product of the barbarism of the time. And trial by
+battle was recognized as a form of ordeal which obtained among the
+warlike German tribes from very ancient times, but it was not practiced
+by the ancestors of the Anglo-Saxons. (I. Pollock and Maitland’s History
+English Law, p. 51.)
+
+[11] Neilson, in speaking of the effect of chivalry, upon the trial by
+battle, observed: “It reached its legal prime in the early feudal ages
+and enjoyed a new era of activity under the auspices of later chivalry.”
+Neilson’s “Trial by Combat.” p. 1.
+
+[12] This is _de hors_ the subject at hand, but demonstrates that
+chivalry and heroism are still abroad in the land and that these virtues
+are confined to no particular class.
+
+[13] 3 Cooley’s Bl. Com. 104; Coke, Litt. 261.
+
+[14] _Ante idem._
+
+[15] Comyns Dig. 252.
+
+Neilson states that private duels succeeded trial by battle, in the
+16’ and 17’ centuries, but of course trial by battle was not abolished
+in England until the year 1819, and duelling had continued for several
+centuries then. (Neilson’s “Trial by Combat,” pp. 18, 328.)
+
+[16] Coke, Litt. 261.
+
+[17] 2 Hawk. P. C. c. 45.
+
+[18] Neilson’s “Trial by Combat,” p. 40.
+
+[19] Coke, III. Inst. 157; I. Russell, Crimes, 495.
+
+That Trial by Battle was introduced into England by the Normans, is now
+quite generally conceded. “One ordeal the Normans recognized which had
+no place in English law, namely, the ordeal of battle.” I. Pollock and
+Maitland’s History Eng. Law, p. 74.
+
+We find that William of Normandy, with his studious desire to preserve
+English institutions and protect Englishmen, in defining the procedure
+which should obtain if a Frenchman accused an Englishman, or _vice
+versa_, provided that the Englishman whom a Frenchman accused had the
+choice between battle and ordeal, but if the Englishman accused the
+Frenchman, the former had the right to compel the latter to join battle,
+or otherwise the Frenchman could swear away the charge, with oath
+helpers, according to Norman law. The Englishman was thus recognized as
+the Norman’s peer, but as was not accustomed to the ordeal by battle, he
+was given the choice of this procedure, if he preferred to avail himself
+of it, and the Norman, by a strict rule of justice, was required to purge
+himself, even though the Englishman would not fight. (Laws of William, c.
+6; Forschungen, 328; I. Pollock and Maitland’s History English Law, pp.
+89, 90.)
+
+For reference to the trial by battle, during the reigns of William I. to
+Henry II., see, I. Reeve’s History English Law, pp. 329, 331, and note
+citing the Mirror.
+
+[20] Neilson’s “Trial by Combat,” pp. 188, 189.
+
+[21] II. Pollock and Maitland’s History English Law, p. 632, Bracton,
+fol. 347.
+
+[22] Leg. Hen. 59, sec. 16.
+
+[23] I. St. Westm. c. 41.
+
+[24] Bracton, fol. 152, 153; Select Pl. Crown, pl. 109, 140, 190, 199.
+
+[25] Neilson’s “Trial by Combat,” pp. 56, 57.
+
+In the class of civil or criminal cases where the right of trial by
+battle obtained, when the plaintiff offered battle, the defendant was
+bound to accept the offer. Having offered to defend the charge preferred
+against him, in legal contemplation, he volunteered to defend it with
+his own body, or with the body of his freeman, “when and where the court
+shall consider that defend he ought.” He then tendered his gage and
+pledges to the court that on the given day set, he would perform the task
+assigned to him. (Year Book, 21, 22, II. Edw. I., pp. 9, 167; II. Pollock
+and Maitland’s History English Law, pp. 610, 611.)
+
+The champion, originally, was a witness and it was as such that he
+intervened. In a plea for land, he testified to having seen the seisin
+and that either he or his father saw the claimant in the possession of
+the land. (Neilson’s “Trial by Combat,” p. 48.)
+
+While hired champions were forbidden by the law, it became a very common
+practice and Neilson gives many such contracts in his interesting and
+thorough book, on “Trial by Combat,” pp. 48, 54.
+
+Maynard’s Year Books, contain the history of many trials occurring during
+the reigns of Edward III. and Henry VI. The report of one such trial, in
+the year 1329, describes the champions as appearing with shaven heads,
+ungirt coats, bare legged and bare armed, tendering a glove, with a penny
+in each finger, to the judge, who afterwards offered the pennies on the
+altar of the nearest church, in order that “God might give the victory to
+him who was in the right.” (Maynard’s Year Books, I. Henry VI., pp. 6, 7;
+_idem._ 21 Henry VI., pp. 19, 20.)
+
+As the pugilists of the present day, have managers, who conduct the
+combats between the champions for the wager of the ringside, so men of
+the thirteenth century kept pugilists for hire, whose services were quite
+generally used in these trials. One of these champions was Richard of
+Newnham, whose master, or manager, was William of Cookham (Note Book, pl.
+185, 400, 551), whose expert services were much in demand about the year
+1220.
+
+[26] Neilson’s “Trial by Combat,” p. 40; Maddox, 71, 66, 311, 349, 379.
+
+[27] III. Reeve’s History English Law, p. 329.
+
+[28] 22 Edward IV., 19; IV. Reeve’s History English Law, p. 58.
+
+[29] 37 Henry VI. 20; IV. Reeve’s History English Law, p. 58.
+
+[30] II. Pollock and Maitland’s History English Law, p. 214.
+
+[31] Herbert’s “Antiquities of Inns of Court,” p. 130.
+
+[32] Neilson’s “Trial by Combat,” p. 46.
+
+Clergymen were exempted from the trial by battle and by 41 Edward III.,
+an appellant, on entering the field of battle could avoid the fight, by
+praying his clergy. (Herbert’s “Antiquities of the Inns of Court,” 130.)
+
+By the Charter of London, the following citizens were also exempted from
+trial by battle, _viz._, _sexagenarii_, or men of three score years;
+_coecus_, or those blind by accident after issue joined. (_Ante idem._)
+
+The exemption granted by Henry I., by the Charter of London, was followed
+by many other similar exemptions. Newcastle-on-Tyne, Norwich, Oxford and
+Winchester, soon followed and almost every borough strove to procure like
+exemptions. (Stubbs’ Charters, Thompson’s English Mun. History.)
+
+Mayhem was a good ground for exemption from trial by combat. Crown Pleas,
+No. 4, 9; Bracton, ii, 458, 468; Glanville, XIV., ch. I; Neilson’s “Trial
+by Combat,” 46.
+
+[33] Beames Glanville, pp. 36, 41; Herbert’s “Antiquities of the Inns of
+Court,” pp. 110, 115.
+
+[34] An _essoin_ is defined by Sir Edward Coke as an excuse, the term
+being taken from the French verb, _essonier_, or _exonier_. The term was
+introduced into England by the Normans. Note to Beame’s Glanville, p. 6.
+
+[35] Beames, Glanville, p. 41; Herbert’s “Antiquities of Inns of Court,”
+115.
+
+[36] Selden, impr. Duello, Lond. 1610; Herbert’s “Antiquities of the Inns
+of Court,” pp. 115, 117; Select Pleas of Crown, Pl. 87; II. Pollock and
+Maitland’s History English Law, p. 634.
+
+During the twelfth century, in controversies between the Lord paramount
+and the tenant as to the right to the possession of real estate, the duel
+or battle was a method of trial generally in vogue. In the reign of Henry
+II., while the tenant, in a writ of right, had his election to defend his
+title by duel, “as a royal benefit conferred on the nation, by the prince
+in his clemency, by the advice of his nobles, as an expedient whereby
+the lives and interests of his subjects might be preserved, and their
+property and rights enjoyed _without being any longer obliged to submit
+to the doubtful chance of the duel_,” we find the institution of the
+_assize_ guaranteed to the subjects by the king, and this constitution
+is perhaps the first guaranty of the trial by jury in the English law.
+(Glanv. lib. 2, c. 4, 5, 6; I. Reeve’s History Eng. Law, pp. 393, 395.)
+
+The proceeding for the recovery of land during the reign of Henry II. and
+preceding reigns, is not without interest. The claim of the demandant,
+or claimant, was based only upon evidence _de visu et auditu_, or by the
+proof furnished by his freeman, whose evidence was either as to what he
+had actually seen and knew, or upon what his father had told him, and had
+enjoined upon him, on his death-bed, by the faith that a son owed to a
+father, which he was to assert, if he ever heard of any plea being urged
+as to the land in controversy. (Glanv. lib. 2, c. 3.)
+
+If the tenant elected to try the issue by the duel, or battle, he could
+not afterwards resort to the assize, but must meet the issue _de verbo
+in verbam_, as the demandant, or claimant had asserted his title. The
+demandant could not be his own champion, but the tenant could defend
+himself, either in person or by a champion, and after the customary
+essoins, the battle proceeded. If the champion of the demandant was
+conquered, the demandant lost his suit and the champion was never again
+a competent witness in a duel. If the champion of the tenant, or the
+tenant himself was conquered, he lost the land with all the fruits and
+produce on it, and he was never afterwards to be heard in a court of
+justice concerning the same. In other words, the final effect of a trial
+by battle was as conclusive as the judgment of a court of competent
+jurisdiction and furnished the basis for a good plea of _res adjudicata_
+in all subsequent controversies over the same land in the future, between
+the same parties. (Glanv. lib. 2. c. 4, 5; I. Reeve’s History Eng. Law,
+p. 394.)
+
+Neilson complains because neither Glanville, Bracton, Britton, nor
+Fleta, describe the procedure governing the actual fighting of the duel
+in an English plea for land under a “writ of right.” (Neilson’s “Trial
+by Combat,” p. 86.) The above description of such a combat, is deemed
+accurate, from sources consulted and for the authorities consulted, the
+reader is referred to Herbert’s “Antiquities of the Inns of Courts,” pp.
+115, 117.
+
+[37] Selden, Duello, impr. Lond. 1610; Mich. 6 R. I. ret. 3.
+
+[38] This is a quotation from an old manuscript book, belonging to Sir
+Edw. Windham, knight, Marshal of the Camp, to King Henry VIII. See,
+Herbert’s “Antiquities of the Inns of Court,” pp. 119, 131.
+
+[39] Coke, Litt. 287; 4 Shars. Bl. Comm. 312, 318, and notes.
+
+[40] Neilson’s “Trial by Combat,” p. 3.
+
+[41] Livy, book I., ch. 24, book 28, ch. 21.
+
+[42] Geoffrey of Monmouth, lx, ch. II; Neilson’s “Trial by Combat,” p. 25.
+
+[43] Neilson’s “Trial by Combat,” p. 8.
+
+[44] If this procedure obtained today, it would have a wholesome effect,
+in some of the disgraceful controversies in our divorce courts.
+
+[45] Lea, “Superstition and Force,” (4 ed.) 120.
+
+Thayer states that the earliest reference to the trial by battle in
+English adjudicated cases, is that of Bishop Wulfstan vs. Abbot Walter,
+in the year 1077. (Essays in Anglo-Saxon Law, 379; Bigelow’s Placita
+Anglo-Normanica, 19; Brunner, Schw. 197, 400-1; Thayer’s Older Modes of
+Trial, V. Harvard Law Review, 66; II. Essays in Anglo-American Legal
+History, 397.)
+
+The history of cases of trial by battle that were preserved, in England,
+prior to Glanville’s time, are to be found in Bigelow’s Placita
+Anglo-Normanica.
+
+[46] I. Ancient Laws England, 494; Neilson’s “Trial by Combat,” p. 59.
+
+[47] Carlyle’s “Past and Present,” book II., ch. 14; Jocelin of
+Brakelond’s Chronicle, p. 52; Neilson’s “Trial by Combat,” pp. 61, 62.
+
+[48] Neilson’s “Trial by Combat,” pp. 43, 44.
+
+[49] Galfridus le Baker, 208, 210; Walsingham, i, 275; Myrick, ii, 32;
+Neilson’s “Trial by Combat,” pp. 168, 170.
+
+[50] Hall, 4; Adam of Usk, 131; Trekolowe, 225; Neilson’s “Trial by
+Combat,” pp. 190, 193.
+
+[51] IV. Coke, Littleton, ed. 1817, ch. 17.
+
+[52] John Stowe’s Survey, iii, 239, 371; Neilson’s “Trial by Combat,” 199.
+
+[53] Gregory, 187; Nichols’ “Illustrations of Manners,” (1797) p. 217;
+John Stowe, 385; Neilson’s “Trial by Combat,” p. 201.
+
+[54] Gregory, 199, 200; Neilson’s “Trial by Combat,” pp. 154, 157.
+
+[55] John Stowe, 475; Neilson’s “Trial by Combat,” pp. 203, 204.
+
+[56] Afterwards a battle occurred in the court of chivalry, in 1631.
+(Rushw. Coll. vol. II., part 2, fol. 112; 19 Rym. 322.) And another in
+the county palatine of Durham, in 1638. (Cro. Car. 512.)
+
+[57] Dyer, 301.
+
+[58] Spelman’s Gloss (_sub voc._ Campus, 1625), 102.
+
+[59] _Ante idem._
+
+[60] I. Barn. & Ald. 405.
+
+[61] I. Barn. & Ald. 405; 3 Shars. Bl. Comm. 339; 4 _idem._ 347.
+
+[62] Grandes Chroniques de France, M. Paulin, Paris, vol. IV., pp. 427,
+430; Brunner, Schw. 297; “Older Modes of Trials,” by Thayer, V. Harvard
+Law Rev., p. 67; II. Essays in Anglo-American Legal History, note, p. 398.
+
+[63] Stephens’ History Criminal Law, in England; Neilson’s “Trial by
+Combat,” p. 319.
+
+The reader, interested in following the many illustrations of the
+trial by combat, in individual instances occurring at various periods
+during the centuries from 1100 to 1600, in Scotland, will find copious
+references to such trials, in Neilson’s “Trial by Combat.”
+
+[64] For full explanation of the different legal phases presented in this
+poem, see, Neilson’s “Trial by Combat,” pp. 180, 188.
+
+[65] See White’s “Law in Shakespeare,” for full discussion of this and
+other scenes on “Trial by battle,” as used by Shakespeare.
+
+[66] King Richard II., Act I., scenes I. and III.
+
+[67] King Richard II., Act IV., Scene I.
+
+The dramatic quarrel between Henry, earl of Hereford (afterward King
+Henry IV.) and the Duke of Norfolk, presented by Shakespeare in his play,
+Richard II., is described by a graphic writer in Herbert’s “Antiquities,”
+pp. 145, 146.
+
+[68] King Richard II., Act IV., Scene I.
+
+[69] Act IV., Scene I.
+
+[70] Act I., Scene III., and Act II., Scene III.
+
+[71] King Lear, Act V., Scene III.
+
+For exposition of the above portions of Shakespeare’s plays, dealing with
+“Trial by Battle,” see, White’s “Law in Shakespeare,” Sec. 191, pp. 229,
+232.
+
+[72] The combat between the Clan Chattan and Clan Kay, on the Inch of
+Perth, made memorable by this great novelist, actually occurred in the
+year 1396. (Neilson’s “Trial by Combat,” 239; 244; 250; Bower, xv, ch.
+3.)
+
+
+
+
+CHAPTER V.
+
+TRIAL BY ORDEAL.
+
+
+Trial by ordeal was the method used to ascertain the guilt or innocence
+of a person accused of crime, according to his ability to perform certain
+acts, or accomplish results which would, in the ordinary course of
+events, be hurtful to him.[1]
+
+If the suspected criminal was injured or killed in the performance of
+the act required of him, he was adjudged guilty, but if he performed the
+part assigned to him without injury, he was declared innocent. The tests
+that the suspected person was subjected to were called ordeals,[2] or
+judgments of God.
+
+The custom of referring disputed questions such as the guilt or innocence
+of a person accused of crime, to the judgment of God, to be determined
+either by lot, or the success of certain dangerous experiments, has
+existed, from the earliest times, among various widely separated nations
+and peoples.[3]
+
+We find that according to the “law of jealousies,” laid down in the
+Mosaic code Fifteen hundred years before Christ, the guilt of a woman,
+accused of infidelity, by her husband, was determined according to this
+trial of ordeal, for it is recorded:
+
+ “And the spirit of jealousy come upon him, and he be jealous
+ of his wife, and she be defiled; or if the spirit of jealousy
+ come upon him and he be jealous of his wife, and she be not
+ defiled; then shall the man bring his wife unto the priest....
+
+ And the priest shall charge her by an oath, and say unto the
+ woman, If no man have lain with thee, and if thou hast not gone
+ aside to uncleanness; with another, instead of thy husband, be
+ thou free from this bitter water, that causeth the curse: ...
+
+ And he shall cause the woman to drink the bitter water that
+ causeth the curse; and the water that causeth the curse shall
+ enter into her, and become bitter....
+
+ And when he hath made her to drink the water, then it shall
+ come to pass that, if she be defiled, and have done trespass
+ against her husband, that the water that causeth the curse
+ shall enter into her and become bitter, and her belly shall
+ swell and her thigh shall rot; and the woman shall be a curse
+ among her people.
+
+ And if the woman be not defiled, but be clean, then shall she
+ be free, and shall conceive seed.”[4]
+
+Compurgation of accused persons, by fire, existed among the ancient
+Greeks,[5] and the Hindus practiced ordeal in nine different ways,—by
+the balance, by fire, by water, by poison, by the _cosha_, or drinking
+water, in which the images of the sun and other deities had been washed,
+by chewing rice, by hot oil, by red hot iron, and by drawing two images
+out of a jar, into which they had been thrown.[6]
+
+The most generally used ordeals throughout ancient Europe were: Trial by
+battle, in which the vanquished one was adjudged guilty; trial by the
+ordeal of fire; trial by water; trial by the corsned; the trial of the
+eucharist; the trial by the cross and the test by judgment of the bier.
+
+In trial by battle, the accuser and accused fought in mortal combat to
+determine the guilt or innocence of the suspected person.[7] In the trial
+by fire, the accused walked bare-footed, over red hot plow-shares, or
+coals of fire,[8] carried a red hot iron in his hand, or walked through
+flames, clad in a suit of wax, spread over woolen cloth, known as the
+“trial of the waxen shirt,” because if he was unhurt by the fire and the
+wax was unmelted, he was considered innocent, but otherwise was adjudged
+guilty.[9]
+
+The trial by water was either by cold or boiling water. If the former,
+which was the test usually applied to witches, the guilt was determined
+by the ability of the accused to float or sink, when cast into the
+water.[10] Where the ordeal by boiling water was used, the accused had to
+take a stone out of boiling water, by inserting his hand into a caldron,
+containing boiling water, as deep as his wrist, and if the triple ordeal
+was used, the boiling water was deepened so that he had to insert his arm
+as far as the elbow to get the stone.[11]
+
+In the _offa execrata_, or corsned ordeal, a priest put the corsned or
+hallowed cheese and bread, in the mouth of the accused, with various
+chants and imprecations and if he swallowed it, he was freed from the
+judgment, but if it stuck in his throat, he was held to be proven guilty
+of the offense with which he was charged.[12]
+
+The test of the eucharist was chiefly applied among the monks and clergy,
+for it was believed that when they took the test, God would smite the
+guilty, with sickness or death.[13]
+
+In the ordeal of the cross, the accuser and accused were placed under
+the cross, with their arms extended, and the one whose hands moved first
+was adjudged to be the guilty one and the other the innocent. A trial by
+lot, similar to this latter ordeal, occurred when the accused was placed
+before certain relics with two dice before him, one of which was marked
+with a cross. If the cross was selected, at hazard, he was acquitted, but
+otherwise was adjudged guilty.[14]
+
+And finally, the ordeal known as the judgment of the bier was used
+to determine the guilt of the accused, under a charge of murder. The
+deceased, supposed to have been murdered, was placed upon a bier, and the
+accused was made to touch his body. If blood flowed, or foam appeared
+in the mouth of the murdered person, or the body changed position, the
+accused was adjudged guilty of the murder, but if none of these signs
+appeared, he was acquitted.[15]
+
+According to the Institute of Narada,[16] the ordeal was used four or
+five centuries before Christ, in India, for we find that the balance,
+fire, water, poison and the sacred libation, were considered the five
+divine tests, for determining the guilt or innocence of suspected persons.
+
+From the formulas given in the Institute of Narada, the most solemn
+ceremonies accompanied the application of the tests used in the trials by
+ordeal, in India, in ancient days. In describing the different tests, it
+is said:
+
+ “Having adjured the balance by imprecation, the judge should
+ cause the accused to be placed in the balance again. ‘O
+ balance, thou only knowest what mortals do not comprehend.
+ This man, being arraigned in a cause, is weighed upon thee.
+ Therefore mayst thou deliver him lawfully from his perplexity.’
+ ... If the individual increased in weight, he was adjudged
+ guilty; if he was found to be lighter or equal in weight, his
+ innocence was established.
+
+ In the ordeal of fire, the judge thus addressed the fire:
+ ‘Thou, O fire, dwellest in the interior of all creatures,
+ like a witness. Thou only knowest what mortals do not
+ comprehend. This man is arraigned in a cause and desires
+ acquittal. Therefore, mayst thou deliver him lawfully from his
+ perplexity.’ ... Seven circles of fire, with a diameter of a
+ foot each and thirty-two inches distant from each other were
+ marked on the ground, and the man, having fasted and cleansed
+ himself, has seven _acvattha_ leaves fastened on his hands and
+ he takes a smooth ball of red hot iron in his hands and walks
+ slowly through the seven circles of fire and deposits the ball
+ on the ground. If he is burnt, he is adjudged guilty, but if he
+ is unburnt, he is declared innocent.
+
+ In the ordeal of water, the judge adjures the water, as in the
+ preceding tests, by the balance and by fire, and the accused
+ wades into water to his waist, while another shoots an arrow.
+ The accused dives into the water and if he remains under while
+ a swift runner returns the arrow, he is innocent, but otherwise
+ is adjudged guilty.
+
+ In the poison ordeal, after the selection of the particular
+ poison the judge thus adjures the poison: ‘Thou, O poison,
+ art the son of Brahma,[17] thou are persistent in truth and
+ justice; relieve this man from sin and by thy virture become
+ an ambrosia to him. On account of thy venomous and dangerous
+ nature, thou art the destruction of all living creatures; thou
+ art destined to show the difference between right and wrong,
+ like a witness.’ The accused person eats the poison and if it
+ easily digested, without violent symptoms, the king shall
+ recognize him as innocent, and dismiss him, after having
+ honored him, with presents.
+
+ In the ordeal of sacred libation, the judge should give the
+ accused water in which an image of that deity to whom he is
+ devoted, has been bathed, thrice calling out the charge, with
+ composure. One to whom any misfortune or calamity happens,
+ within a week, or a fortnight, is proved to be guilty.”[18]
+
+Charlemagne apparently did not place much dependence in the _judicium
+Dei_, by means of the ordeal, at the beginning of his reign, for in 779,
+by his edict the trial by ordeal was to be used in the more trifling
+offenses, while cases of greater magnitude were to be tried by the civil
+law of the realm.[19]
+
+Later on in his reign, however, by his edicts of the year 806 and 809
+this monarch seems to have come to regard the ordeal with much greater
+favor, for he frequently referred to this method of trial; when dividing
+up his empire between his sons he directed that all disputes should be
+settled by ordeal, and endeavored to force a greater regard for the
+judgments in trials by ordeal, on the part of the subjects, whom, it
+seems, had come to entertain his own early distrust in this species of
+trials.[20]
+
+It seems that Charlemagne completely believed in the efficacy of the
+ordeal, by the year 794, for we are told that in this year, a certain
+Bishop Peter, who was condemned by the Synod of Frankfort to clear
+himself of the suspicion of complicity in a conspiracy of treason
+against Charlemagne, being unable to obtain conjurators, one of his
+vassals offered to attempt the test of the ordeal, as his proxy, and
+on his success, the Bishop was adjudged innocent of the charge and was
+reinstated.[21]
+
+Soon after the death of Charlemagne, in the year 816,
+Louis-le-Debonnaire, at the Council of Aix-la-Chapelle, prohibited the
+continuance of the ordeal of the cross,[22] because it had a tendency to
+bring the Christian symbol into contempt and his son, the Emperor Lothair
+also issued a similar edict against the use of this ordeal, after he
+assumed the reigns of government.[23]
+
+Among the early Saxons, the ordeals by fire and water were practiced,
+for we find that the _ordale_ signified _judicium aequum, justum,
+indifferens_, “an upright, just and indifferent judgment.”[24]
+
+Tacitus tells us that the ancestors of our Saxon forefathers, during
+pagan times, were addicted to divination and risked certain results upon
+the flying of birds, the neighing of horse and trial by combat.[25] And
+trial by ordeal was used by them in both civil and criminal cases, to
+determine the issues later solved by the testimony of witnesses, or the
+oaths of compurgators.[26]
+
+The ordeal of hot water appears in the laws of Ine,[27] who began his
+reign in the year 710, and the ordeals by fire and water had become
+so common by the time of King Athelstan, that we find the procedure
+governing such trial, fully covered by his Constitutions,[28] by which
+they were considered in the light of religious ceremonies:
+
+ “Concerning ordeal, we command, in the name of God, and by the
+ precept of our archbishops and bishops, that no man enter into
+ the church after the fire is brought in, wherewith the judgment
+ is to be made hot, except the priest, and he who is to undergo
+ the trial; and let there be measured nine feet from the stake
+ unto the mark, according to the measure of the foot, who is to
+ come thus to judgment.
+
+ And if the trial be by water, let it be made hot, till it boil,
+ in a vessel of iron, brass, lead, or clay; and if it be single,
+ let his hand be put therein after a stone or stock up to his
+ wrist; but if the accusation be threefold, then to his elbow;
+ and when the judgment shall be prepared, let two men be brought
+ in on either side, to make experiment, that it be as hot as is
+ afore expressed.
+
+ Let as many also come in on each side the judgment, along the
+ church; and let them be fasting and abstain from their wives
+ that night; and the priest shall sprinkle holy water on them,
+ and give them the text of the holy gospel to kiss, as also the
+ sign of the cross; and no man shall make the fire any longer
+ than whilst the benediction beginneth, but shall cast the iron
+ upon the coals until the last collect; afterwards it shall be
+ put upon the _ceac_ (cauldron)[29] without any more words, then
+ that they pray earnestly to God that he will vouch safe to
+ manifest the truth therein; then shall the person accused drink
+ holy water and his hand wherewith he shall carry the judgment
+ shall be sprinkled therewith; and so let him go, the nine feet
+ measured being distinguished by three and three.
+
+ At the first mark next to the stake, he shall set his right
+ foot and at the second his left foot; and thence he shall
+ remove his right foot unto the third mark, where he shall
+ throw down the iron and hasten to the holy altar; which done,
+ his hand shall be sealed up, and the third day after viewed,
+ whether it be clean or unclean where it was so sealed. And
+ he who shall transgress these laws, let the ordeal judgment
+ or trial be done upon him, that he pay 120 s. for a fine or
+ mulct.”[30]
+
+For three days before the trial, the accused was to attend the priest,
+to be constant at mass, to make his offering and in the interim, to
+sustain himself on nothing but bread, salt, water and onions. On the day
+of the trial he was to take the sacrament and swear he was not guilty
+of the crime imputed to him. The accuser and accused both came to the
+place of trial, with not more than twelve persons each, to stay any
+interposition or violence and the accuser then renewed his charge upon
+oath and the accused made his purgation on oath also. If the ordeal was
+by hot water, he put his wrist or arm into the boiling water, accordingly
+whether it was the simple or triple test, and if the trial was by cold
+water, his thumbs were tied to his toes and he was cast into the water.
+If he escaped the boiling water unhurt, or sank in the cold water, he was
+adjudged innocent, but if he was burned by the hot water, or swam in the
+cold water, he was adjudged guilty, as charged by his accuser.[31]
+
+These trials by water and fire were called _judicium Dei_, or, as the
+Mirror of Justice puts it, miracles of God, but “Christianity suffered
+not that they be by such wicked arts cleared, if one may otherwise avoid
+it.”[32]
+
+From this observation in the Mirror, it has been contended that the
+Anglo-Saxons distinguished between open and manifest offenses and those
+not so public as to be susceptible of proof and that trial by ordeal was
+only used in the latter class of crimes.[33]
+
+It is true that in Alfred’s time there were trials by jury, and it seems
+that trial by ordeal may have been re-established, after trial by jury,
+in doubtful cases, as a refuge or solution of an otherwise doughty
+problem for the barbarian mind to solve.[34]
+
+Pursuance to the terms of a certain league, made between Edward the Elder
+and Guthrun, the Dane, ordeals were forbidden upon festivals or fasting
+days[35] and the same provision was inserted in the constitution made by
+the synod held at Eanham, under King Ethelred.[36]
+
+The laws of Canute and Edward the Confessor also contained provisions
+forbidding trials by ordeal upon festivals or fasting days, for we read
+that the _judicium Dei_, upon these auspicious occasions, was to be
+postponed, until the affairs of mortals could be better arranged for its
+reception, by the following provision:[37]
+
+ “We forbid ordeals and oaths” (the name law trials at that
+ time were called) “on feast days and ember days, and from the
+ advent of our Lord till the eighth day after twelfth be past;
+ and from Septuagesima till fifteen nights after Easter. And the
+ sages have ordained that St. Edward’s day shall be festival all
+ England on the fifteenth cal. of April, and St. Dunstan’s, on
+ the fourteenth cal. of June; and that all Christians, as right
+ it is, should keep them hallowed and in peace.”
+
+In the simple ordeal, of the Anglo-Saxons, the hot iron weighed one pound
+and in the triple ordeal, it was to weigh three pounds. The triple ordeal
+was used in the crimes of arson and murder, treason and forgery.[38]
+
+In the laws of Edward the Elder, perhaps the earliest reference in
+Anglo-Saxon laws, to the ordeal, it was provided that perjured persons,
+or those once convicted should not thereafter be deemed oath-worthy, but
+on their accusation, should be hurried to the ordeal,[39] and similar
+provisions are to be found in the laws of Ethelred, Cnut and Henry I.[40]
+
+Trial by ordeal at first carried with it the sanction of the priest, as
+well as the civil power and the clergy continued to approve and interject
+the spiritual portion of the proceeding, until the early portion of the
+thirteenth century.[41] Under the law of William the Conqueror, the
+conduct of the ordeal, as a known ecclesiastical procedure, was declared
+to be the business of the bishop, but the civil and spiritual powers were
+to co-operate harmoniously, in the trial by ordeal, the court of the
+hundred making the original order by which a man was sent to the ordeal
+of fire or water, but the bishop presided at the ceremony and regulated
+the course of the proceeding, in accordance with the solemn religious
+ceremony, whereby the element used was blessed and the Divine Wisdom of
+Omnipotence was invoked to the conclusion of the whole proceeding.[42]
+
+The Normans were attached to the procedure, elsewhere discussed, as the
+_trial by battle_ and they did not relish a procedure which seemed to
+them to be a mere superstitious formality, fit only for women and old or
+maimed men. However, ever since the reign of Ina, the Saxons had been
+accustomed to the ordeal and the laws of Ina and later monarchs continued
+in effect, and the accused person was entitled to select the ordeal of
+hot iron, or that of hot water and to undergo, under the supervision of
+the priest or bishop, a trial, to determine his guilt or innocence of the
+offense charged.[43]
+
+In the year 1166, in the Assize of Clarendon, and again in the year 1176,
+in the Assize of Northampton, Henry II. provided for a public mode of
+accusation for the capital felonies and trial by ordeal was the method
+of procedure fixed to determine the guilt or innocence of the person
+charged.[44]
+
+Prior to the thirteenth century perjury was so common and it was so
+impossible to avoid the effects of a false oath, by the proceedings of
+men, that the Laws of Henry provided that “No one is to be convicted of a
+capital crime by testimony.”[45] Mere human testimony was not enough to
+send a man to the gallows, but one accused of a capital offense was to be
+entitled to one of the old-world sacred processes, wherein the _judicium
+Dei_, was supposed to take the place of the false standards, too often
+erected by ordinary mortals. The ordeal was then so far “the law of the
+land” that one accused of a capital offense, who refused the ordeal,
+could be executed, as an outlaw, because he had thus defied the law of
+the realm. But one who had not been accorded this “law of the land,”
+based upon the sacred and Divine belief in the infallibility of the test
+of ordeal, could not legally be condemned, as trial by jury or by the
+oaths of witnesses was not yet an accredited method of procedure in cases
+of capital offense.[46]
+
+Glanville tells us that in his time, about the year 1187, an accused
+person, who was so far disabled by mayhem that he could not test his
+guilt or innocence by the ordeal of battle, was entitled to the ordeal of
+fire or water, to determine his guilt or innocence, this author of the
+first law book observing:[47]
+
+ “In such case, the Accused is obliged to purge himself by the
+ Ordeal, that is, by the hot Iron, if he be a free Man—by water,
+ if he be a Rustic.”
+
+This corresponds with the statement elsewhere made, that in the early
+use of this trial, the hot iron ordeal, was confined to the nobility, or
+patricians, while the water ordeal was generally used among the common
+people, accused of minor offenses or other than the capital felonies.[48]
+
+By the latter part of the twelfth century, the ordeal had become so
+discredited, in the time of Henry II. that the law of that reign provided
+that any one charged before the king’s justices with the crime of
+murder, theft, robbery, or the receipt of such offenders, or of arson,
+or forgery, by the oaths of twelve knights of the hundred, or of twelve
+free and lawful men, in the absence of such knights, should submit to
+the water ordeal, and if he failed in the experiment, he should lose
+one foot; and this law afterwards amended, at Northampton in order to
+make the punishment more severe and the felon also lost his right hand,
+as well as one of his feet. He was also required to abjure the realm,
+within forty days and even though he was acquitted by the water ordeal,
+he was required to find pledges to answer for his good behavior, and if
+he were later charged with murder, or other felony, he was then required
+to abjure the realm within the forty days, with all his goods, save what
+his lord might distrain to discharge his obligations due him.[49] This
+law was to remain in effect, as long as the king pleased and the effect
+of this law was that the accused, if convicted, lost a limb and suffered
+banishment and even if acquitted, by ordeal, he was likewise banished,
+for such was the doubt then entertained as to the justness of the trial
+by ordeal.[50]
+
+This doubt upon the justness of the trial by ordeal, was due, in large
+measure to the fact that many such trials were fraudulently managed, by
+the Bishops, to bring about the acquittal of the accused.
+
+It is related that William Rufus, who had caused fifty Englishmen of good
+family, to be tried by ordeal for the violation of some law of the realm,
+after their acquittal by the ordeal of the hot iron, declared that he
+would try them again by the judgment of his court and would not abide by
+this pretended judgment of God, “which was made favorable or unfavorable,
+at any man’s pleasure.”[51] And Henry II., likewise convinced of the
+fraud accompanying such acquittals, by this means, also refused to give
+final effect to such acquittals.[52]
+
+Trial by ordeal continued in England until the judgments of councils,
+in the reign of Henry III., but in the third year of the reign of this
+monarch on January 27’, 1219, direction was given to the justices
+itinerant for the northern counties of the kingdom not to try persons
+charged with murder, arson, robbery, theft or other felonies, by the
+ordeals of fire or water, but for the present, until further provision
+could be made, to keep them in prison, _so as not to endanger their life
+or limb_[53] and those charged with the inferior offenses were to be
+compelled to abjure the realm.[54]
+
+This order of council, during the reign of Henry III., had such a potent
+influence toward abolishing the superstitious trial of ordeal, that it
+went quite out of use by the time of Bracton, who makes no mention of it
+in his book.[55]
+
+Compurgation by witnesses was substituted, in England in the early part
+of the thirteenth century, for the former mode of compurgation by ordeal
+and the latter became an obsolete procedure in England, until revived
+in the crime of witchcraft, by James I., where it was quite generally
+used, to determine the guilt or innocence of persons accused of sorcery,
+because of the absence of any other test to apply, to determine their
+guilt or innocence.[56] This superstitious monarch maintained that trial
+by ordeal was an infallible test in cases of witchcraft, because the pure
+elements of fire and water would not receive those who had renounced
+the sacred privileges of their baptism and by his authority and example
+thousands of cases of cruelty and oppression resulted, in the use of
+the ordeal, as applied to cases of sorcery, during the craze of that
+delusion, in Europe,[57] but otherwise, the trial by ordeal passed into
+history, along with the many other cruel institutions of a past age.
+
+The ordeal was frequently used, in ancient Europe, to establish the
+paternity of children or the chastity of women, the success or failure of
+the test being generally accepted as the judgment of God.
+
+In 887 Charles-le-Gros accused his wife, the Empress Richarda, of
+adultery with Bishop Liutward, and she offered to prove her innocence by
+the judicial combat, or the ordeal of the red-hot iron.[58]
+
+St. Cunigundi, referred to as the “virgin-wife” of the Emperor St. Henry
+II., is also reported to have eagerly appealed to the judgment of God, to
+establish her innocence of the baseless charge of infidelity, preferred
+against her by her jealous lord, and in vindication of her honor, to have
+successfully trod, unharmed, the red-hot plow-shares.[59]
+
+In the eleventh century, the unholy purpose of Edward the Confessor—who
+was himself too ascetic to make his own wife, Editha, the partner of his
+bed[60]—in his desire to accomplish the death of his own Mother, Queen
+Emma, because of her partiality to his half brother, Hardicanute—the son
+of Canute,—was frustrated by the Queen invoking this judgment of God,
+through the ordeal of the red-hot iron, to establish her innocence of
+the charge of adultery with Alwyn, the Bishop of Winchester. The Queen
+triumphantly purged both herself and the Bishop, by the help of St.
+Sowthin, by walking bare-footed over nine red-hot plow-shares and out of
+gratitude for this vindication, the Queen and the Bishop each gave nine
+manors to the Church of Winchester in memory of the nine plow-shares, and
+it is reported that the King, for preferring the false charge against
+them, was corrected with stripes.[61]
+
+The Confessor was more successful in ridding himself of his
+father-in-law, however, and the interesting case of Godwin, Duke of Kent,
+father of Harold and sometimes called the “King maker of England,” during
+the reign of Edward the Confessor, also illustrates the superstitious
+belief in the corsned ordeal.
+
+As the story goes, Duke Godwin was dining with his royal son-in-law
+Edward the Confessor—for the latter had then married his daughter
+Editha—and whether premeditated or not, the King repeated the accusation
+that his brother Alfred had met his death at the hands of Duke Godwin. To
+vindicate himself old Godwin then invoked the ordeal of the corsned and
+seizing a morsel of bread he dramatically exclaimed: “May God cause this
+bread to choke me if I am guilty in thought or in deed of this crime.”
+Then the King took the bread and blessed it, and, whether he poisoned
+it or not, when Godwin put it in his mouth and swallowed it, he was
+suffocated by it and fell down dead.[62]
+
+In this age of scepticism it is hard to accept this superstitious
+explanation for the end of old Duke Godwin, but the secret of his death
+is more reasonably accounted for, on the theory of Boccascio’s story of
+Calen Drino, where the expected miracle was brought about by the secret
+mixture of aloes in the bread of the corsned, for, as Lea suggests,
+Edward the Confessor, both because of his dislike for his father-in-law,
+and his desire to cast off the tutelage in which he was held, in order
+to further his self interest and rid himself of a hated enemy, would no
+doubt have secretly mixed poison with the corsned used in this ordeal and
+then caused the story to be circulated among the superstitious subjects,
+to account for the Duke’s sudden demise.[63]
+
+We find that the ordeal was utilized in France, in the tenth century in
+the notable case of Teutberga, the wife of King Lothair, great-grandson
+of Charlemagne. Desiring to rid himself of his wife, this degenerate
+grandson of a worthy grand-sire, accused her of incest and forced her
+to a confession. She afterwards recanted and denied the truth of her
+confession and offered to establish her innocence by the ordeal of hot
+water, by proxy.[64]
+
+Hincmar, the most distinguished divine of this period championed the
+cause of the unfortunate queen and wrote a dissertation upon the
+infallibility of the test of the ordeals, because they had the guidance
+of the Divine Wisdom, effectually convincing himself and a large number
+of the French subjects of the correctness of the judgment by this ordeal,
+especially when King Lothair so far estopped himself from claiming that
+he had not desired to get rid of his wife, by espousing his concubine,
+Waldrada, whom he had, in fact, preferred to the wife he had discredited
+by the criminal charge against her.[65]
+
+Illustrating the prevalence with which the pagan practice of ordeal had
+taken possession of the minds of the churchmen of the ninth century, Lea
+quotes the argument of Hincmar, in his interesting work, “Superstition
+and Force,”[66] as follows:
+
+ “In boiling in water the guilty are scalded and the innocent
+ are unhurt, because Lot escaped unharmed from the fire of
+ Sodom, and the future fire which will precede the terrible
+ judge, will be harmless to the saints, and will burn the wicked
+ as in the Babylonian furnace of old.”
+
+Of course the correctness of this syllogism, depends upon the correctness
+of the first assumption, based upon the delusions and superstitions of
+a past age, but the conclusion seemed to satisfy a large number of that
+day, judged by the standards then obtaining, among which was the idea of
+a Deity who was a bigger, stronger, crueler man—a more “terrible judge.”
+
+Some few of the many interesting trials by ordeal, which obtained during
+the twelfth century in the reigns of Richard I. and King John, have been
+reproduced by Sir F. Palgrave, in his “Proofs and Illustrations,” to be
+found in the _Rotuli Curiae Regis_[67] for those reigns. Let us examine a
+few of these old Rolls.
+
+ “_Roll of the Iter of Wiltshire, 10 Richard I._—The jurors
+ say that Radulphus Parmentarius was found dead with his neck
+ broken, and they suspect one Christina, who was formerly the
+ wife of Ernaldus de Knabbewell, of his death, because Radulphus
+ sued Christina in the ecclesiastical court for breach of a
+ promise of marriage she had made to him and after the death
+ of her husband Ernaldus, Reginald, a clerk, frequented her
+ and took her away from Radulphus, and Reginald and Christina
+ hated Radulphus for sueing her, and on account of that hatred,
+ the jurors suspect her and the clerk of his death. And the
+ country says it suspects her. Therefore, it is considered that
+ the clerk and Christina appear on Friday, and that Christina
+ purge herself by fire.[68] _Roll of the Iter of Stafford, in 5
+ John._—One Elena is suspected by the jurors, because she was
+ at the place where Rainalda de Henchenhe was killed and because
+ she was killed by her help and consent. She denies it. Let her
+ purge herself by the judgment of fire; but as she is ill, let
+ her be respited, till she gets well.
+
+ Andrew of Bureweston is suspected by the jurors of the death of
+ one Hervicus, because he fled for his death, therefore let him
+ purge himself by the judgment of water.”[69]
+
+During the witchcraft craze, in Europe, the ordeal of fire and water was
+frequently invoked by the accused persons, to clear themselves of the
+charge, but so incensed were the people against those arraigned for this
+offense that it was difficult to convince the courts and juries of the
+innocence of the alleged offender, even by this supposed infallible test
+of the judgment of God. It was presumed that the Devil interfered with
+the correctness of the termination of the tests in this hated crime and
+so the poor suspects were condemned, after suffering untold tortures,
+even though the test of the ordeal favored their innocence of the charge.
+
+The Inquisitor Sprenger cites the case of a witch, tried before the Count
+of Furstenberg, in 1484. The accused invoked the test of the red-hot
+iron and the Inquisitor attributed his acquiescence to his youth and
+inexperience and the fact that he was not acquainted with the methods
+of the Devil, to further the cause of the sorcerers. Although sentenced
+to carry the hot iron only six paces, the supposed witch carried it six
+paces and offered to hold it still longer, if required, as she displayed
+her hand wholly uninjured. The Count was thus compelled to render
+a judgment of not guilty against the accused person and at the time
+Sprenger wrote, in 1487, he reported that she still lived “to the scandal
+of the faithful.”[70]
+
+The superstition connected with the trial by ordeal, as a means of
+detecting the guilt or innocence of the participants of the foul crimes
+of the middle ages, early took a firm hold of the popular imagination and
+we find repeated references to the ordeal, in the dramatic and popular
+literature of the different countries where this mode of trial obtained.
+
+The heroic Iceland song of the Elder Edda, supposed to have been composed
+between the sixth and eighth centuries, utilizes the ordeal as a means of
+bringing to justice the false witness borne by the accuser, the Concubine
+Herkia, in her charge of adultery against Gudrun, the wife of Atli.[71]
+First describing the test, resulting in the innocence of Gudrun, and then
+the proof of the guilt of her accuser, the poem proceeds:
+
+ “She to the bottom plunged her snow-white hand,
+ And up she drew the precious stones,
+ ‘See now, ye men, I am proved guiltless,
+ In holy wise, boil the vessel as it may.’
+ Laughed then Atli’s heart within his breast
+ When he unscath’d beheld, the hand of Gudrun.”
+
+ “‘Now must Herkia to the cauldron go,
+ She who Gudrun had hoped to injure.’
+ No one has misery seen, who saw not that,
+ How the hand there of Herkia was hurt.
+ They then the woman led to a foul slough.
+ So were Gudrun’s wrongs avenged.”
+
+The ordeal of the bier was exemplified in the current literature of the
+age of Richard Coeur-de-Lion, for the histories of that King report that
+when he met the funeral procession of his father Henry II., at Fontevraud,
+the blood spurted from the nose of the deceased, because of the treason
+and rebellion of which his son had been guilty.[72]
+
+Shakespeare utilizes this story of Richard Coeur-de-Lion, in the funeral
+scene, in Richard III., where Lady Anne, when interrupted in her grief at
+the bier of Henry VI., is made to say to the by-standers:
+
+ “O gentlemen, see, see: dead Henry’s wounds
+ Open their congeal’d mouths, and bleed afresh.”[73]
+
+In Sir Walter Scott’s “Minstrelsy of the Scottish Border” we also find
+a reference to this ordeal of the bier, when, in the ballad of Earl
+Richard, this author established the innocence of the maid, by this test:
+
+ “‘Put na the wite on me,’ she said;
+ ‘It was my may Katherine.’
+ Then they hae cut baith fern and thorn,
+ To burn that maiden in.
+
+ It wadna take upon her cheik,
+ Nor yet upon her chin;
+ Nor yet upon her yellow hair,
+ To cleanse that deadly sin.
+
+ The maiden touched that clay-cauld corpse,
+ A drap it never bled;
+ The ladye laid her hand on him,
+ And soon the ground was red.”
+
+And thus Scott uses the ordeal of the bier to establish that the accuser
+was herself the guilty person[74] and the Bard of Avon and the Elder Edda
+utilize this ordeal and that of the boiling water, to demonstrate the
+infallibility of this Divine test, when applied, to ascertain the guilt
+or innocence of one accused of such crimes as may legitimately be the
+subject of this character of proceeding, known to the ancient law as one
+of the Judgments of God.
+
+The ordeal was entirely a judicial proceeding, regularly used, in
+an early day, for the trial of criminal cases, before the civil and
+ecclesiastical courts. The accused had no alternative but to undergo
+the trial by ordeal, for when ordered to submit to it, the order had
+the force and effect of a regular judgment of the court.[75] A failure
+to comply with the order of the court to undergo a trial by ordeal,
+was treated as a contempt of court, and under the early English law,
+the accused who refused to submit to such a test, was outlawed and his
+property was confiscated, the same as if he had been adjudged guilty of
+the offense, for in refusing a compliance with the mandate of the law, he
+placed himself beyond the pale of the law and later could not claim the
+right to a lawful trial.[76] The Anglo-Saxon codes allowed no alternative
+but contained direct and specific provisions for the trial by ordeal, in
+all its different phases.[77]
+
+The circumstances and conditions under which ordeal was employed, in the
+trial of the various felonies known to the early Saxon laws, varies,
+necessarily, with the customs and legislation of the different rulers,
+and sometimes we find that the right of selection obtained, between
+this and other modes of compurgation, or between the different forms of
+ordeal.[78]
+
+Little, if any good, could result from a discussion of the power of a
+Court to order submission to such barbarous treatment, for the courts
+assumed the power and it was backed-up with the influence of the Church
+and the authority of the King. The citizens could do little else than
+submit to such a formidable alliance, which proceeded in the name of the
+Majesty of the Law and the Solemn Assurance of the Church, for there
+were no constitutions to protect the citizens from cruel or unusual
+punishments; might was right when used against the weak and oppressed
+and the power of the Church and State was too much for any individual to
+overcome. Society was not organized, as at present, to protect the rights
+of the individual, but the Church and State were all-powerful and their
+orders had the force to overcome all private resistance.
+
+As shown, in the beginning, the institution known as trial by ordeal,
+like many other of the cruel customs of the ancient world, had the Mosaic
+law as its foundation and the Church’s approval, in the construction of
+the foundation and the recognition of the whole institution. The Church
+was not only ready to accept the barbarous practices of its pagan
+converts but itself gave them fresh claim to confidence, by throwing
+around them the solemn ceremonies of its own approval. The ordeals were
+all conducted with the aid of the priests, and prelates in all the
+Catholic countries were everywhere granting special charters authorizing
+the privilege of trials by ordeals.[79]
+
+But as the Church was partly responsible for the practice of trials by
+ordeal, because the Churchmen were but human and, as such, entered into
+the manners and customs of the people of the period when they lived, the
+Church had no inconsequential part in abolishing this barbarous custom,
+for ever since the sixth century and perhaps from the beginning of the
+custom, eminent Churchmen had opposed the institution as a pagan custom,
+not authorized by the teachings of the ancient Jews or the religion of
+Christ, and finally, the protests of these wise Churchmen culminated in
+the suppression of this old test, and in 1215 the Lateran Council forbade
+the clergy from afterward taking part in the ceremony known as trial by
+ordeal.[80] And Henry III., following the lead made by the Church, “Seeing
+that the judgment of fire and water is forbidden by the Church of Rome,”
+directed his judges, starting on their circuits, to adopt other methods
+of proof and to forever discard this brutal test.[81]
+
+If the Church was remiss in its duty to oppose the ordeal, therefore,
+in the beginning, it brought about the repression of the practice, and
+is, at least, entitled to the benefit of the approval of the friends of
+humanity for this tardy beneficence, upon its part.
+
+If true that every age, like every person, has its own sins and
+short-comings to answer for, and that is the happiest which best succeeds
+in hiding them for a time,[82] then the age of the trial by ordeal,
+according to our twentieth century standard, was guilty of a sin that
+the past centuries must atone for, if atonement is essential for the
+wayward customs of a pagan race, struggling without compass or needle,
+amid the darkness of a barbarous age, to steer a straight course. They
+should not be held to more than the ordinary standards of right and wrong
+then prevailing, in their efforts to find the higher law for society,
+when just able to attempt to clamber up the mountain heights of wisdom.
+The inhabitants of the centuries who utilized the trial by ordeal had
+not then perfected their judicial system so that very high ideals of
+individual right obtained, but they had made wonderful strides in the
+arts and sciences, while practicing this hideous custom of trusting to
+the wisdom of God, in the trials of men and women for their offenses
+against society, as judged by man made laws. We have elevated the
+standards of the judicial system somewhat, since that period, but in our
+own time, a large number of people, instead of further establishing the
+independence of the judiciary, are favorable to submitting to popular
+vote, the correctness of a given decision, or the judicial fitness
+of a judge; mormonism only recently was abolished and instead of the
+superstition and delusion which invoked the judgment of God in trials of
+witches and others accused of unproven crimes, we have spiritualism and
+other similar protests against rationalism and reason, so we are not yet
+in a position to condemn, in unmeasured terms, our older brothers of the
+day of trials by ordeal.
+
+
+FOOTNOTES:
+
+[1] Pattetta, Ordalia, c. I.
+
+[2] From the Anglo-Saxon, _Ordaal_, _or_, primitive, and _daal_,
+judgment, meaning “primitive judgment,” or _urtheil_, according to the
+German.
+
+[3] Thayer says: “Nothing is older,” Harvard Law Review, Vol. V., p. 63;
+II. Essays in Anglo-American Legal History, 392.
+
+[4] Numbers, V., 14, 15, 19, 24, 27, 28.
+
+This same ordeal is in use among the Africans, of the Gold Coast, to
+determine incontinence on the part of a woman.
+
+From Herodotus it would seem that the ancient Egyptians believed in
+ordeals, with other divine power, to solve the guilt of prisoners, in
+cases where the evidence was doubtful, as he narrates instances where
+Aames II. who led a dissolute life, was convicted on the supposed divine
+judgment of the oracle. Herodotus II., 174.
+
+In their excellent history of English Law, Pollock and Maitland say, of
+the trial by ordeal: “The history of ordeals is a long chapter in the
+history of mankind; we must not attempt to tell it. Men of many, if not
+all races, have carried the red-hot iron or performed some similar feat,
+in proof of their innocence.” (Vol. II., p. 598.)
+
+[5] Sophocles’ _Antigone_, 264; Aeschylus, fr. 284.
+
+[6] Asiatic Researches, vol. i., p. 389.
+
+[7] Neilson’s “Trial by Combat.”
+
+[8] Thayer’s “Older Modes of Trial,” II. Essays in Anglo-American Legal
+History, p. 393.
+
+[9] Pattetta, Ordelie.
+
+[10] Mackay’s Delusions; Athelstane.
+
+[11] Pattetta, Ordalie.
+
+In Sophocles’ Antigone, the guards protest their innocence to Creon, of
+any complicity in the burial of Polynices and offer to establish their
+innocence by ordeal, in the following lines:
+
+ “Ready with hands to bear the red-hot iron,
+ To pass through fire, and by the gods to swear
+ That we nor did the deed, nor do we know
+ Who counselled it, or who performed it.” (PP. 264-267.)
+
+[12] Pattetta, Ordalie; I. Reeve’s History English Law, p. 203.
+
+[13] _Ante idem._
+
+[14] Mackay’s “Memoirs of Delusions.”
+
+[15] _Ante idem._
+
+[16] According to Jolly, the translator of this book, the materials for
+the text date back many centuries before Christ and some of the old laws
+treated of, belong to the remotest antiquity, p. XX.
+
+Rishi Narada was a celebrated Hindu Sage and Lawgiver, supposed to have
+been the son of Brahma and Saraswari. Mrs. Manning’s “Ancient and Med.
+India,” Vol. I., pp. 146, 249; Vol. II., pp. 119, 134.
+
+The ordeal of the eucharist was based upon the statement of the Apostle,
+construed with pious veneration and accepted literally “he that eateth
+and drinketh unworthily eateth and drinketh damnation to himself.” _I.
+Corinthians_ XI., 28, 29; Lea, “Superstition and Force,” (3 ed.) 304.
+
+[17] Brahma, the first person, in the Triad, of the Hindus, was the god
+of the fates, master of life and death, the author of the Vedas and the
+great lawgiver and teacher of India.
+
+[18] Institute Narada, Pt. I., c. 5, sec. 102, to Pt. II., pp. 44, 45.
+According to an eminent authority, ordeals are still practiced in India,
+in private life. Sir Henry Maine’s “Life and Speeches,” p. 426; Manning’s
+“Ancient and Mediaeval India,” Vol. I., pp. 146, 249; Vol. II., pp. 119,
+134.
+
+From the fragments of the Avesta, which have come down to us, containing
+snatches of the prehistoric law of the ancient Persians, the ordeal of
+boiling water was a fixed, settled legal procedure, at that distant day,
+for it is there recorded:
+
+“Creator: he who knowingly approaches the hot, golden, boiling water, as
+if speaking truth, but lying to Mithra;
+
+What is the punishment for it?
+
+Then answered Ahura-Mazda: Let them strike seven hundred blows with
+the horse goad, seven hundred with the craesho-charaha.” This was the
+punishment affixed for using this particular ordeal for fraudulent
+purposes, just as if one trifled with one of the settled legal processes
+of the present day and as perjury was then prevalent, the punishment of
+twice seven hundred blows to the perjurer, was the penalty for using this
+ordeal to further perjury, or false swearing. Vendidad, Farg. IV., 156;
+“Records of the Past,” VII., 109; Lea, “Superstition and Force,” (3’ ed.)
+233.
+
+[19] Cap. Car. Mag. ann. 779, sec. 10; Lea, “Superstition and Force,” (3
+ed.) 348.
+
+[20] Capit. iv ann. 803, secs. iii, vi; in L. Longobard, Lib. ii, Tit.
+xxviii, sec. 3; Tit. iv, sec. 25; Capit. Car. Mag. I., ann. 809, sec. 20.
+
+[21] Capit. Car. Mag. ann. 794, sec. 7; Lea, “Superstition and Force,” p.
+338.
+
+[22] Concil. Aquisgran. cap. xvii.
+
+[23] L. Longobard, Lib. II., Tit. lv, sec. 32; Lea, “Superstition and
+Force,” p. 298.
+
+[24] Herbert’s Antiquities (1804), p. 146.
+
+[25] De Moribus Germanorum, cap. X.
+
+[26] Herbert’s Antiquities, p. 147.
+
+[27] _Ante idem._; I. Pollock and Maitland’s History English Law, p. 39;
+Dr. Liebermann’s Sitzungsberichte der Berliner Akademie, 1896, XXXV., p.
+829.
+
+[28] Leg. Athelstan, 23; I. Reeve’s History English Law, p. 201; Analecta
+Anglo-Brit. lib. ii, cap. 8, inter Leges Athelstan, cap xxx.
+
+[29] Dr. Liebermann’s Sitzungsberichte der Berliner Akadamie, XXXV., 829;
+I. Pollock and Maitland’s History English Law, p. 39, note.
+
+[30] Herbert’s Antiquities (1804), pp. 147, 148.
+
+[31] I. Reeve’s History English Law, pp. 201, 202; Leges Athelstan, 23.
+
+[32] Mirror of Justice, c. 7, s. 24.
+
+[33] I. Reeve’s History English Law, p. 203.
+
+[34] Finlason’s note to I. Reeve’s History English Law, p. 201.
+
+Pollock, in his “Anglo-Saxon Law,” says “A man of good repute could
+usually clear himself by oath, but circumstances of grave suspicion or
+previous bad character, would drive the defendant to stand his trial by
+ordeal.” I. Essays in Anglo-American Legal History, p. 93.
+
+[35] Lamb, de priscis Angl. Leg. cap. 39.
+
+[36] Herbert’s Antiquities (1804), p. 156.
+
+[37] _Ante idem._
+
+[38] Leges, Aesthelstan, iv, sec. 6; Aetheldred, iii, sec. 7; Cnut,
+Secular. sec. 58; Lea, “Superstition and Force” (3 ed.), 253.
+
+[39] Legg. Edwardi, cap. iii; Lea, “Superstition and Force” (3 ed.) 340.
+
+[40] Legg. Aethelredi, cap. i, sec. I; Cnuti Saecul. cap. xxii; Henrici,
+I., cap lxv, sec. 3; Lea, _supra_.
+
+[41] Schmid, Gesetze, p. 357; Stubbs, Select Charters; I. Pollock and
+Maitland’s History English Law, p. 450.
+
+[42] _Ante idem._
+
+[43] LL. Inae, c. 77; _Traites sur les coutumes Anglo-Normand_. Tom. I.,
+p. 577; Hale’s History Common Law, p. 152.
+
+[44] Thayer “Older Modes of Trial,” V. Harvard Law Review, 64; II. Essays
+in Anglo-American Legal History, p. 394.
+
+[45] Leges Henri, 31, sec. 5; Foedera, i, 154; II. Pollock and Maitland’s
+History English Law, p. 650.
+
+[46] Palgrave, Commonwealth, p. 207; II. Pollock and Maitland’s History
+English Law, p. 650.
+
+[47] Glanville (Beame’s tr.), p. 283.
+
+[48] I. Reeve’s History English Law, pp. 456, 457; Mirror of Justice,
+cap. III., sec. 23; Lea, “Superstition and Force,” (3 ed.) 256.
+
+“The water ordeals, both hot and cold, were stigmatized as plebian, from
+an early period, as the red-hot iron and the duel were patrician.” Lea,
+283.
+
+[49] I. Reeve’s History English Law, p. 456; I. Pollock and Maitland’s
+History English Law, p. 152.
+
+[50] _Ante idem._
+
+[51] I. Reeve’s History English Law, p. 456.
+
+[52] Litt. Hen. II., vol. iv, 279; I. Reeve’s History English Law, 457.
+
+Instead of the _judicium Dei_, the success of the fifty men would look
+more like _judicium clericus_. Eadmer, Hist. Nov. 102; II. Pollock and
+Maitland History English Law, 599.
+
+[53] This order to the justices, as we have seen, in the Essay on _Peine
+forte et dure_, had the effect of filling the jails of the kingdom with
+prisoners content to await the invention of some other method of trial
+than that of ordeal, and since none such was provided, to refuse to plead
+and thus baffle the king’s justices. To overcome this custom, the order
+not to _endanger their lives or limbs_, soon gave place to the terrible
+torture, by which they were literally _pressed to death_, for standing
+mute.
+
+[54] II. Reeve’s History English Law, 286.
+
+[55] II. Reeve’s History English Law, 287, and note.
+
+[56] Lea “Superstition and Force,” (3 ed.) 291; Daemenologiae, Lib. III.,
+cap. vi.
+
+[57] _Ante idem._
+
+The Lateran Council of 1215 forbade the clergy to take part in the
+ceremony of the ordeal any further and in prompt obedience to this
+decree in England, Henry III. abolished it in the kingdom, as England
+was then at the Pope’s feet, and aside from the cases of witchcraft and
+sorcery, in the reign of James I., the ordeal last appears, as a method
+of judicial trial, in the old rolls of the reign of King John. (Concil.
+Lateran. IV., c. 18; Foedera, i, 154; Rolls of King’s Court, Pipe Roll
+Soc. 80, 86, 89;) Select Pl. Cr; Note Book, pl. 592; Lea, “Superstition
+and Force,” (3 ed.) 421; II. Pollock and Maitland’s History English Law.,
+p. 599 and notes.
+
+Lord Hale informs us: “That in all the time of King John ... trial by
+ordeal continued, ... but it seems to have ended with this king, for I do
+not find it in use any time after.” (History Common Law, p. 152.)
+
+In Nigeria the trial by ordeal still obtains in cases of witchcraft and
+to vindicate the chastity of women. P. Amaury Talbot’s article, in London
+Telegraph, July, 1912.
+
+[58] Regino. ann. 886—Annales Metenses; Lea, “Superstition and Force,” (3
+ed.) 257.
+
+[59] Lea, “Superstition and Force,” _supra_; S. Kunegundae, cap. 2;
+Ludewig Script. Rer. German. I., 346.
+
+[60] Green’s History English People, vol. I.
+
+[61] Freeman’s Norman Conq. Vol. II; Rapin, History d’ Angleterre, I.,
+123; Wm. of Malmesbury, Giles’ note, ann. 1043; Lea, “Superstition and
+Force,” (3 ed.) 258.
+
+It seems that the charges against Queen Emma were preferred by Robert,
+Archbishop of Canterbury. She was accused both of consenting to the death
+of her son, Alfred, and of preparing poison for her son Edward, the
+Confessor, and also of intimacy with Alwyn, the Bishop of Winchester. The
+Dowager Queen, on the night preceding the trial, prayed for help, in the
+Abbey of St. Swithune, at Winchester and the next day she passed over the
+nine plow-shares unhurt. Archbishop Robert fled the kingdom and the King,
+who had brought about her trial, did penance for his credulity.
+
+(The Percy Anecdotes, p. 161.)
+
+The paternity of two children resulting from a morganitic marriage of
+Robert Curthose, son of William the Conqueror, is reported to have been
+established by the ordeal of the red-hot iron, which the mother carried
+unhurt, and Curthose, then Duke of Normandy, thus convinced of the
+legitimacy of the boys, regularly adopted them. Roger de Wendover, Ann.
+1085; Lea, “Superstition and Force,” (3 ed.) 259.
+
+[62] Roger of Wendover, ann. 1054; Matthew of Westminster, ann. 1054;
+Chronicles of Croyland, ann. 1053; Henry of Huntington, ann. 1053; Wm. of
+Malmesbury, Lib. II., cap. 13; Lea, “Superstition and Force,” (3 ed.) p.
+301.
+
+[63] Lea, “Superstition and Force,” _supra_.
+
+[64] Lea, “Superstition and Force,” (3 ed.) p. 247.
+
+[65] _Ante idem._
+
+[66] Lea, “Superstition and Force,” (3 ed.) p. 247; Hincmar, de Divert.
+Lothat. Interrog. vl.
+
+[67] Palgrave erroneously states that the _Retuii Curia Regis_ is
+the “oldest judicial record in existence.” The records of trials
+obtaining during the reign of Hammurabi, 2250 years before Christ, are
+in existence. See Chapter on “_Recall of Judges_;” John’s “Laws of
+Babylonia,” etc.
+
+[68] Palgrave’s “Proofs and Illustrations,” clxxxviii; Stephen’s
+“Criminal Procedure,” II. Essays in Anglo-American Legal History, pp.
+487, 488.
+
+[69] Palgrave’s “Proofs and Illustrations,” clxxxv; Stephen’s “Criminal
+Procedure,” _supra_.
+
+[70] Malleus Maleficar. Francof. 1580, pp. 523-31; Lea, “Superstition and
+Force,” (3 ed.) 264.
+
+[71] Benjamin Thorpe’s Elder Edda, pp. 106, 107; Prof. Bugge’s Ed. of
+Copenhagen, (1867); Prof. Rask’s ed. of 1818; Lea, “Superstition and
+Force,” (3 ed.) 335.
+
+[72] Benedicti Abbatis Gest. Henr. ann. 1189; Roger de Hoveden, ann.
+1186; Lea, “Superstition and Force,” (3 ed.) 316.
+
+[73] Richard III., Act I., Scene II.
+
+Sir Walter Scott uses the ordeal of the bier in the “Fair Maid of Perth,”
+in connection with the killing of Oliver Proudfute, who was killed with a
+lochabar axe. On the principle that “murder will out,” while the body lay
+in state at the High Church of St. John, in Perth, the servants of Sir
+John Ramorny were required to pass by the corpse and touch it, but when
+Bonthron, the person who had really slain the deceased, came to the body,
+he refused to touch it and claimed the right of trial by battle. (“Fair
+Maid of Perth,” Chapter XXIII.)
+
+[74] Lea, “Superstition and Force,” (3 ed.) 335.
+
+[75] II. Pollock and Maitland’s History English Law, 650; Lea
+“Superstition and Force,” (3 ed.) 333.
+
+[76] _Ante idem._
+
+[77] II. Cnuti, Saec. cap. xxx, xli.
+
+[78] L. Henrici, I., cap. lxv, sec. 3.
+
+[79] Lea, “Superstition and Force,” (3 ed.) 354, 356; Annal. Benedict. L.
+57, No. 74, ann. 1036.
+
+[80] Concil. Lateran. IV., c. 18; II. Pollock and Maitland’s History
+English Law, 599.
+
+[81] Rymer, Foed. I., 228; II. Pollock and Maitland’s History Eng. Law,
+_supra_.
+
+Illustrative of the approval of the church of Rome in the ancient
+procedure by ordeal, we find, in the ninth century that Hincmar
+expatiated upon the blessing of such a test, in that it combines “The
+elements of water and of fire: the one representing the deluge—the
+judgment inflicted on the wicked of old; the other authorized by the
+fiery doom of the future—the day of judgment, in both of which we see
+the righteous escape and the wicked suffer.” Hincmar, de Divort. Lothar.
+Interrog. vl; Lea, “Superstition and Force,” (3 ed.) 244.
+
+[82] Lea, “Superstition and Force,” (3 ed.) 370.
+
+
+
+
+CHAPTER VI.
+
+PEINE FORTE ET DURE.
+
+
+_Peine forte et dure_,[1] or, the “strong and hard pain,” as it was most
+appropriately termed, was the name given in Europe to the particular kind
+of punishment formerly inflicted upon a prisoner, charged with felony,
+where he stood mute and refused to answer on his arraignment, or having
+entered his plea of not guilty, where he peremptorily challenged more
+than twenty jurors, which was quite generally considered a contumacy
+equivalent to standing mute.[2]
+
+Generally, in indictments for high treason and the lower felonies and
+misdemeanors, standing mute was held equivalent to a conviction and the
+prisoner was sentenced and received his punishment, just as if he had
+entered a plea of guilty or suffered a conviction. But in all other
+felonies the prisoner was required to plead to the indictment, before a
+conviction could be obtained and if he obstinately stood mute, or refused
+to plead, he was subjected to the _peine forte et dure_, a judgment
+purposely ordained to be exquisitely severe, that by that very means it
+might rarely be put into execution.
+
+The judgment for standing mute, was: That the prisoner be remanded to
+the prison from whence he came, and put into a low, dark chamber, and
+there be laid on his back, on the bare floor, naked, unless where decency
+forbids; that there be placed upon his body as great a weight of iron
+as he can bear; and more, that he have no sustenance, save only, on the
+first day, three morsels of the worst bread; and on the second day three
+draughts of standing water, that should be nearest to the prison door;
+and in this condition, this should be alternately his daily diet, until
+he answers to the indictment.[3]
+
+To understand how such an inhuman institution as that of pressing
+prisoners to death came into existence, it is necessary to understand
+somewhat the history of criminal proceedings of the period when it
+obtained. The motive which would induce the prisoner charged with felony
+to submit to this terrible punishment, rather than enter his plea, was no
+doubt to escape the attainder which would result from a conviction for
+felony. If he was convicted of felony, his goods were forfeited to the
+crown and in the case of capital felony, corruption of blood followed
+attainder and the felon could neither inherit nor transmit landed
+property.[4] Where the prisoner had heirs, therefore, and possessed any
+estate, his attachment and affection for his heirs or children frequently
+prompted him to suffer the punishment of being pressed to death, to avoid
+the attainder of his name and the corruption of his blood, for death and
+attainder would both result from the conviction, which was frequently
+certain to result, in any event.
+
+Trial by ordeal obtained in England until the thirteenth century,[5] and
+as a part of the procedure obtaining when this barbarous custom prevailed
+the prisoner when asked “Culprit, how will you be tried,” replied, “By
+God,” meaning that he would be tried by ordeal, rather than “By my
+country,” which was the request for a jury trial. When the prisoner stood
+mute and refused to plead, the court was so perplexed that frequently the
+prisoner would escape by some trivial punishment, as the procedure of
+the period did not include this kind of a case, so the astute criminal
+lawyers of these times no doubt frequently practiced this subterfuge to
+perplex the court and secure the escape of a guilty client. Legal forms
+at this period had much greater efficacy than at present when we have
+statutes of jeofails and look to the substance, rather than the forms of
+things, and it was unheard of then to try a prisoner by ordeal, before he
+entered his plea, or even to put him upon his country, so where he stood
+mute, the difficult thing was to secure his consent to try him by either
+method.
+
+Under the stress of the perplexity of having found concrete cases not
+covered by the custom and practice of the period, the judges instantly
+ordered some of the offenders standing mute on malice, to be put to
+death, for refusing to consent to be tried, according to the custom of
+the realm, but this was practically judicial murder, as the defendant
+had not been legally convicted, before sentence, so the pendulum of
+public sentiment swung back from this precedent and brought about a great
+revulsion to this practice.
+
+In the beginning of the thirteenth century the penalty for refusing to
+plead consisted merely of a severe punishment, with low diet, until the
+obstinacy was overcome, and latterly, the practice prevailed, which had
+no legal sanction, of tying the thumbs together, with whipcord, that the
+pain might induce the prisoner to plead.
+
+During the reign of Edward I., in the year 1275, in the proceedings
+of the Parliament of Westminster, the first mention is made of this
+punishment for standing mute through obstinacy or wilfullness. It was
+enacted by this statute that felons refusing to plead through obstinacy
+should be confined in the prison, _forte et dure_. They were to go
+“barefooted and bareheaded, in their coat only, in prison, upon the bare
+ground continually, night and day, fastened down with irons,” only eating
+and drinking on alternate days, until the plea was entered.[6] But the
+courts could not wait for the obstinate prisoners to voluntarily renounce
+their obduracy and succumb to such mild treatment and the accumulation
+of cases where the prisoner stood mute and the growing popularity of
+this offense, seemed to threaten the speedy dispatch of the criminal
+business of the period. Starvation was then added to the punishment of
+confinement, but this did not accomplish the desired end, of forcing
+these obdurate offenders to consent to be tried, according to the custom
+then obtaining.
+
+As before seen, the first statute, touching upon this punishment, passed
+during the reign of Edward I., applied only to “notorious felons,”
+who were “openly of evil name,” for these alone, refusing to plead
+before the justices at the King’s suit, were to have the “strong and
+hard punishment,” that the act called for, and by express statutory
+exception prisoners “taken upon light suspicion” were not to suffer the
+punishment.[7]
+
+Some writers have taken the position that the punishment, _peine forte
+et dure_ owed its existence alone to this statute, but Sir Edward Coke
+states that the punishment was assessed at common law, before the
+enactment of this statute,[8] and the statute in merely providing for an
+imprisonment _forte et dure_, was declaratory of an existing punishment
+assessed by the common law, but not sufficiently described, or limited.
+
+This view is shared by Reeves, who states that this method of treating
+felons who stood mute was introduced sometime between the fifth year of
+the reign of King Henry III. or perhaps from the time of Bracton, and the
+third year of King Edward I. and the punishment did not owe its existence
+to this statute.[9]
+
+However this may be, we find that during the reign of Henry IV. the mild
+punishment provided for by the statute of Edward I. and the proceedings
+detailed by Fleta and Britton,[10] of merely being fastened down with
+irons, on the bare ground of the prison, “until the plea was entered,”
+had given way to the harsher punishment of being compelled to lie under
+a “_peine_,” “_till they were dead_,” an event most likely to follow
+speedily from the quantity of weight or iron placed upon such prisoners.
+The _peine forte et dure_, as it was known, therefore, from the fifteenth
+to the eighteenth century, seems to have been firmly established as
+an institution of the English Criminal Law, during the time of Henry
+IV., and the reason for its existence is to be found in the object of
+the justices in eyre and justices of gaol delivery, of obviating the
+necessity of remaining for long periods in the English country towns,
+waiting for the mild effect of the formerly prevailing punishment,
+provided for by the statute of the reign of Edward I., in inducing
+prisoners charged with felony to consent to be tried.[11]
+
+The prevalency of the practice of standing mute in such cases, under
+the milder form of punishment, increased to such an extent that the
+patience of the justices was sorely tried. They determined, about the
+beginning of the fifteenth century, to put an end to such a practice,
+by furnishing such a harsh punishment that the example of inflicting it
+would discourage prisoners from thus defying the law, even if it resulted
+in the speedy and painful death of the offender. All exhortations and
+mild treatment were abandoned and the obdurate prisoner, thus defying
+the court, was sentenced to be literally “pressed to death,” unless he
+recanted and submitted himself to a trial, according to the fixed customs
+of the realm.
+
+It may justly be doubted if the defiance of the majesty of the law
+by this failure to plead was sufficient to justify such a barbarous
+practice, with the object of compelling a respect for the law, or if the
+remedy was not really worse than the disease, but upon this philosophical
+phase of the subject we are not concerned. Whether justly or unjustly,
+this species of punishment obtained for three centuries and a half in
+the English criminal law and a great many concrete cases, illustrating
+the application of the custom, arose during this period. And it is
+interesting to note how the punishment was made more severe with the
+increasing prevalency of the offense.
+
+In the year 1219, when the first eyre of Henry III.’s reign was in
+session, a case arose for the instruction and advice of the King’s
+Council regarding the course to be pursued where the prisoner refused to
+plead.[12]
+
+It was decided that although the prisoner was charged with the
+gravest kind of a felony, he was to be safely kept in prison, but the
+imprisonment was not to endanger life or limb. No suggestion was made
+of attempting to compel the submission to a trial, and the details
+of assessing the punishment to be inflicted was left wholly to the
+discretion of the justices.[13]
+
+The cases occurring before the passage of the statute of Westminster in
+the reign of Edward I., show that the justices did not have any fixed
+method of handling the cases wherein the prisoner refused to plead, but
+took such course as seemed best suited to the individual case before
+the court. Sometimes the expedient was resorted to of taking the verdict
+of an exceptionally strong jury and condemning the prisoner, if he was
+found guilty, regardless of whether he had formally entered his plea
+or not. During the Warwickshire eyre of 1221 Martin Pateshull pursued
+this course, on two different occasions.[14] The prisoner stood mute
+and refused to plead, but the twelve hundredors and twenty-four other
+knights, having sworn to his guilt, he was hanged.[15]
+
+In 1222, on the refusal of a prisoner accused of receiving felons, to
+plead to the charge, at Westminster, the court merely committed him to
+prison, to be held in solitary confinement, although the townships and
+the knights of the shire had declared him guilty.[16]
+
+During Bracton’s time, the procedure does not seem to have taken the
+course that it did in later years, as he speaks of the method of
+compelling a man to place himself upon the country and states that he was
+considered undefended and quasi-convict, if he refused.[17]
+
+Thus, it appears that before the enactment of the statute of Edward I.
+the cases arising were determined without any fixed rule governing the
+punishment to be assessed, but a few years after this act, the prisoner
+was laden with irons and in the course of a short period the hideous
+_peine forte et dure_ was developed.[18]
+
+During the reign of Edward III. the courts adopted starvation as a
+remedy for refusing to plead to an indictment for murder, as the case
+of Cecelia Rygeway illustrates. She was indicted for the murder of her
+husband and refusing to plead, she obstinately stood mute. She was
+committed to prison and lived without meat or drink for a period of
+forty days and nights, when she was allowed to go free, as her wonderful
+longevity, without food, was ascribed to the influence of the Virgin
+Mary, whose intercession could only be reconciled with the innocence of
+the defendant.[19]
+
+Starvation was generally discarded sometime after the statute of Edward
+I. and after the reign of Henry IV. the _peine forte et dure_ was
+the regular and lawful mode of punishing persons who stood mute and
+obstinately refused to plead in charges of felony.
+
+In 1442 Juliana Quick was arraigned upon a charge of high treason, for
+speaking contemptuously of the King, Henry VI. She refused to plead and
+it having been determined that her refusal was obstinate, rather than by
+an infirmity of nature, she was “pressed to death,” in a summary manner.
+
+The case of Margaret Clitherow, who was pressed to death at York, on Lady
+Day, March 25’, 1586, is most pathetic, as narrated by her spiritual
+adviser, the good John Mush, a friendly priest. Margaret’s husband was a
+Protestant, but she was accused of harboring Jesuit and Seminary priests,
+of hearing mass and other similar offenses and so she was committed to
+York Castle and later was regularly arraigned in the Common Hall. When
+plied with the usual question, “Culprit, how will you be tried?” instead
+of making the usual answer, “By God and my country,” the prisoner refused
+to make any other answer than that she would be tried “by God and your
+consciences.” After repeated entreaties by the court, and continued
+obstinacy of the prisoner, she was committed to prison and during the
+intercession of the court Parson Whigington, a puritan preacher, labored
+long and hard with her to convince her that she ought to forego her
+obduracy and enter her plea, but she refused to do so. On her second
+arraignment, when the court seemed about to condemn her to the _peine
+forte et dure_, Parson Whigington spoke in the interest of the prisoner,
+calling the court’s attention to the fact that “this woman’s case is
+touching life and death; you ought not, either by God’s law, or man’s,
+to judge her to die upon the slender witness of a boy.” Entreating her
+twice again to renounce her obdurate plea and to throw her case upon
+the country, on her refusal, the court ordered “the law to take its
+course”; she had her arms pinioned with a cord, by the Sheriff and as she
+was led through the crowd, the jeers and taunts, ever levelled at the
+unfortunate, in keeping with “man’s inhumanity to man,” gave the Sheriff
+the idea that he was to soon become a popular man, by the murder of this
+defenseless woman, so he proceeded to his work as if he were, in fact, a
+hero.
+
+She was urged to press the exemption of pregnancy, but refused, and the
+Lord Mayor of York, on his knees begged her to enter her formal plea to
+the charge against her and to submit to trial, as did her friend the
+good Parson Whigington. She stood firm, as if courting martyrdom, in an
+attempt to demonstrate the injustice of such a hideous punishment, and
+finally even the sympathetic Parson Whigington, after expressing his
+pity, left her and came again no more.
+
+Her execution having been set for Friday, as if in commemoration of the
+day when the gentle Saviour took his departure upon the cross of Calvary,
+this innocent woman, on Lady Day, in 1586, also suffered martyrdom and
+died her death, that the horrible example of this hideous punishment
+could be made the more detestable. She refused the offer of friends to
+add sufficient weight to dispatch her immediately, but subjected herself
+to the torture, as deliberately as any martyr ever took the rack. She was
+led bare legged and bare-footed through the street, with a loose gown to
+hide her nakedness and distributed alms to the idle spectators as she
+passed along. The inhuman wretch who acted as Sheriff was named Fawcett
+and with no instinct of decency or chivalry, he bade her “put off her
+apparel,” whereupon she pleaded on her knees, that she might be allowed
+to die in her “smock” and that “for the honor of womankind, they would
+not see her naked.” Fawcett refused this becoming plea, but finally, on
+the entreaty of her friends, she was allowed to die in a long loose linen
+robe she had made for the occasion.
+
+She was placed flat upon the ground on her back, with a handkerchief
+on her face; a door was laid upon her body and her hands were bound by
+Fawcett to two posts, so that her arms and body made a perfect cross;
+even as the Holy One of Galilee was taunted by the mob who followed Him
+to Calvary, so this innocent soul was crossed by the taunts and gibes
+of the vulgar mob, until finally the weights were placed upon the door.
+A large, sharp stone had been placed under her back, and seven or eight
+hundred pound weight was placed on the door and this weight broke her
+ribs and caused them to burst through the flesh on her sides. She gave
+but a single cry and exclaimed: “Jesu, Jesu, Jesu, have mercy upon
+me.”[20] Let us hope that with the wail of this lost soul the weeping
+Christ made room for the misguided martyr, in a realm where such Satanic
+tyranny and intolerable cruelty are unknown. Strange, is it not, that
+the death knell of this hideous and cruel procedure did not follow
+immediately, as a result of the aroused and outraged public feeling,
+after the death of this good woman, in this cruel manner? But when it
+is considered that such Satanic cruelty could have lasted for sixteen
+hundred years after the crucifixion of the Saviour—and that all traces
+of his presence are not entirely eliminated from the earth, as yet—it is
+quite evident that the ideals of holiness and righteousness are slow to
+permeate the hearts of all the human family.
+
+Anthony Arrowsmith stood mute and refused to plead to the charge of
+felony, in 1598, and was accordingly pressed to death, in the usual
+manner.[21]
+
+Walter Calverly, of Calverly in Yorkshire, was arraigned at the York
+assizes in 1605, for murdering his two children and stabbing his wife,
+and on refusing to enter his plea he was pressed to death, in the castle,
+by a large iron weight, placed on his breast.[22]
+
+It would be impossible, in any reasonable space, to recount all the most
+interesting cases where this inhuman punishment was inflicted, during
+the last half of the sixteenth and the early part of the seventeenth
+centuries, as a great many prisoners underwent this torture about this
+time. For the nine years between 1609 and 1618, for instance, there
+were thirty-two prisoners subjected to this punishment and among this
+number three were women, in Middlesex county alone. In the record of
+these cases the Clerk wrote the words: “_Mortuus en pen fort et dur_,”
+which furnished the sad epitaph for each of the beknighted sufferers who
+underwent this fearful punishment. The records show that many of these
+poor prisoners were totally destitute and suffered this punishment either
+through stupidity of the prisoner or of his counsel, or through obstinacy
+or indifference to his personal suffering and death.[23]
+
+In 1615 Sir Richard Weston, a prisoner of some note, was arraigned for
+the murder of Sir Thomas Overbury. He stood mute and obstinately refused
+to plead to the indictment, after being solemnly warned by the judges
+of the terrible consequences of his persisting in his defiance of the
+laws of his country. The proceedings were adjourned to give him time for
+reflection, but on his continued obstinacy, he was adjudged to suffer
+the _peine forte et dure_.[24]
+
+Major Strangeways was pressed to death, at Newgate, in 1657, for
+obstinately refusing to plead to an indictment charging him with the
+murder of his brother-in-law, Mr. Fussell. At the Coroner’s inquest he
+was made to take the corpse by the hands and touch the wounds, upon the
+supposition that if he had committed the murder, the wounds would bleed
+afresh. Although he was innocent, according to this test, it availed
+him nothing, however, and he was placed upon trial at the Old Bailey,
+where so many tragedies were enacted, in the olden time, in the name of
+the law, and refusing to plead and standing mute, in order to prevent
+the attainder of his blood and the forfeiture of his estate, resulting
+from his conviction, so certain to follow his trial, he was condemned to
+the _peine forte et dure_. The press was placed upon him angle-wise and
+although of sufficient weight to cause him much pain, it was not heavy
+enough to kill him, so the spectators, through pity, no doubt, for the
+sufferer, added the weight of their bodies to that of the press and soon
+he was out of his suffering and in keeping with the custom of the period
+his dead body was displayed to the vulgar gaze,[25] that the morbidly
+curious could advertise the details of the tragedy and thus deter other
+offenders from a similar offense.
+
+In the year 1720, a man named Phillips, who stood mute and refused to
+plead to an indictment for felony, was adjudged to undergo the _peine
+forte et dure_; he was placed under the press at Newgate and suffered the
+torture for a considerable time, until he concluded to enter his plea
+of not guilty and stand trial, in the ordinary manner, so the press was
+removed and he entered his plea and stood trial.[26]
+
+And in the following year, one Nathaniel Hawes, upon his arraignment for
+a felony, stood mute and obstinately refused to enter his plea and on
+being sentenced to the _peine forte et dure_, he suffered the pressure of
+a weight of two hundred and fifty pounds for a period of seven minutes
+and then gave up his resolution and craved the privilege of entering his
+plea and throwing himself upon the country in his trial.[27]
+
+In 1726 a man named Burnworth, arraigned for murder, concluded that he
+would stand mute and try the effects of the _peine forte et dure_. He
+was sentenced at Kingston to suffer this punishment for his obstinate
+defiance of his country’s laws and after being pressed for an hour and
+three-quarters, with four hundred pounds of iron, his will was broken. He
+was taken to the dock and was tried, convicted and hanged.[28]
+
+From the number of reported cases that have been inspected, it seems
+that a great many were unable to withstand the suffering resulting from
+the application of the weight to their bodies, but when the torture was
+experienced, they would weaken and conclude to enter their plea.
+
+This was true of John Durant, who was arraigned at the Old Bailey, in
+1734. Upon his obstinately refusing to enter his plea upon a charge of
+felony, his thumbs were first tied together with whipcord and the Sheriff
+pulled him up taut in the presence of the court and the latter dignitary
+promised him the _peine forte et dure_, forthwith, if he did not
+regularly enter his plea to the indictment. On reflection, he concluded
+to do this, so he was placed upon his trial and filed his plea of not
+guilty.[29]
+
+As late as the year 1741, it is reported that a prisoner was pressed to
+death, at the Cambridge assizes, for standing mute and refusing to plead
+to a charge of felony, after the tying of his thumbs and other customary
+procedure was found to be unavailing.[30]
+
+The only instance noted in which this punishment was ever inflicted in
+the United States, was in the case of Giles Cory, of Salem, who stood
+mute and obstinately refused to plead, when arraigned upon a charge of
+witchcraft and sorcery.[31]
+
+He was arraigned at Salem, in April, 1692, before Hawthorn and Jonathan
+Curwin. “Mary Walcott, Mercy Lewis, Ann Putnam, Jr., and Abigail Williams
+affirmed he had hurt them.” He was accused of giving Elizabeth Hubbard
+a fit; of hurting Benjamin Gold; of bringing the book to these various
+witnesses; of being frightened in the cowhouse and of threatening
+suicide.[32]
+
+On September 16’ “just as the Autumn leaves were beginning to glorify the
+earth,” he was laid upon the ground, bound hand and foot; stones were
+piled upon him, till the tongue was pressed out of his mouth. The Sheriff
+with his cane, forced it in again, when he was dying.[33] And he was the
+first and last to die for this offense in New England.
+
+In his account of this trial, in the “New England Tragedies,” the gentle
+Longfellow, has made Cory thus explain to Richard Gardner, why he refused
+to plead:
+
+ “I will not plead.
+ If I deny, I am condemned already,
+ In Courts where ghosts appear as witnesses,
+ And swear men’s lives away—If I confess,
+ Then I confess a lie, to buy a life,
+ Which is not life, but only death in life.
+ I will not bear false witness against any,
+ Nor even against myself, whom I count least.”
+
+The Sheriff then calls him to his punishment and Cory answers him:
+
+ “I come.
+ Here is my body. Ye may torture it,
+ But the immortal soul, ye cannot crush.”
+
+Gloyd wonders if
+
+ “The old man will die and will not plead,”
+
+and while thus wondering, arrives too late to view the test of martyrdom.
+
+In Scene IV. of this tragedy, based upon this sad miscarriage of justice
+in this New England case, the field near the graveyard is presented, with
+Cory lying dead, with a great stone upon his breast.
+
+Hathorn and Mather are introduced to the spectators and make a vain
+attempt to explain and justify the deed and the former points to the dead
+body of Cory as a horrible example of
+
+ “Those who deal in witchcraft and when questioned,
+ Refuse to plead their guilt or innocence
+ And stubbornly drag death upon themselves.”
+
+But Mather, not satisfied with the proceeding, is thus made to deliver
+himself:
+
+ “In a land like this,
+ Spangled with churches, Evangelical,
+ Inwrapped in our salvation, must we seek,
+ In mouldering statute-books of English courts,
+ Some old, forgotten Law, to do such deeds?
+ Those who lie buried in the Potter’s field,
+ Will rise again, as surely as ourselves
+ That sleep in honored graves, with epitaphs,
+ And this poor man, whom we have made a victim,
+ Hereafter will be counted as a martyr.”[34]
+
+The _peine forte et dure_, as an institution of the English courts,
+continued in effect, as a part of the criminal procedure of the kingdom,
+until the year 1772, when the statute 12 George III., c. 20, virtually
+abolished the punishment of pressing prisoners to death for standing
+mute, when called upon to plead.
+
+This statute declared that any person who should stand mute and refuse
+to plead, when arraigned for felony or piracy, should be convicted, and
+suffer judgment and sentence to be rendered against him, the same as if
+he had been regularly convicted, by verdict or confession.
+
+This procedure was again changed in England, in the year 1827 by the
+more humane rule, that upon a failure or refusal of the defendant in a
+felony charge to plead to the indictment, “a plea of not guilty should be
+entered for the person accused,”[35] and he was thus given the benefit of
+the legal presumption of innocence, which the criminal law surrounds all
+prisoners with and he could be convicted and sentenced for the offense
+charged in the indictment only after this presumption of innocence had
+been overcome by the proof of his guilt, even though he stood mute and
+refused to enter his formal plea.
+
+This latter statute, in substance, has been adopted in most of the
+United States and the cases arising under these statutes illustrate the
+beneficence of the new procedure.
+
+In Commonwealth vs. Braley,[36] in the year 1804, the defendant stood
+mute and refused to plead and the court proceeded to empanel a jury to
+try the defendant to ascertain if he stood mute wilfully, or by Act of
+God, just as the court proceeded when the _peine forte et dure_ was
+in force and on the return of the verdict that the defendant wilfully
+refused to plead, the court remanded him to jail.
+
+In Commonwealth vs. Moore,[37] in the year 1812, the defendant was
+arraigned upon a charge of larceny and stood mute and upon a finding
+of the jury that he stood mute through wilfullness, the court proceeded
+to sentence him, just as if he had been regularly convicted, evidently
+proceeding under the statute, 12 George III., c. 20.
+
+In State vs. Hare, in the year 1818, in Maryland, the prisoner stood
+mute and refused to plead, but the court entered up a plea of not guilty
+for him and proceeded to try him, just as if he had himself entered his
+formal plea. This enlightened procedure was adopted by Congress at the
+beginning of the past century, in all cases where prisoners stood mute.
+
+It was provided by Act of Congress, March 3’, 1825, that
+
+ “If any person, upon his or her arraignment, upon any
+ indictment, before any court of the United States, for any
+ offense not capital, shall stand mute or will not answer or
+ plead to such indictment, the court shall notwithstanding,
+ proceed to the trial of the person so standing mute, or
+ refusing to answer or plead, as if he or she had pleaded not
+ guilty, and, upon a verdict being returned by the jury, may
+ proceed to render judgment accordingly.”[38]
+
+Since the enactment of this federal statute, similar acts have been
+adopted in most of the United States and the practice now quite generally
+obtains of entering a formal plea of not guilty, whenever the prisoner
+stands mute, for any reason and the trial proceeds just as if the
+defendant had himself entered his plea.[39]
+
+The punishment for standing mute and refusing to plead, as one of the
+cruel and extreme methods of procedure of the olden times, has attracted
+the attention of the poets and writers in the English language.
+
+Shakespeare makes frequent reference to this punishment and always in
+such manner as to demonstrate that he was thoroughly familiar with the
+nature and object of the procedure governing the infliction of the
+penalty upon those who obstinately stood mute, when called upon to plead
+to indictments for felonies.
+
+Thus, in “Much Ado About Nothing” he makes Hero say to Ursula, when
+speaking of Beatrice, in the Orchard of Leonato:[40]
+
+ “_Hero._ No, not to be so odd and from all fashions
+ As Beatrice is, cannot be commendable;
+ But who dare tell her so? If I should speak,
+ She would mock me into air; O, she would laugh me
+ Out of myself, press me to death with wit.”[41]
+
+In “Measure for Measure,” when the Duke adjudged that Lucio should marry
+the woman he had wronged, the latter replied:
+
+ “_Lucio._ Marrying a punk, my lord, is pressing to death,
+ whipping and hanging.”[42]
+
+In Richard II., on overhearing the talk of the Gardener and servant, in
+the Duke of York’s garden, concerning the King, the Queen soliloquizes
+
+ “_Queen._ O, I am pressed to death through want of speaking,”[43]
+
+as if she were really in the dock and actually conditioned so that she
+would suffer the customary penalty for standing mute.
+
+Pandarus also refers to the _peine forte et dure_, in Troilus and
+Cressida, in advising them to “press” the bed to death because it stands
+mute as to their “pretty encounters” thereon:
+
+ “_Pan._ ... I will show you a chamber and a bed,
+ Which bed, because it shall not speak of your pretty encounters,
+ Press it to death: away.”[44]
+
+By a study of the old cases, decided when the _peine forte et dure_
+obtained, the development of the law on this subject, can best be
+understood, for like landmarks, pointing the devious course of the
+tortuous procedure that obtained for centuries, before the evolution
+of the science, to the point where it was able to preserve the just
+rights of the individual, consistently with the demands of society, the
+later cases evidence the gradual decline of the old, harsh punishment
+for standing mute, and thus, with the abolition of this quandam formal
+procedure, that was considered such a material part of the old criminal
+law of England, the law itself has reached a higher plane, from which we
+can look down upon the crudities and cruelties of the old system, with
+pity for the multitudes who were subjected to its harsh rules and false
+standards. And judging the future by the past, we can indulge the hope
+that many of our own formal procedures will be amended and abolished,
+to the end that unjust results and delays may be minimized and the
+attainment of just ideals promoted.
+
+The science of the law should keep pace with the advance of the student
+of philosophy. The law should ever stand aloof—even as a just parent—from
+any punishment prompted solely through the mad power of might. When it
+has attempted to inflict punishment unjustly, the causes and effects,
+the advantages, if any and the disadvantage of such procedure, should be
+thoroughly scrutinized. Laws are man-made, in popular governments and the
+laws should be improved for the benefit of the people.
+
+We have seen that for centuries, upon the obstinate refusal of a prisoner
+charged with felony, to enter his plea, the inhuman judgments of the
+courts—established for the administration of justice—were that he should
+be literally “pressed to death,” regardless of his guilt or innocence of
+the charge that he was called upon to answer.
+
+With the passing of this horrible institution—as with others of the past
+centuries—we can perhaps congratulate ourselves, that with the evolution
+of the institutions of our civilization, humanity has generally triumphed
+over inhumanity and the mistakes of our ancestors, although most
+dearly bought, furnish a lasting object lesson for present and future
+generations. Every generation, however, has its follies and mistakes and
+nonsense is not confined wholly to the past ages, but with the errors of
+the past before us, we ought to avoid the same mistakes that it took such
+suffering and experience to correct.
+
+However unwise and unjust the standards of our ancestors may have been,
+which made possible the wholesale legal murder of thousands of human
+beings, who, for different reasons, defied the fetish and barbarous
+custom that developed the cruel institution, _peine forte et dure_,
+this institution, like many others of the past, ought to warn us, like
+a beacon light, of the dangerous shoals and reefs, which the ship of
+state should be safely piloted around. But our own procedure contains
+many incongruities and erroneous standards, that should be corrected,
+and while priding ourselves upon the fact that nothing so inhuman as
+“pressing to death,” obtains today, we are still guilty of many “crimes
+against criminals,” which succeeding ages, in the perfection of the
+science of jurisprudence, will no doubt regard in much the same light as
+we of the present age look upon the cruel punishment, _peine forte et
+dure_.
+
+
+FOOTNOTES:
+
+[1] The terms are pronounced pān fōrt ā dūr.
+
+[2] II. Reeve’s History English Law, p. 423.
+
+[3] Coke, 2 Inst. 178, 179; Hale’s P. C. vol. ii., 322.
+
+“He was to be laid down, naked, upon the ground, on his back, his feet
+and head and loins covered, his arms and legs drawn apart, by cords, and
+as much weight of iron or stone as he could bear, was placed upon his
+chest.” This punishment was called also, “pressing to death.” Bouvier’s
+Dictionary; II. Reeve’s History English Law, 134; 4 Sh. Bl. Comm. 324;
+Britton, ch. 4 fol. ii; Fleta, lib. I., 34, sec. 33.
+
+[4] Coke, Litt. 130a, 391; 6 Coke, 63a, 63b; I. Bishop’s Crim. Law, 641.
+
+[5] II. Essays in Anglo-American Legal History, 392, 396, 486, 488.
+
+There is no doubt but that for a long time after the year 1215, the law
+did not know what to do with a man who stood mute and refused to plead
+and the _peine forte et dure_ was an institution slowly and painfully
+evolved from the customs of the past. II. Pollock and Maitland’s History
+English Law, p. 650.
+
+[6] II. Reeve’s History English Law, p. 423; Stat. West. l. c. 12.
+
+[7] Statute West, l. c. 12; II. Reeve’s History English Law, p. 423.
+
+[8] 2 Inst. 178, 179.
+
+[9] II. Reeve’s History English Law, p. 424.
+
+[10] Britton, fol. 11, c. iv; Fleta, lib. l. c. 29, sec. 33.
+
+[11] III. Reeve’s History English Law, 439.
+
+[12] Leges Henri, 31, sec. 5; Foedera, i, 154; Palgrave, Commonwealth,
+207; Thayer, Harvard Law Review, V., p. 265; II. Pollock and Maitland’s
+History English Law, p. 650.
+
+[13] II. Pollock and Maitland’s History English Law, p. 650.
+
+[14] II. Pollock and Maitland’s History English Law, p. 651.
+
+[15] Select Pleas of Crown, pl. 153, 157; Hale’s Pl. Cr. ii, 322.
+
+[16] Note Book, pl. 136.
+
+[17] Bracton, fol. 142b, 143b.
+
+[18] Year Book 30, I. Edward I., 511, 503, 531; Britton, i, 26; Fleta, p.
+51; II. Pollock and Maitland’s History English Law, p. 652.
+
+[19] Watt’s “The Law’s Lumber Room.”
+
+During the reign of Henry VII., we find two felons, who had been taken
+from sanctuary, at Southwark, on being arraigned before Sir Thomas
+Frowike urged their plea of sanctuary, which was overruled, and, on being
+commanded to plead to the felonies, and refusing, they were peremptorily
+ordered to be taken back to the jail and there placed upon the bare
+ground, and that more weight should be placed upon them than they could
+stand and they be given only bread and water, until they die; in short,
+that they be literally _pressed to death_, or suffer the terrible _peine
+forte et dure_. (21 Henry VII., Keilway, 70; IV. Reeve’s History English
+Law, Finlason’s note, p. 254.)
+
+[20] Law Notes, May, 1910, p. 32; Watt’s “The Law’s Lumber Room.”
+
+[21] Surtee’s History of Durham, vol. iii, p. 271.
+
+[22] Stow’s Chronicle.
+
+[23] Watt’s “The Law’s Lumber Room.”
+
+[24] Law Notes for May, 1910, p. 31; Watt’s “The Law’s Lumber Room.”
+
+According to Rushworth, when John Felton was arraigned for the
+assassination of the Duke of Buckingham, in November, 1628, the Privy
+Council debated the question of their right to place the prisoner on the
+rack. It was finally decided that:
+
+“Torture was not, with one exception, permitted at all, and in that one
+exception, it was permitted neither as a punishment nor as a means of
+getting evidence, but as a _persuasion_, to induce a man charged with
+felony, to put himself upon his trial.”
+
+Vol. 44, Chamber’s Journal, pt. Jan.-June, 1867, p. 373.
+
+[25] Watt’s “The Laws Lumber Room”; Law Notes, for May, 1910, p. 33.
+
+[26] Stowe’s Chronicle.
+
+[27] _Ante idem._
+
+[28] Watt’s “The Law’s Lumber Room.”
+
+[29] Watt’s “The Law’s Lumber Room.”
+
+[30] XI Inter. Enc. _Sub. Nom._ _Peine forte et dure._
+
+[31] Washburn, Jud. History, 142; I. Chandler, Cr. Trials, 122.
+
+[32] “Wonders of the Invisible World,” by Robt. Calef (1828), pp. 329,
+333.
+
+[33] “The Spirits in 1692,” Putnam’s Magazine, for January and June,
+1856, No. 7, p. 509.
+
+[34] Longfellow’s “New England Tragedies.”
+
+Tradition has it that Cory was pressed to death in an open field, between
+the Howard street burial ground and Brown street, in Salem.
+
+Nevins, “Witchcraft in Salem Village, in 1692,” p. 107.
+
+[35] 7 and 8 George III., c. 28.
+
+[36] I. Mass. 103.
+
+[37] 9 Mass. 402.
+
+[38] 3 Story, U. S. Laws, 2002 Sec. 14.
+
+[39] Fernandez vs. State, 7 Ala. 511; People vs. Thompson, 4 Cal. 238;
+Johnson vs. People, 22 Ill. 314; State vs. McCombs, 13 Iowa, 426;
+Commonwealth vs. Lannon, 95 Mass. 563, holding that the old rule in this
+state was changed by statute; Thomas vs. State, 6 Mo. 457; Link vs.
+State, 50 Tenn. (3 Heisk.) 252.
+
+[40] Act III., Scene I.
+
+[41] White’s “Law in Shakespeare,” sec. 40, p. 67.
+
+[42] Measure for Measure, Act V., Scene I.
+
+[43] Richard II., Act III., Scene IV.
+
+[44] Troilus and Cressida, Act III., Scene II.
+
+
+
+
+CHAPTER VII.
+
+WAGER OF LAW.
+
+
+Wager of law, in ancient England, was the practice whereby the defendant
+was allowed to make oath denying the charge of the complainant and
+supporting his oath by the oaths of a certain number of his friends or
+neighbors.[1]
+
+The term _wager of law_, comes from the Roman law _vadiatio legis_, from
+the defendant being put in pledges (_vadios_), to make oath on the day
+appointed.[2]
+
+The practice is traceable to the Mosaic law which provided that:
+
+ “If a man deliver unto his neighbor an ass, or an ox, or a
+ sheep, or any beast, to keep; and it die, or be hurt, or
+ driven away, no man seeing it; then shall an oath of the Lord
+ be between them both, that he hath not put his hands unto his
+ neighbors’ goods; and the owner of it shall accept thereof, and
+ he shall not make it good.”[3]
+
+Under the Mosaic law, the rule of practice which now obtains in criminal
+cases, that the good character or reputation of the defendant is always
+proper for him to offer, in his own defense, upon the issue of the
+likelihood of his commission of a crime, was extended to include his
+right to actually acquit himself of the debt or other cause of action by
+his own oath, for if he would absolutely swear himself not chargeable and
+was a person of good reputation, he stood acquitted of the charge, in
+order to prevent an innocent man from being overcome by a multitude of
+false witnesses.
+
+This method of procedure, or similar practices obtained in ancient
+Babylon,[4] among the Romans and the northern nations, adjacent to the
+Roman Empire, as well as among the ancient Israelites.[5]
+
+He who waged his law, under the old Saxon procedure, brought with him,
+into court, eleven of his neighbors, for by the constitution entered into
+as a league between Alfred and Guthrun, the Dane, a man’s credit, in a
+court of law, depended upon his reputation among his neighbors, touching
+his veracity.
+
+The defendant who pleaded _nil debit_, or denied the charge against him,
+usually concluded his answer with the plea containing the formula:
+
+ “And this he is ready to defend against him, the said A. B.
+ and his suit, as the court of our Lord, the King, shall here
+ consider,” _etc._
+
+He was then placed under surety to _wage his law_, on a day appointed by
+the judge and on the day named the defendant, in open court, took his
+oath, which was also confirmed by the oaths of eleven of his neighbors,
+called compurgators.
+
+The defendant stood at the end of the bar and was solemnly admonished by
+the judge of the nature and danger of a false oath and if he persisted,
+he repeated an oath like the following:
+
+ “Hear this, ye justices, that I do not owe unto A. B. the sum
+ of ten pounds, nor any penny thereof, in manner and form as
+ the said A. B. hath declared against me, so help me God.”[6]
+
+And thereupon his eleven compurgators avowed, upon their oaths, that they
+believed, in their consciences, that he saith the truth.
+
+The oath, therefore, of the defendant, himself, was _de fidelitate_, or
+on his fidelity, and the eleven compurgators testified _de credulitate_
+or upon their belief in his integrity.[7]
+
+These oaths had the legal effect of a verdict for the defendant, in all
+actions of debt, on a simple contract, or in actions of detinue, but the
+defense was not allowed to persons who did not enjoy a good reputation
+among their neighbors.
+
+The compurgators acted rather in the capacity of jurymen than as
+witnesses, for they swore to their belief, not to what they actually
+knew. In other words, when the accused made oath of his innocence or
+denied the charge filed against him, they swore that they believed he
+was swearing the truth. Yet they differed from jurymen in many important
+particulars. The jury was summoned by a public officer and took an oath
+to tell the truth, whatever the truth might be—for jurymen then did not
+sit in trial of issues as today—while the oath helper—or compurgator,
+merely took an oath to testify to the truth of his principal’s oath.[8]
+
+There is authority for the proposition that in the earliest times, the
+oath-helpers were necessarily kinsmen of the defendant.[9] The only
+obligation recognized by a defendant in either a civil or criminal case
+was to the injured party and no responsibility was predicated upon a duty
+owing to the state or to society at large. With the family as a unit,
+the person charged with a crime could summon his family to repulse an
+armed attack by the injured person and so he took them with him to the
+court, to defend him by their oaths.[10] When a person was accused of
+a crime sufficient to result in a blood-feud, his kinsmen were vitally
+interested in his acquittal and it is but natural that they proffered
+their help as oath-helpers for him, but in due course of time, the
+relatives alone were not required and the compurgators rather assumed the
+character of disinterested “character witnesses,” such as we see today,
+in all criminal cases, except that instead of swearing merely to the good
+reputation of the defendant, these compurgators made oath of their firm
+belief in his oath of innocence of the charge filed against him or of the
+cause of action set up by the injured party.[11]
+
+By the laws of Wihtraed,[12] in the seventh century, the king or a
+bishop could rebut an accusation by his own simple asservation, and
+the thane or priest by the simple oath, while the laity generally were
+required to undergo the formal procedure of waging their law by the
+regular number of compurgators.
+
+Mr. Reeves, in his History of English Law, says that Glanville does not
+mention the wager of law, as a mode of proof for the defendant in civil
+suits,[13] but in this the author must have meant to limit the statement
+to defenses only, for Glanville expressly describes the proceeding by the
+tenant, wherein he observes:
+
+ “If he should deny all the summonses, he shall, as to each of
+ them individually, corroborate his denial with the oaths of
+ twelve. Should it happen on the day appointed that either of
+ the compurgators fail, or should the person of either of them
+ be justly excepted to, and the vacancy occasioned by either of
+ these circumstances not filled up, the tenant shall, on account
+ of his default, immediately lose his seisin. But, if the tenant
+ thus completely disprove the summonses, he shall, on the same
+ day, answer to the action.”[14]
+
+According to Sir Edward Coke, any one who waged his law, in a court of
+record, prior to _Magna Charta_, in England, was required to bring with
+him _Fideles Testes_,[15] and this learned author intimates that the
+number of compurgators was eleven, besides the principal,[16] while the
+author of “_Les Termes de la Ley_,” in describing the same ceremony,
+expressly states that the number of compurgators was twelve.[17]
+
+Bracton advises us that it was not necessary that the compurgators should
+be of the same rank as the principal, provided they were trustworthy
+citizens,[18] and, when treating of the wager of law, in actions by
+tenants, he states that the land was not to be taken out of the tenant’s
+possession before the tenant had waged his law, nor if he failed in
+waging it.[19] And he states that the tenant could not wage his law by
+means of an attorney, constituted for that purpose, but was allowed to
+urge this plea, only by and through himself, personally.[20]
+
+In Bracton’s day, wager of law was the normal mode of defense and it
+was then the ordinary procedure for establishing that one had never
+been lawfully summoned to appear in court;[21] that a defendant had
+not deprived a guardian of the lawful possession of his ward;[22] that
+the defendant was not guilty of a breach of a covenant;[23] that the
+defendant had not wrongfully detained or distrained the plaintiff’s
+cattle or other animals,[24] and during this period it was even allowed
+by way of defense in an action of trespass.[25]
+
+According to Bracton, however, compurgation was not allowed to dispute
+evidence of offenses which were apparent to the senses, such as waste,
+which could be observed, as a physical condition, by any man, for if
+compurgation were allowed in such cases, the oath of compurgators would
+be allowed to overcome the evidence of our senses, which would place
+a premium on perjury and destroy the best evidence by mere secondary
+proof.[26]
+
+The wager of law was not confined entirely to the defendant, however, for
+according to this author, if the defendant set up an affirmative defense,
+the plaintiff, by way of reply, was allowed to deny the affirmative
+defense and to establish his avoidance of the special defense pleaded by
+the aid of oath-helpers.[27]
+
+During the reign of Edward III., the right of a defendant to wage his law,
+was guaranteed in all cases where the right existed in the time of Edward
+I., the object of the statute being that “many people were grieved and
+attached by their bodies in the city of London, at the suit of citizens,
+surmising that they were debtors, and could be proved so by their papers,
+though they had no deed or tally to produce them,” it was therefore
+enacted that “every man should be received _to his law_, by people of
+his condition against such papers, and the creditor should not put the
+party to plead to the inquest unless he chose,”[28] so the wager of law
+was thus preserved to the citizens of London, against mere papers, or
+verbal testimony as firmly as it was previously practiced in the common
+law courts.[29] But it was provided by statute, during the same reign,
+that the fines payable before the justices, should be in the presence of
+the pledges, in all cases, civil or criminal, and the pledges were to be
+advised of the sum of the fine, before they departed.[30]
+
+The law wager did not seem to be settled so securely that there was no
+doubt left, of the cases in which it would lie and those wherein it could
+not be invoked, in this reign, however, for while a defendant was denied
+wager of law, against his written obligation,[31] he was allowed to wage
+his law, in a suit on a deed, by the plea of non-summons, in the same
+manner that such plea had long been used.[32] It was allowed against a
+receipt, alleged to be by the hand of another than the defendant,[33] and
+in detinue of charters it was allowed,[34] although the charters related
+to the freehold and ought to be equally as binding upon a defendant as an
+obligation creating an action of debt.
+
+Wager of law was allowed in all cases where voluntary credit had been
+extended to the defendant, upon the theory that by giving him credit the
+plaintiff had estopped himself from denying that he was a man of good
+reputation, but wager of law was not permitted in charges created against
+the defendant by the law, for no man was allowed to thus swear away an
+obligation imposed by the law of the land.[35]
+
+It was denied in cases of contempt, trespass, fraud or deceit, or for
+damages for any injury with force; executors and administrators were
+not allowed, upon grounds of public policy, to deny under oath the
+obligations of their testators, since no man could safely wage law of
+another’s contracts; the king had certain prerogatives, which prevented
+the wager of law, in actions by him, as all wagers of law naturally
+reflected upon the honesty of the plaintiff, so wager did not obtain in
+actions by the king.[36]
+
+And since the wager of law only obtained in favor of those who bore a
+good reputation for veracity, one who had been outlawed, or attainted for
+any felony, or one who had become infamous, or who had pronounced the
+horrible word, _craven_, in a trial by battle, was denied his wager of
+law.[37]
+
+And under the old practice, since infants, or those under twenty-one
+years were not admitted to take oaths, they were also denied the wager of
+law, but a married woman was allowed the defense, when sued jointly with
+her husband and it extended in favor of an alien, who was to be sworn in
+his own language.[38]
+
+In the thirteenth and fourteenth centuries compurgators were allowed,
+even in the most serious charges of felony, in England, on the part of
+a defendant. According to the London custom, in the “great law” used
+in murder cases, the defendant was required to swear six times, with
+six compurgators for each oath; in the “middle law,” used in charges of
+mayhem, three oaths, each backed by six oath-helpers, satisfied the law,
+and in “the third law,” used in the smaller offenses, a single oath,
+corroborated by six helpers, satisfied the law.[39]
+
+In course of time the “great law” was found to be so onerous that the
+rule requiring six separate compurgators to as many separate oaths by the
+defendant was relaxed, so as to allow him to make his compurgation by one
+oath, supported by thirty-six helpers, but if any one of these failed to
+support his oath, he was hanged.[40]
+
+And by the last of the fourteenth century even when charged with the
+capital crime of murder, a citizen liable under the “great law,”
+which formerly required him to make his compurgation by thirty-six
+oath-helpers, was allowed to either make his compurgation in this manner,
+or, at his election, to go to trial before a jury of twelve men, for by
+this period the trial by jury was beginning to take its place as one
+of the fixed institutions in the administration of the criminal law of
+England.[41]
+
+The trial by oath-helpers, even in murder cases, was not speedily
+superceded by the trial by jury, however, for as late as the fifteenth
+century, according to Palgrave, purgation with thirty-six oath-helpers,
+was allowed at Winchelsea and in other jurisdictions subject to the
+English common law.[42]
+
+By the time of Henry VI., we find the cases in which wager of law was
+allowed still open to much discussion. It was recognized in actions
+of debt and detinue[43] and in the action of account, it came to be
+the custom for the justices to examine the attorney for the plaintiff
+and other persons and to allow or refuse the wager of law to the
+defendant,[44] accordingly as the account was found to be an account
+stated in the presence of auditors, in which case it was not allowed,
+or an account not taken in the presence of auditors, where the wager
+was held to obtain.[45] The theory of denying the wager to cases
+where an account was had in the presence of auditors was that such an
+account arose to the dignity of an obligation admitted before competent
+judges.[46]
+
+A defendant sued upon a debt for board and lodging was denied his
+law,[47] but Justices Priscott and Needham, decided, near the end of the
+reign of Henry VI. that wager of law would lie in an action for board
+and lodging, if the plaintiff had it in his power to furnish the board
+or lodging at his own volition and not upon compulsion,[48] but if the
+defendant had been imprisoned in the Tower and the board and lodging
+was furnished by force of the obligation of common humanity, this would
+so far deprive the plaintiff of his option of furnishing the board and
+lodging, as to make him a creditor of such merit as to deprive the
+defendant of his wager of law.[49]
+
+Where persons were compelled to serve by the statute of laborers, such
+as plowmen, shepherds, and all servants of husbandry, in an action for
+wages, the defendant was not allowed his wager of law, because the
+plaintiff had no option to refuse the service, but in cases where the
+service was not compulsory, wager of law would lie.[50]
+
+And upon the theory that an attorney could be compelled by the judges of
+the common pleas court to render faithful service to his client and was
+not allowed to refuse such service, we find that Chief Justice Fortescue
+decided, during this reign, that in an action by an attorney for services
+rendered in such a court, no wager of law would lie on the part of
+defendant.[51]
+
+By the middle of the fifteenth century, in England, the wager of law in
+criminal cases had begun to fall into disuse, for the method followed
+in such trials, at Westminster, was such that professional oath-helpers
+were customarily used and such professional swearers necessarily debased
+the wager of law in criminal cases.[52] And in the courts of the country
+districts it got to be a very easy matter for a citizen of bad repute to
+produce his oath-helpers, and his neighbors were afraid to negative the
+oaths of men who were frequently too desperate to thus antagonize,[53]
+and this led to a gradual preference for the trial by jury, in criminal
+cases, both on the part of the person accused of crime and by the
+general public, who came to regard the wager of law, in such cases, with
+odium.[54]
+
+Long before its repeal, by statute, the old defense had fallen into
+disuse, and in 1833, by 3 & 4 William IV.,[55] the wager of law was
+finally abolished in England, and compurgation in the ecclesiastical
+courts was abolished during the reign of Queen Elizabeth.
+
+While this irrational procedure obtained in England, the accused in the
+gravest criminal charges, could avoid punishment, regardless of the
+notorious character of his crime, without being confronted with evidence
+of his guilt, if he was able to find compurgators who would testify to
+their belief in his innocence.[56] And while he could not invoke this
+procedure in a case of theft, if the stolen goods were found upon his
+person, or he had been previously convicted, in all other offenses, he
+was at liberty to thus acquit himself, by means of his oath-helpers,[57]
+and this favorable procedure for the criminals continued long after
+its abuses were set forth and denounced in the Council of Bale,[58]
+in municipal and ecclesiastical courts, although in the king’s court,
+in criminal cases of the graver sort compurgation is said to have
+disappeared in consequence of what has been styled “the implied
+prohibition” of the Assize of Clarendon, in 1166.[59] But the statute of
+Elizabeth (38 Elizabeth, 3, 5), shows that the wager was in common use in
+1596, in actions of debt upon simple contracts.[60]
+
+Turning to some of the instances where the oaths of compurgators, or the
+wager of law, as known under the old procedure, was utilized to acquit
+the accused of charges, either in the ecclesiastical or lay courts of
+old England, we find, in the sixth century, that Pope Pelagius I., when
+confronted with charges that he was concerned in the troubles which
+drove his predecessor into exile, exculpated himself, by his oath, taken
+in the pulpit, while holding the crucifix above his head, denying any
+implication in the affairs that had resulted in the disgrace of his
+predecessor.[61]
+
+And when Gregory of Tours was arraigned for the use of words which
+seriously reflected upon Fredegonda, before a Council of Bishops, it was
+decided that he should acquit himself of the charge by oaths upon three
+separate altars, which in due time, the accused performed to the complete
+satisfaction of the Council.[62]
+
+In the dispute which arose, in 824, between Hubert, bishop of Worcester,
+and the abbot of Berkeley, in regard to the monastery of Westbury,
+the issue was settled by the oath of bishop Hubert, supported by
+fifty priests, ten deacons and a hundred and fifty other clerks and
+ecclesiastics.[63]
+
+Again, the bishop of Trent, when accused of simony, was ordered by Pope
+Innocent II. to clear himself with the oaths of two bishops and three
+abbots or monks, a course that was followed by the accused, to the
+complete satisfaction of his superiors in the church.[64]
+
+Compurgation was, indeed, for many centuries the common procedure whereby
+Churchmen, when accused of simony, or other irregularities, cleared
+themselves of the charges filed against them, and it seemed almost
+invariably an easy task to find other brothers of the order willing
+to stand by the accused and render him the assistance of an oath in
+the belief of his innocence, perhaps because of the frequency of such
+charges and the uncertainty of the future and that necessity might place
+the compurgators in a position where they might desire the reciprocal
+service, rendered to their unfortunate companion.[65]
+
+In the thirteenth century the earl of Warenne, or his men, slew Alan de
+la Zouche, in Westminster Hall, in the presence of the king’s justices.
+He was allowed to escape with his compurgators’ aid, according to
+the rule then obtaining, by his own oath, supported by the oaths of
+twenty-five knights, that the deed was not done with malice aforethought,
+or in contempt of the king, but under the heat of passion and under such
+circumstances as to reduce the offense to simple manslaughter.[66]
+
+In the Bedfordshire eyre, of the year 1202, in a prosecution under the
+statute for selling beer under a false measure, the defendant when placed
+upon her trial, claimed the right of compurgation and was ordered to
+defend herself “twelve handed” and she met the demand of the court by the
+offer of her compurgators.[67]
+
+In April, 1435, Agnes Archer was indicted for the alleged murder of Alice
+Colynbourgh, at Winchelsea, whom she was charged with having stabbed five
+times in the throat, with a knife. The defendant, when arraigned for this
+crime entered a plea of not guilty, by declaring, as the report of the
+case records it: “I am not guilty of thoo dedys, ne noon of hem, God help
+me so.” And when interrogated by the Judge as to how she would acquit
+herself of this charge, she replied: “By God and by my neighbors of this
+town,” so the charge being one which brought the case within the rule
+of the “Great Law,” she was required to acquit herself by the oaths of
+thirty-six compurgators.[68]
+
+In 1440, in a suit for board and lodging furnished the defendant by the
+plaintiff, one Counselor, Yelverton, for the plaintiff, contended that
+the defendant was not entitled to his wager of law, in this action, but
+the justices held that wager of law would lie in a suit for board and
+lodging.[69]
+
+During the reign of Henry VI., in the year 1454, quite a memorable legal
+battle was waged concerning the right of a defendant, in a real action,
+to wage his law upon a plea of non-summons. The plaintiff demurred to
+this plea and the justices were divided upon the propriety of recognizing
+the plea. Chief Justice Priscot and his associates, Danvers and Danby,
+overruled the demurrer to this plea, holding that the defendant could
+urge his wager of law in a real action, while admitting that the practice
+had been otherwise. The minority of the court, however, dissented from
+this view, much as the minority frequently dissent in modern times and
+Moile and Ayshton earnestly pressed their views upon the majority of the
+court, for the reason that, “All our law is directed by usage or statute;
+it has been used that no one wages his law in trespass, and the contrary
+in debt; so that we should adjudge according to the use.”[70]
+
+In the year 1492, one Sebastian Giglis complained to the Chancellor
+against Robert Welby, that complainant had persuaded a third party to
+advance a certain sum of money to Welby, who promised to repay the loan
+and then when he was sued therefor, by the creditor, he had waged his law
+and the result was that complainant had been compelled to pay the loan,
+so advanced, at his instance, to Welby. In his answer to this plea, Welby
+admitted the loan, but set up that he had procured the money for King
+Richard III., who had received and used the money and that the receipt
+given was a mere memorandum of the transaction, but not under seal,
+and he attempted to wage his law to this debt. The court refused to
+recognize the wager of law in this case, but held that in as much as the
+plaintiff had paid the debt for money had and received by the defendant,
+and since the defendant admitted the debt, and the receipt of the money,
+it was immaterial that he had given it to another, and adjudged that he
+should pay the plaintiff, and that no wager of law would lie in such a
+case.[71]
+
+In the year 1587 the Star Chamber refused to entertain a criminal charge
+of perjury against a man who was charged with having perjured himself
+in waging his law, in a prior proceeding. The Lord Chancellor rather
+dissented from the decision of the majority of the judges and asked if
+the effect of the wager, based on perjury was to discharge the debt sued
+for. The judges answered that it was, Manwood, C. B., maintaining that
+it was because of the plaintiff’s folly, in sueing for debt, rather than
+upon an assumpsit, wherein wager of law would not lie.[72]
+
+In his report of Slade’s case, in 1602, Sir Edward Coke remarked that
+the court would not allow a man to wage his law, until the court
+had admonished both the principal and the compurgators and upon due
+examination as to their qualifications and the merits of the cause,
+in order to ascertain if the case was one wherein wager of law was
+allowable.[73]
+
+Several cases came before Chief Justice Holt, during the latter part of
+the seventeenth century and some of the cases, which have been noted,
+will be briefly referred to.
+
+In the Company of Glazier’s Case, which arose in 1699, the Company sued
+in an action of debt and the defendant waged his law. Counselor Northey
+appeared for the Company and when the defendant appeared with his
+compurgators, he insisted that if he swore falsely, the court did not
+have to receive his wager of law, but to this contention, Chief Justice
+Holt replied: “We can admonish him, but if he will stand by his law, we
+cannot hinder it, seeing it is a method the law allows.” Plaintiff’s
+counsel then insisted that such a holding would be a dangerous precedent,
+because it would have the legal effect of compelling litigants sueing in
+debt, to extend the practice of sueing upon an assumpsit still further,
+but the doughty Chief Justice replied to this argument that “We will
+carry them no further,” so the wager of law was received, because it was
+a “method the law allows.”[74]
+
+The Chief Justice practically reversed his holding in the Company of
+Glazier’s Case, two years later, however, for in exactly the same kind
+of an action of debt, arising on a by-law, in London vs. Wood, the court
+refused to entertain the defendant’s plea of wager of law, remarking that
+the plaintiff’s counsel in the Company of Glazier’s Case (Northey), had
+yielded too much—although he seemed to do all that an earnest counsel
+can do, to urge his plea and then except to the court’s action, when
+it is overruled—in characterizing that decision, the court observing
+that “It was a gudgeon swallowed and so it passed without observation,”
+meaning that a bad precedent had been recorded because not strenuously
+enough objected to.[75]
+
+In this case, the action was on a city by-law, for the penalty provided
+for the refusal of the defendant to serve as sheriff. According to the
+custom of London, the defendant offered to wage his law, with six good
+and reputable compurgators, but to this plea the plaintiff demurred, and
+in considering the issue of law, on the question of the right of the
+defendant to wage his law, in such an action, Baron Hatsell reviewed the
+older decisions bearing upon the defense of wager of law and maintained
+that it would lie in five certain cases only, “first, in debt on simple
+contract, which is the common case; secondly, in debt upon an award, upon
+a parole submission; thirdly, in an account against a receiver; fourthly,
+in detinue, and fifthly, in an amercement in a court baron, or other
+inferior court, not of record.”
+
+Lord Holt repudiated the reasoning which limited the Wager to any
+specific classes of actions, but maintained that the wager could only be
+made to depend upon other distinctions, growing out of the very nature of
+the cause of action and not the mere class to which it might belong.
+
+In the course of his opinion in this celebrated case, he observed:
+
+ “This is the right difference, and not that which is made in
+ the actions, viz., that it lies in one sort of action and not
+ in another; but the true difference is when it is grounded on
+ the defendant’s wrong; ... for if debt be brought, and the
+ foundation of the action is the wrong of the defendant, wager
+ of law will not lie.... The secrecy of the contract which
+ raises the debt is the reason of the wager of law; but if the
+ debt arises from a contract that is notorious, there shall be
+ no wager of law.”[76]
+
+The great Chief Justice was far too independent to be bound by the dictum
+of some previous case, which did not commend itself to him, according to
+the touchstone of reason or logic. He had a naturally inquiring mind and
+sought to go deep into the mysteries of things. Refused credence to the
+absurd or allegiance to an arrogant authority and was too broad to be
+bound by mere doctrine, but of course could only judge according to the
+standards of his time.
+
+This decision marks the trend of judicial thought of the period to
+further limit and deny the wager of law, because of the fact that it
+was becoming to be considered contrary to the prevalent sense of right
+of the great mass of citizenship, to permit one who was sufficiently
+elastic in his conscience, to swear away the debt or obligation of
+another, just as formerly it had come to be regarded as wrong to permit
+the accused in a criminal case, to set aside the public law which he had
+violated, by means of the oaths of compurgators.
+
+During the age of Bracton, the defendant, who was incarcerated in jail
+and attempted to deny the obligation for his board and lodging, by the
+wager of law, was held incompetent to wage his law, in such a case,
+because it was counter to reason to permit one to be thus defeated of
+an obligation which he had recognized, based upon feelings of common
+humanity.
+
+In this opinion of Lord Hort, it was counter to his idea of right, in
+the case of London vs. Wood,[77] to permit the wager of law, to avoid
+an obligation which was not merely secret, but notorious and where the
+recognition of the right to wage law, would result in a wrong upon the
+other party. The real reason for this limitation of the right, however,
+was that the procedure itself was wrong and the common sense of the
+nation was becoming aware of the fact and thus the courts for one reason
+or another, reached the conclusion that this or that case was not one
+wherein the right could be recognized, when, as a matter of fact, with
+the growing popularity of the right of trial by jury, this old procedure
+was eternally at war, since the former institution was based upon the
+disinterested judgment of impartial men, who were assembled to carefully
+weigh the issues and pass judgment according to the right, whereas, in
+the other procedure interested men, through the influence of friendship
+or other ties, were led to approve the course of a neighbor or a friend,
+however wrong his object might be, and assist him by the corroboration of
+his oath.
+
+A century after this leading case of London vs. Wood,[78] however, in
+which Lord Holt and Baron Hatsell differed as to the reasons why the
+right to wage his law should be denied to the defendant in that case,
+the right was recognized in England, although not expressly enforced by
+the court. In 1805, the case of Barry vs. Robinson,[79] came before the
+English Court of Common Pleas and the Counsel for the plaintiff in his
+presentation of his client’s cause before the court, said: “If a man were
+now to tender his wager of law, the court would refuse to allow it,” as
+the counsel considered that this procedure was entirely obsolete at that
+period. But the reporter of this case, however, advises us that to this
+statement of counsel, the court demurred, or, in the language of the
+Reporter, “This was denied by the court.”
+
+The last recorded case wherein this old defense was attempted in England
+was in the year 1824, in the case of King vs. Williams,[80] but as
+Professor Thayer observes, in his “Older Modes of Trials,”[81] the wager
+of law at this time was “a discredited stranger, ill considered.” This
+was an action of debt, upon a simple contract, a case wherein the wager
+of law clearly applied, under the old practice. The defendant pleaded
+“_nil debet per legem_.” Counselor Langslow appeared for the defendant
+and after filing this plea, asked the court to assign the number of
+compurgators, for the reason that “The books leave it doubtful and this
+species of defense is not often heard of now.” This requested rule,
+to assign the number of compurgators to the defendant was refused by
+Abbot, C. J., who observed: “The court will not give the defendant any
+assistance in this matter. He must bring such number of compurgators
+as he shall be advised are sufficient.” This, upon the theory that
+everyone is presumed to know the law and that the court would not assist
+a litigant in the perpetration of a wrongful act, although it might be
+presented in the robe of regularity, was good enough. But according
+to the ancient report of this case, even as Banquo’s ghost dispelled
+the banqueters, when it was apparent to Macbeth’s fervid imagination,
+so this recourse to the old obsolete wager of law, which allowed an
+adversary with his friends to swear his opponent out of court, caused the
+plaintiff in this case to abandon his cause, for we are advised that:
+“The defendant prepared to bring eleven compurgators, but the plaintiff
+abandoned the action.”[82]
+
+Wager of law was several times invoked in the courts of the United States
+and we find that the Supreme Court considered the nature and limitations
+of the practice, as late as the year 1823, in the case of Childress,
+plaintiff in error, vs. Emory and McCleur,[83] wherein Mr. Webster,
+attorney for the plaintiff in error, in a suit on a note, urged before
+the court that
+
+ “The wager of law has ceased, but many rules of practice and
+ pleading, founded upon it, have survived, and have become rules
+ of property, which cannot be now safely disturbed.... On the
+ English law, it is clear that debt cannot be maintained in this
+ case, as the testator might have _waged his law_, which none
+ can do who defend in a representative character; hence it is
+ that in the case of simple contracts, debt has been superceded
+ by the action of assumpsit, in which, as the testator could
+ not have _waged his law_, his executor is not deprived of any
+ defense which might have been used by the testator.”
+
+To this argument, Mr. Hoffman, for the defendant in error, argued,
+_contra_, that:
+
+ “In an action of debt by a merchant stranger, on any species
+ of simple contract, the defendant was not permitted to _wage
+ his law_. Even in those early times, the courts were strongly
+ disposed to rescue commercial transactions and dealings from
+ this species of trial, as may be seen by the intended operation
+ of the statute _de mercatoribus_, and particularly in the
+ case of foreign creditors, who, it was presumed, could not
+ so easily obtain the requisite evidence, of their claims as
+ resident merchants; and this may be seen in Godfrey and Dixon’s
+ case.”[84]
+
+And Mr. Justice Story, in disposing of the case, _inter alia_ decided:
+
+ “Now, whatever may be said upon the question, whether the
+ wager of law was ever introduced into the common law of our
+ country by the emigration of our ancestors, it is perfectly
+ clear that it cannot, since the establishment of the state of
+ Tennessee, have had a legal existence in its jurisprudence.
+ The constitution of that state has expressly declared, that
+ the trial by jury shall remain inviolate; and the constitution
+ of the United States has also declared that in suits at
+ common law, where the value in controversy shall exceed
+ twenty dollars, the right of trial by jury shall be preserved.
+ Any attempt to set up the wager of law would be utterly
+ inconsistent with this acknowledged right. So that the wager of
+ law, if it ever had any legal existence in the United States,
+ is now completely abolished. If, then, we apply the rule of the
+ common law, to the present case, we shall arrive, necessarily,
+ at the conclusion, that the action of debt does lie against the
+ executor, because the testator could never have waged his law
+ in this case.”[85]
+
+And so Mr. Webster’s defense of the _wager of law_, to this action on
+this note, was held not to obtain, and he lost his case and his client
+was adjudged to pay the note of his testator.
+
+If true that but “a hair divides the false and true,” it is little wonder
+that for centuries, in the struggle for right, immersed amid the darkness
+of the dawn of judicial procedure, an occasional false note should come
+down to us, through the centuries, from the pathetic drama wherein the
+individual was made to assert his right, upon the mere _wager of law_,
+instead of more accurate human standards to balance the scales of
+justice. Judged by our own environment, it seems that the quarrels of the
+Universe of old were gauged far too long by the erroneous standards used
+in the vain pursuit of This and That, about which the citizens of the
+past centuries endeavoured and disputed. And that with the institution of
+trial by jury, brought into existence in the middle ages, the _wager of
+law_ would have much sooner become an obsolete form of procedure.
+
+But in the continuance of the drama of human life, this prided
+institution of our twentieth century, may seem as crude and barbaric to
+the spectators viewing the show from the vantage of subsequent centuries,
+as this grotesque comedy of errors, known as the _wager of law_ now
+appears to us, when we look back upon the judicial farce enacted by our
+ancestors, in the uncertain procedure of Law Wager. They seemed to wander
+“in and out, above, about, below,” yet ever missing the door which led
+to the correct ideal. They labored under new and strange conditions,
+however, and perplexed as they were with the many problems of the Human
+and Divine and intermingling the processes and procedures of the lay and
+ecclesiastical courts, as they did, it is perhaps to their credit that
+the old tangles of the law were solved as creditably as they were.
+
+However this may be, in the _Wager of Law_ we have but another “story
+from of old,” in connection with the perpetual struggle for right, which
+has followed man’s course down through the successive generations of the
+past.
+
+
+FOOTNOTES:
+
+[1] Bouvier’s Law Dictionary.
+
+[2] 3 Bl. Comm. 341; Coke, Litt. 295.
+
+[3] Exodus, XXII., 10.
+
+[4] John’s “Babylonian Laws,” etc.
+
+[5] 3 Bl. Comm. 341; Spellman, L. b. 28, c. 13; Stiernh., _de jure
+Sueon_, 1. l. c. 9.
+
+The clergy were no doubt responsible for the establishment of the
+practice in England, as it resembles the canonical purgation of the
+clergy, as well as the _sacramentum decisionis_, of the civil law. (3 Bl.
+Comm. 342.)
+
+[6] 3 Bl. Comm. 343; Cap. & Wilk. LL Anglo-Saxons.
+
+[7] Coke, Litt. 295; 3 Bl. Comm. 343.
+
+As the effect of the compurgators oath was the same as a verdict, this
+is the reason assigned by Coke and Blackstone, why eleven compurgators
+were required, under the old codes. 3 Bl. Comm. 343; Coke, Litt. 295;
+Glanville, Lib. l, c, 9x.
+
+[8] I. Pollock and Maitland’s History English Law, p. 140.
+
+[9] II. Pollock and Maitland’s History English Law, 600.
+
+[10] Lea, “Superstition and Force,” (3 ed.) 35.
+
+[11] II. Pollock and Maitland’s History English Law, 600.
+
+It was also a custom for a long time, for the defendant to select his
+compurgators from the nominees of the injured person, and a case is
+recorded, as late as 1277, in Leicester, where this was required, but
+it was soon abolished as too onerous a task for an accused person. II.
+Pollock and Maitland’s History English Law, p. 636, note.
+
+[12] Laws Wihtraed, cap. 16, 21; Lea, “Superstition and Force,” (3 ed.)
+23.
+
+[13] III. Reeve’s History English Law, 294.
+
+[14] Glanville, Book I., chap. IX.
+
+[15] Coke, Litt. 168b.
+
+[16] Coke, Litt. 295a; 2 Inst., 44.
+
+[17] _Les Termes de la Ley, ad voc. ley._
+
+[18] Bracton, 410a.
+
+[19] Bracton, 366a; 410a.
+
+[20] _Ante idem._
+
+[21] Bracton, fol. 366; Note Book, pl. 7, 1436.
+
+[22] Note Book, pl. 731, 742.
+
+[23] Note Book, pl. 396, 1097.
+
+[24] Bracton, fol. 156; Note Book, pl. 477, 741.
+
+[25] Somersetshire Pleas, pl. 572.
+
+[26] Bracton, fol. 315b; Note Book, pl. 580.
+
+[27] Note Book, pl. 184, 1574.
+
+[28] 38 Edward III. st. l, c. v.
+
+[29] III. Reeve’s History English Law, 184.
+
+[30] 38 Edward III. st. l, c. 3.
+
+[31] III. Reeve’s History English Law, 295.
+
+[32] 28 Edward III. 100a; 29 Edward III., 44b; III. Reeve’s History
+English Law, 295.
+
+[33] 47 Edward III., 18; III. Reeve’s History English Law, 295.
+
+[34] 38 Edward III., 7a.
+
+[35] Coke, Litt. 295.
+
+[36] 3 Bl. Comm. 346.
+
+[37] Coke, Litt. 295.
+
+[38] 3 Bl. Comm. 346.
+
+Wager of law was never required, in England, but was allowed, as a
+privilege to the defendant. Coke, Litt. 295.
+
+[39] Mun. Gild. I., 56, 59, 90, 92; II. Pollock and Maitland’s History
+English Law, p. 635.
+
+[40] Mun. Gild. I., 57; II. Pollock and Maitland’s History English Law,
+_supra_.
+
+[41] Mun. Gild, ii, 321; II. Pollock and Maitland’s History English Law,
+p. 636.
+
+[42] Palgrave, English Commonwealth, pp. 117. Lyons Dover, ii, 300, 315.
+
+[43] III. Reeve’s History English Law, 567.
+
+[44] This was by virtue of a statute of the reign of Henry IV. III.
+Reeve’s History English Law, c. xviii.
+
+[45] III. Reeve’s History English Law, p. 568.
+
+[46] 14 Henry VI., 24.
+
+[47] 39 Henry VI., 18.
+
+[48] 28 Henry VI., 4.
+
+[49] _Ante idem._ III. Reeve’s History English Law, p. 569.
+
+[50] 38 Henry VI., 14, 22.
+
+[51] III. Reeve’s History English Law, 570.
+
+Referring to the fact that wager of law was allowed in actions of debt
+and detinue and the attempt to demonstrate that this was because jury
+trials were inconsistent with the rights of the parties in these actions,
+Pollock and Maitland, in their History of English Law, show that the
+truth is that these actions are older than jury trials. (Vol. II., p.
+634.)
+
+[52] II. Pollock and Maitland’s History English Law, p. 636.
+
+[53] _Ante idem._
+
+[54] _Ante idem._
+
+[55] 3 and 4 William IV., c. 42, sec. 13.
+
+[56] Jur. Prov. Saxon. Lib. I., Art. 15, 18, 39.
+
+[57] Lea, “Superstition and Force,” (3 ed.) 22, note.
+
+[58] This protest against this procedure was in the Fifteenth century.
+Schilter. Thesaur, II., 291.
+
+[59] Pike, History Crime, i, 130; Thayer, “Older Modes of Trial,” II.
+Essays in Anglo-American Legal History, p. 384.
+
+[60] Jacob’s Review of the Statutes (2 ed.), 532.
+
+[61] Anastas Biblioth. No. LXII.
+
+[62] Gregor. Turon. Hist. Lib. V., cap. XLIX. The custom of acquitting
+oneself by swearing on different altars, was an old Anglo-Saxon practice,
+the plaintiff being allowed to substantiate his claim by oaths upon four
+altars, while the defendant could rebut the charge by oaths upon twelve
+altars. Dooms of Alfred, Cap. 33; Fleta, Lib. II., cap. lxiii, sec., 12.
+
+[63] Spelman, Concil. I., 335.
+
+[64] Lea, “Superstition and Force,” (3 ed.) 57.
+
+[65] _Ante idem._, p. 61.
+
+[66] Ann. Wint. 109; Wykes, 234; II. Pollock and Maitland’s History
+English Law, 636.
+
+[67] Maitland’s Pl. Cr. i, case, 61; Palgrave’s Com. ii, cxix, note.
+
+[68] Lyon’s History Dover, ii, 265; II. Essays in Anglo-American Legal
+History, 385.
+
+[69] Year Book, 19 Henry VI., 10, 25.
+
+[70] Year Book, 33 Henry VI., 7, 23.
+
+[71] Cal. Proc. in Chan, i, ccxx-ccxxii. In Spence’s Equity
+Jurisprudence, this case is cited as one of the notable cases which
+finally helped to bring about the repeal of the law wager.
+
+[72] Goldsborough, 51, pl. 13; Doctor and Student, ii, c. 24; Thayer’s
+“Older Modes of Trial,” II. Anglo-American Legal History, p. 388.
+
+In the persecution of the reformers, in 1527, under Henry VIII., Margaret
+Cowbridge and Margery Bowgas were allowed to acquit themselves by the
+oaths of compurgators, although there were several witnesses against
+them, and the compurgators comprised several women in the test.
+
+[73] Slade’s Case, 4 Rep. p. 95.
+
+[74] Company of Glaziers’ Case, 2 Salk. 682.
+
+[75] 12 Mod. 669, 684.
+
+In Gunner’s case, in 1708, the plaintiff took a non-suit when the
+defendant was ready to wage his law. Jacob’s Review of the Statutes, (2
+ed.) 532.
+
+[76] London vs. Wood, 12 Mod. 669, 679. This opinion of Lord Holt, that
+wager of law would not lie, unless the debt was a secret debt, is based
+upon the law, as stated by Sir Edward Coke, for he says: “The reason
+wherefore, in an action of debt upon a simple contract, the defendant
+may wage his law, is for that the defendant may satisfy the party in
+secret, or before witnesses and all the witnesses may die.” (II. Inst,
+45.) But of course this same plea of payment would be good, whether the
+debt arose on contract or in parole, and the same reason would obtain for
+perpetuating the testimony, and this illustrates how an erroneous custom
+will live upon irrational doctrines.
+
+[77] 12 Mod. 669.
+
+[78] 12 Mod. 669.
+
+[79] I. B. & P. (N. P.) 297.
+
+[80] 2 Barnew & C. 538; 4 D. & R. 3.
+
+[81] V. Harvard Law Review; II. Essays in Anglo-American Legal History,
+391.
+
+[82] King vs. Williams, 2 Barnew. & C. 538; 4 D. & R. 3.
+
+[83] 8 Wheaton, 642; 21 L. Ed. 705.
+
+[84] Palmer’s Rep. 14; Fleta, 136.
+
+[85] 8 Wheaton, 675; 21 L. Ed. 713.
+
+Compurgation was allowed in a charge of usury, by statute in
+Massachusetts, in 1783. (St. Mass. 1783, c. 55.) But in Little vs.
+Rogers, (1 Met. 108) Shaw, C. J., observes that the trial by jury has
+been “substituted for the old trial by oath.”
+
+Mr. Lea, in his excellent work, “Superstition and Force” (3 ed.) mentions
+the fact that in South Carolina, an act of the Legislature of 1712
+mentions specific English laws as still in force and enumerates the
+law of compurgation, or wager of law, and that in Maryland, as late as
+1811, Chancellor Kilty mentions the fact that wager of law has gone into
+disuse, because contrary to our spirit of law, but does not contend that
+it had then been specifically abolished, in Maryland. (Cooper’s Stat.
+at L. of So. Car. Columbia, 1837, II., 403; Kilty’s Report on English
+Statutes, Annapolis, 1811, p. 140; Lea, “Superstition and Force,” p. 81.)
+
+
+
+
+CHAPTER VIII.
+
+BENEFIT OF CLERGY.
+
+
+Engrossed as the profession is today with the agitation for the
+betterment of our remedial procedure, it will sometimes prove profitable
+to turn aside from the progress of our twentieth century procedure and
+entering the musty lumber-room of the law, brush aside the cob-webs
+and take a cursory view of some of the pleas that occupied the time of
+courts and lawyers of past centuries. Nothing is calculated to encourage
+more respect for the modern procedure of American and English courts,
+than reading the history of some of the unequal and unjust privileges
+and exemptions which obtained in the administration of the English law,
+until a comparatively recent date. The contrast is indeed striking, when
+we turn from the just ideals of equality and justice that characterize
+the remedial procedure of our day, to contemplate some of the customs
+and pleas that were followed and enforced by our own courts, before the
+evolution of our civilization had made the present ideals possible.
+
+There is no doubt but that the English common law is the outgrowth of
+the most enlightened system of jurisprudence that the world has ever
+seen, for it represents the best thought of the brightest minds of
+civilization’s most progressive people. Its rules and doctrines were
+formed, however, during the middle ages, and although it was generally
+consistent with the scholastic methods of thought that dominated the
+thinking world of that period and for the most part, it was in thorough
+accord with proper and just ideals, yet, at the same time, the general
+doctrines and principles were applied along with many of the unequal
+proceedings and special pleas and privileges existing in favor of the
+higher classes and together with the extremely technical standards, that
+frequently were nothing but mere fantastic quibbles.
+
+The benefit of clergy is an illustration of the engraftment upon this
+enlightened system of jurisprudence, of one of the old special privileges
+of a favored class, who, as an incident and high prerogative of their
+office, claimed exemption from punishment for crimes. Of course such
+an exemption of a favored class was inconsistent with the object of
+distributive justice, to visit equal punishment upon all alike who are
+similarly situated and with the elevation of the standards of justice and
+equality, the plea was finally abolished by the legislative and judicial
+branches of Government in England and the United States.
+
+The benefit of clergy, or _privilegium clericale_, was the exemption of
+the clergy from all responsibility to the temporal courts and laws from
+the punishment imposed for various criminal offenses. Originally the
+persons of clergymen alone were held to be exempt from criminal process
+before a secular judge, but the privilege was later extended by the law
+to all who could read, as all such were held to be _clerica_, or clerks.
+
+For many centuries this plea was an important part of the criminal
+procedure of the continental countries of Europe and still furnishes a
+curious and instructive part of the history of the laws of England.
+
+The privilege had its origin in a claim made by the ecclesiastics,
+at a very early period, for the entire exemption of their order from
+the jurisdiction of the common law courts of England. The growth and
+development of the privilege is an interesting chapter in the history
+of the controversy between the secular and spiritual power, during the
+middle ages and the limitation or expansion of the authority of the State
+or the Church, over matters temporal, depended largely upon the public
+sentiment that shaped the policies of the government and the weakness or
+strength of the individuals holding the reigns of government.
+
+Benefit of clergy was the immediate outgrowth of conditions contributing
+to the growth of the English common law. Before the Norman conquest and
+afterwards, for many centuries, the clergy took a very active part in
+the legislation and judicial branches of government and they shaped the
+policies of the government, in many important respects. The educated
+class belonged to this profession and we owe it largely to them that
+the Anglo-Saxon law has left us any evidences at all. During the Saxon
+period of superstition and ignorance, the ecclesiastical power had the
+ascendency, but it gradually declined, as intellect and education became
+the common property of the masses. Bishops were then the principal
+members of the courts of law and they instructed the judges in both the
+spiritual and secular laws and the respective limits upon each.[1] The
+question of ecclesiastical or lay jurisdiction gave rise to the most
+intense jealousies and contests between sovereigns and archbishops and
+lawyers, but the superior learning of the clergy resulted in a gradual
+encroachment by the Church upon the powers of the State.[2] During the
+reign of Henry II., the jurisdiction of the king’s court over criminal
+clerks was the subject of a memorable quarrel, between king Henry and
+Thomas a’ Becket.[3] Boniface, Archbishop of Canterbury, as the successor
+of Becket, waged a continuous fight, during the reign of Henry III., to
+establish and enlarge the power of the Church, over matters secular, when
+clerks or churchmen were brought before the secular courts. He ordained,
+under the authority of a convocation, in 1261, that archbishops, bishops
+and other inferior churchmen should ignore the letters of the king,
+calling them for trial before secular courts,[4] and before this, in
+1253, with other bishops, he pronounced a sentence of excommunication
+against all those who had violated similar provisions of the canonical
+laws, while enforcing secular power.[5]
+
+In this civilized age, it seems strange that the Church would so dominate
+the State, since the State must have consented to such a power, or it
+could not have existed; but the Church, in this superstitious period
+of mankind, held the terror of excommunication over the heads of the
+temporal authorities and the State was thus coerced into the gradual
+consent to the domination of the spiritual authorities. The Church always
+claimed exclusive jurisdiction over all spiritual offenses, and as it
+held the unfettered power of excommunication, even though its degrees
+were opposed to secular laws, those around whom the Church threw its
+protecting arms were really held to be above and beyond the power of the
+secular courts.
+
+The power of the Church was based upon a theory of Divine Right and it
+was claimed to be far nobler than that of the State, because, whereas,
+the power of the Pope extended to the soul, itself, the power of Princes
+was limited to the body alone. The power of the Church, being thus _jure
+divino_, ought to have been limited, at all times, to matters spiritual,
+but by a gradual encroachment and by compact with the powers of the
+State, the Church also assumed to exercise authority over bodies by the
+aid of the State. But notwithstanding the firmness with which the clergy
+claimed the exemption from all secular interference for the persons of
+clerks, and the general indulgence that the laity gave to this claim,
+confirmed, as it was by solemn declarations and acts of Parliament, the
+privilege was always viewed with more or less jealousy and considered
+as a usurpation that was generously tolerated rather than as a part and
+parcel of the established common law of England.[6]
+
+Under the terms of the canonical decree, “No power was given to laymen
+to judge God’s anointed,”[7] because laymen, instead of possessing
+power to command, were under the Divine injunction to obey the Church
+and Churchmen. The clergy was not without a notable precedent for this
+position, for it was recorded that king Alfred had a judge hanged who had
+executed a clerk, because as a secular judge, he must have known that he
+had no power over clerks.[8]
+
+Churchmen also found many Bible references as authority for the
+privilege. In King David’s psalm of praise, he cautioned his subjects:
+
+ “Be ye mindful always of his covenant, and the word which he
+ commanded to a thousand generations;
+
+ Even of the covenant which he made with Abraham and of his oath
+ unto Isaac;
+
+ And hath confirmed the same to Jacob for a law, and to Israel
+ for an everlasting covenant:
+
+ He suffered no man to do them wrong; yea, he reproved kings for
+ their sakes,
+
+ Saying, _Touch not mine anointed, and do my prophets no
+ harm_.”[9]
+
+One guilty of the crime of high treason was not entitled to clergy
+and the exemption was not granted to those convicted of ordinary
+misdemeanors.[10] A clergyman was exempted from capital punishment
+_toties quoties_, as often as he repeated the same offense; for a second,
+although it might be a wholly different offense, he was hanged. But of
+the laity, peers and peeresses were discharged for the first offense,
+without reading, while commoners, of the male sex, who could read,
+were branded in the hand and women commoners were held not entitled to
+clergy.[11] Nuns, however, were held entitled to their clergy, at an
+early day, the same as the monks and other churchmen, but the privilege,
+in contemplation of the law, enured for the benefit of the church and not
+for the nun.[12]
+
+As the privilege was enforced in more recent times, after conviction and
+any time before the execution of the sentence, when the clerk claimed his
+clergy, a priest or ordinary would present him with a “psalter,” and if
+he could read his “neck-verse,” he was burned in the hand and discharged.
+The first verse of the 51’ Psalm was the verse most generally read to
+test the learning of the prisoner and this verse was therefore called a
+“neck-verse,” because it decided the fate of the person claiming clergy,
+and the neck of the unfortunate called upon to read this verse depended
+upon his ability to read it.[13] The rule of law governing the ordained
+clerk was that he could not be tried in the lay courts at all, but only
+in an ecclesiastical court and his punishment was governed entirely by
+that court. In Bracton’s time, even before conviction in the secular
+court, the clerk was delivered when demanded by the bishop’s court.[14]
+But before the end of the reign of Henry III. the accused was not
+delivered until after his conviction.[15]
+
+In the time of Edward III., the recognition and enjoyment of the benefit
+of clergy, depended entirely upon the ordinary demanding the felon as a
+clerk from the secular authorities.[16] In the reign of Edward IV., if
+the ordinary refused a man his clergy, where he was able to read, the
+cause was certified to the King’s Bench, and the ordinary was fined,
+on the theory that he was only a minister of the secular court and not
+a judge in the cause.[17] And during the same reign, if the ordinary
+granted clergy to a felon who could not read, the ordinary was fined and
+the convict hanged and the secular courts assumed the right to judge of
+the ability of the prisoner to read, for they made the record, “_quod
+legit ut clericus, ideo tradator ordinario_” and if the ordinary granted
+clergy to one who could not read, or refused it to one qualified, he was
+fined.
+
+But the qualification as to reading was not strictly applied at this
+period, for if the prisoner could spell and thus put syllables together,
+he was held, by Fortescue, to be entitled to his clergy. Littleton said
+that if the clerk refused generally to read, he was denied his clergy;
+but if a cause were stated which could not be allowed by the law of
+the land, as where he had not the _tonsura clericalis_ or _ornamentum
+clericale_, if clergy were refused, the ordinary was fined and enjoined
+to receive the felon.[18]
+
+During the reign of Edward IV. the prisoner claimed his clergy, upon his
+arraignment, but this was deemed prejudicial to the prisoner, for he
+thus had no challenges and was denied the right to a trial on the merits
+and even if innocent of the crime, if he could not read, was hanged,
+and his estate was forfeited. Sir John Priscott, Chief Justice of the
+Common Pleas Court, during the reign of Henry VI. changed the practice
+and when the felon claimed his clergy, on arraignment, he was required
+to plead to the merits and then, if convicted, the crown took his estate
+by forfeiture and he was then allowed his clergy. This practice served
+the double purpose of giving the prisoner the benefit of a trial on the
+merits and giving the crown a chance at his estate, which the other
+practice denied to the crown and hence, it was afterwards generally
+followed.[19]
+
+It was customary to keep a register of clerks-convict and persons
+attainted, so that such persons might not have their privilege more than
+once.[20]
+
+The burning in the hand, which was a necessary part of the procedure
+of the privilege of clergy, was not ordained by the statute (IV. Henry
+VII.) as a punishment, but merely to enable the court, on a subsequent
+arraignment of the offender, to ascertain if the defendant had been
+accorded his clergy. By statute, during the reign of Elizabeth (18
+Elizabeth), it was enacted that the prisoner should not be delivered
+until he had been burned in the hand, and in Biggen’s case, near the end
+of the reign of Queen Elizabeth, it was decided, notwithstanding the
+statute referred to, that the Queen could pardon the burning in the hand,
+but unless she had done so, the prisoner could not be discharged until
+he had been burned in the hand, and must remain perpetually in prison.[21]
+
+The case of one Stone, originating during the fourth year of the reign
+of Queen Elizabeth, is interesting as showing the effect of clergy upon
+crimes committed preceding the granting of clergy to the criminal. Stone
+had committed two felonies in one day, one of which was clergyable and
+the other not. He was first indicted upon the crime which was clergyable
+and being found guilty, was admitted to clergy and the judgment was
+recorded. Having been adjudged guilty at a subsequent session upon the
+non-clergyable felony, the conviction on the clergyable offense was
+set up in bar and was held to be good, by a divided court, seven of
+the thirteen deciding that since he had been once placed in jeopardy,
+it should not be presumed that the felony for which clergy was not
+admissible was committed before the other and _in favorem vitae_, the
+most merciful side should be taken and though the felony upon which he
+was convicted last was committed after the other one, yet since the felon
+had suffered judgment upon the former conviction, as a clerk convict, he
+should not be arraigned upon the second indictment, because the effect
+of the discharge on the conviction was to acquit him of all felonies
+committed before the conviction, as he should have been arraigned for
+all his offenses before his clergy was allowed and the court would be
+presumed to have had them in mind, as this was the duty of the court,
+and the effect of his clergy was to discharge him of all preceding
+felonies.[22]
+
+The judgment of the court, in Stone’s case, as to the effect of clergy
+upon a preceding crime, was followed in an early North Carolina case,[23]
+where the court held that if the defendant claimed clergy for an offense
+committed before clergy was granted to him, this claim should be urged
+the same as a pardon, when the prisoner was brought up for judgment on
+the latter conviction.
+
+The distinction between “clergyable” and “unclergyable” crimes was not
+so clearly defined during the thirteenth century, as at a later period.
+At this time the benefit of clergy was but the privilege of “ordained
+clerks” and the legislation of king John’s reign shows that the exemption
+was slowly and by degrees ordained as not applicable to the crime of
+high treason.[24] While the exemption to the clerks of the twelfth
+century was much broader than later, during the thirteenth century clerks
+could be tried for all minor offenses and in Bracton’s day clerks were
+answerable to civil process the same as the laity.[25] The clergy had so
+far established the exemption of their persons from corporal pains, that
+during the reign of Henry III. it was enacted that a clerk, taken for the
+death of a man, or for any other crime, if demanded by the ordinary, was
+to be immediately delivered, without inquisition, to the court Christian,
+to make canonical purgation and to establish his innocence or stand
+convicted.[26]
+
+During the reign of Edward I., the practice established during the reign
+of Henry III., that a clerk, convicted of felony, could be delivered to
+the ordinary, was recognized by act of Parliament (Statute Westminster),
+and this statute recited this privilege and simply admonished the
+prelates not to liberate those so delivered to them, without putting
+them to their canonical purgation.[27] In the 25’ year of Edward III.
+the clergy complained to Parliament that a certain knight, entitled to
+clergy, had been hanged and quartered, on a judgment of treason and that
+a priest had been hanged for killing his master. These complaints led to
+the enactment of the statute _De Clero_ (25 Edward III. st. 3) by the
+terms of which it was provided that henceforth all manner of clerks, as
+well secular as religious, convicted before any secular justice, for
+treason or felony, touching other persons than the king himself or his
+royal majesty, should freely have and enjoy the privilege of the holy
+church and should, without any impeachment or delay, be delivered to the
+ordinary demanding them.[28]
+
+During the reign of Henry VII. (7 Henry VII., c. 1), the benefit of
+clergy was taken away from persons convicted of desertion while under
+enlistment as soldiers of the crown and the privilege was likewise taken
+away from those convicted of petit treason. The exemption of the clergy
+from punishment for crimes was given a most decided set-back by the
+statute 4’ Henry VIII., c. 2, which provided that:
+
+ “All persons committing murder or felony, in any church,
+ chapel, or hallowed place; or who, of malice prepens, rob or
+ murder any person in the king’s highway, or rob or murder any
+ person in his house, the owner or dweller of the house, his
+ wife, child or servant being then therein, and put in fear or
+ dread, shall not be admitted to clergy.”
+
+This statute contained no exception of those actually engaged in the
+holy orders and this led to the most determined resistence on the part
+of the clergy of the kingdom.[29] Henry VIII. stood firm, however, and
+during the same reign another statute was passed (23 Henry VIII., c.
+1), taking away the benefit of clergy from persons convicted of petit
+treason, wilful, malicious murder, robbery, wilful burning of a dwelling
+house, or barn, where grain or corn was stored, and the like privilege
+was denied to the abettors, helpers, maintainers or counselors of such
+felons, except only such as were within the holy orders. It was also made
+a felony, without clergy, for a clerk convict to break prison and escape,
+and this was a serious blow to the exemption, for though the lives of the
+clergy were spared, after conviction of the offenses named, yet they were
+to be condemned to imprisonment and even to death, if the ordinary so
+directed.[30]
+
+By 27 Henry VIII., c. 17, clergy was also taken away from servants who
+embezzled their master’s goods or property, and by 28 Henry VIII., c. 1,
+persons under holy orders were to be judged the same as those not under
+holy orders, so that real clerks were subjected to capital punishment for
+felony, the same as nominal clerks.[31] During the same reign, by statute
+33 Henry VIII., c. 1 to 14, clergy was denied to persons practicing
+witchcraft or enchantment and to those making prophesies upon coates
+of arms, badges, etc.[32] Before the reign of Elizabeth, the granting
+or recording clergy had been reduced to a mere formality, but by 18’
+Elizabeth, it was provided that the temporal courts should not deliver
+the prisoner, until he had been burned in the hand.[33]
+
+Benefit of clergy was not abolished, in England, until the year 1825,
+when, by statute, 7 George IV., c. 28, sec. 6, this ancient privilege of
+the middle ages was abolished, in that country.
+
+In the United States, by Act of Congress, April 30’, 1790, it was
+provided that the benefit of clergy should not be allowed upon conviction
+for any crime where, by statute, the punishment was death. In North
+Carolina, in 1816, the punishment by burning in the hand was abrogated,
+and, in Kentucky, the benefit of clergy was abolished, by statute, in
+1847.[34]
+
+The celebrated case of Doctor Horsey, Chancellor to the Bishop of London,
+who, during the reign of Henry VIII., was prosecuted and adjudged guilty
+of the murder of John Hunne, is one of the most interesting that has
+come to the writer’s attention. On account of the well known position
+of Doctor Standish, as an advocate of the temporal power, the clergy
+concluded not to wait upon the procedure of the temporal courts, in
+Doctor Horsey’s case, but they caused a charge of heresy to be lodged
+against Doctor Standish, because of his advocacy of the power of the
+temporal courts over the persons and punishment of clerks. The clergy
+and the justices of the King’s Courts had a notable dispute concerning
+the power of the temporal courts over the persons of clerks, the clergy
+contending that the benefit of clergy was established by the express
+command of Jesus Christ, in the words, _nolite tangere Christos meos_,
+while the temporal justices argued that these were the words of King
+David, not of the Saviour at all, and that the “anointed,” referred to
+the believers, to distinguish them from the unbelievers, then abroad in
+Palestine. Those who had proceeded against Doctor Standish were adjudged
+guilty of a _praemunire_, when Cardinal Wolsey threw himself at the
+king’s feet and beseeched him to withhold his decision until the Pope
+could be heard from. King Henry, however, decided that the arguments of
+the supporters of Doctor Standish had not been answered by the clergy and
+concluded with all of his accustomed firmness:
+
+ “By the order and sufferance of God, we are king of England;
+ and the kings of England who have gone before us never had
+ any superior but God alone; and, therefore, know that we will
+ maintain the right of our crown and temporal jurisdiction, as
+ well in this point as in others, in as ample a manner as our
+ predecessors have done before us.”[35]
+
+This decisive stand of the King concluded the agitation concerning the
+conflict of authority over the case of Doctor Horsey. Doctor Standish
+was discharged from the charge of heresy. Doctor Horsey was so far
+rescued from temporal power, however, that he enjoyed the free custody
+of the house of the Archbishop of Canterbury, until the popular clamor
+had subsided, when he was privately surrendered to the court of King’s
+Bench and having entered a plea of not guilty, it was confessed and the
+defendant was discharged.[36]
+
+Although the clergy thus failed to convince Henry VIII. of the true
+foundation of its power, in the case of Doctor Standish, it lost none
+of its authority against the temporal courts, in the case of Doctor
+Horsey, but its jurisdiction and the benefit of clergy was practically
+conceded by the judges of the king’s court and the privilege continued
+to be recognized until the 23’ year of this king’s reign, when he waged
+war against the whole papal authority and passed an act taking away the
+benefit of clergy from murder and robbery, in certain cases.[37]
+
+One of the most distinguished men known to have been accorded the benefit
+of clergy, in England, was the gifted Ben Jonson, the friend of “gentle
+Shakespeare” and the scholarly Lord Bacon. He was arraigned at the Old
+Bailey, in October, 1598, for the manslaughter of Gabriel Spencer, in a
+duel. The indictment charged that the defendant, at Shordiche, had,
+
+ “with a certain sword of iron and steel called a rapiour, of
+ the price of 3s., which he then and there had in his right
+ hand and held drawn, feloniously and wilfully struck the same
+ Gabriel then and there with the aforesaid sword, giving to the
+ same Gabriel Spencer, in and upon the same Gabriel’s right side
+ a mortal wound, of the depth of six inches and of the bredth
+ of one inch, of which mortal wound the same Gabriel then and
+ there died instantly.”[38]
+
+The record in this same case further shows that the prisoner when
+arraigned,
+
+ “Confessed the indictment, asked for the book, read like a
+ clerk, was marked with the letter T, and delivered according to
+ the form of the statute,”
+
+which meant that the author of “Every Man in His Humor” had claimed and
+been accorded the benefit of clergy; that he had been branded on the left
+thumb with a T, generally known as the Tyburn T, and discharged.[39]
+
+The benefit of clergy was set up and recognized in many criminal cases
+in the United States, during the Colonial period and the great patriot,
+James Otis, successfully urged the exemption in favor of Massachusetts
+soldiers, convicted of murder for their participation in the Boston
+massacre.[40] The Federal Court decided, in the year 1817, in the case
+of United States vs. Lambert,[41] that a person convicted of bigamy,
+in Alexandria, was entitled to clergy, and, if able to read, should be
+burned in the hand and recognized for good subsequent behaviour. In the
+year 1830, the Federal Court held, in the case of United States vs.
+Jernegan[42] that on a conviction for bigamy, in granting the benefit of
+clergy, it was discretionary with the trial court to dispense with the
+burning in the hand.
+
+In the year 1806 the Supreme Court of North Carolina held that females
+could claim the benefit of clergy, the same as males.[43] The Legislature
+of North Carolina, having, in 1816 passed a statute abolishing the
+punishment of “burning in the hand” for clergyable felonies, the Supreme
+Court of that state, construing this statute, in 1825, in the case of
+State vs. Yeater,[44] held that corporal punishment and imprisonment
+could not both be inflicted upon a person found guilty of the crime of
+manslaughter.
+
+In 1837, however, in the same state the same court held that one found
+guilty of manslaughter could be burned in the hand and also imprisoned
+for one year. And in the year 1855, the Supreme Court of North Carolina
+held that when a new felony was created by statute, the privilege of
+clergy was an incident thereto, unless it was expressly taken away by
+the statute creating the offense.[45] And in State vs. Carroll,[46] the
+same court held that when the defendant prayed the benefit of clergy, for
+a clergyable offense, if the State objected because the defendant had
+before had clergy, this objection must be set up by a plea in writing.
+
+In State vs. Sutcliff,[47] decided in South Carolina, in 1855, a
+defendant, convicted of burning a dwelling house, was held entitled to
+the benefit of clergy, and in the same state, the same year, another
+person convicted of arson in the nighttime, was held entitled to
+clergy.[48]
+
+In Indiana, in 1820, and in Minnesota, in 1859, the Supreme Courts of
+those states held that the benefit of clergy did not and never had
+existed in those commonwealths,[49] and in the year 1787 the Supreme
+Court of Virginia held that the crime of arson was not a clergyable
+offense in the courts of that state.[50] But in the same state, in 1795,
+two persons were convicted for stealing a horse, in 1793, and before
+the _sentence of death_ was pronounced, they both prayed the benefit of
+clergy and the Supreme Court held that they were entitled to clergy.[51]
+
+One of the last cases where clergy was recognized, in the United States,
+was in a Kentucky case.[52] A negro was convicted of rape upon a white
+woman, after a trial had before Judge Buckner, in Bonner County, at
+Glasgow. Under the statute, the punishment to be assessed was death and
+the judge believed the defendant innocent of the crime for which he had
+been convicted. The defendant’s counsel claimed the benefit of clergy
+for him and the defendant was found able to read the Constitution of the
+United States and he was accordingly burned in the hand and discharged.
+
+These instances are not nearly all that could be found in England or the
+United States to illustrate the application of this exemption from crime,
+at common law, but the random cases mentioned will show the general
+recognition of the privilege until comparatively recent times.
+
+There is no doubt but what the benefit of clergy bred much crime
+and operated, for centuries, as a great impediment in the impartial
+enforcement of the criminal laws of England and the United States. Like
+the right of sanctuary, established by the early Saxon kings, the benefit
+of clergy owed its existence to the fact that the law’s redress of wrongs
+was, at an early period in the history of the world, inadequate to
+protect the educated class from the ambition and cupidity of the race and
+in the dangerous games for place and power then waged, these privileges
+were very dear to Englishmen and on the whole, were strictly respected.
+
+Judged by modern standards, the exemption of the clergy, enlarged to
+include all those who could read, from the punishment that others,
+similarly situated, were subjected to, who were not so fortunate as to
+be able to read, seems an anomaly in the administration of any system
+of justice; but it must be accepted as a mere incident of the barbarous
+period when the privilege was applied.
+
+As a doctrine of the common law, it illustrates the fallibility of
+all institutions of man, both in and out of the holy orders. The
+privilege had neither justice nor reason for its foundation, but, like
+the practice of witchcraft, enchantment and the belief in ghosts, so
+prevalent during the same period, it owed its existence to the ignorance
+and superstition of that civilization. Because of such an unjust practice
+the common law is not to be condemned, any more than is the literature
+of the same period of English history, because of the introduction of
+ghosts, witchcraft and enchantment, into the literary masterpieces of the
+past centuries, for these beliefs were prevalent at that time.
+
+The Benefit of Clergy was an institution of the “myriads who, before us,
+pass’d the door of darkness through.” No doubt some of our institutions
+and procedure, to the jurists of succeeding ages, that come and go, “upon
+this chequer-board of nights and days,” will seem equally as unjust and
+ridiculous as this institution of the past now appears to us. We should
+congratulate ourselves, that with our own liberal constitution, founded
+upon a more exact idea of distributive justice, we are able to “grasp
+this sorry scheme of things,” which existed until the present century.
+But that this institution continued until the past century, ought to
+prevent our entire satisfaction with our own procedure, and urge us to
+the improvement of our present laws.
+
+
+FOOTNOTES:
+
+[1] Bracton, Ch. XII., fol. 409.
+
+[2] Glanville, lib. V. c. VIII., IX.
+
+[3] Maitland, Henry II. and Criminous Clerks, E. H. B. vii 224; I.
+Pollock and Maitland’s History Eng. Law, p. 447.
+
+[4] II. Reeve’s History English Law, p. 341.
+
+[5] Bracton, De Legibus, lib. V. c. XI., XII.; II. Reeve’s History
+English Law, p. 344.
+
+[6] III. Reeve’s History English Law, p. 196.
+
+[7] Decret, lib., 1, tit. 10; III. Reeve’s History English Law, p. 348.
+
+[8] Mirror, c. V.
+
+[9] 1 Chronicles, XVI. 15, 22; Also, 1 Kings, XXVI. 9; 2 Kings, I. 16.
+
+[10] 1 Chitty, Criminal Law, 667, 668; 1 Bishop’s Criminal Law, Secs.
+622, 624; 4 Bl. Comm. ch. 28.
+
+[11] Bouvier’s Dictionary, tit. Benefit of Clergy.
+
+[12] II. Hale’s Pleas of Crown, 328, 371; I. Pollock and Maitland’s
+History English Law, p. 445. By a curious combination of terms, some of
+the old cases refer to the exemptions women in pregnancy enjoyed in the
+law, as “Clergy of the belly.”
+
+[13] Webster’s New Int. Dict; Murray’s English Dict., “Neck-verse.”
+
+[14] Bracton f, 123b; I. Pollock and Maitland’s History English Law, p.
+442.
+
+[15] Coke, 2 Inst. 164.
+
+[16] III. Reeve’s History English Law, pp. 197, 198.
+
+[17] IV. Reeve’s History English Law, p. 59.
+
+[18] 9 Edward IV. 28.
+
+Kelying reports a case, where at the Lent Assizes, for Winchester, the
+clerk appointed by the bishop to give clergy for the prisoners, charged
+with larceny, delivered the book to the prisoner and the prisoner did
+not look at the book at all, but when asked, “_legit_ or _non-legit_,”
+the clerk replied “_legit_.” The court then bid the clerk of assizes not
+to record that the prisoner read, and fined the bishop’s clerk for so
+finding. (18 Car. II.)
+
+[19] Littleton, 2 Inst. 164; IV. Reeve’s History English Law, p. 60.
+
+[20] IV. Reeve’s History English Law, p. 466.
+
+[21] 5 Eliz. Dyer, 50; V. Reeve’s History English Law, p. 346.
+
+[22] V. Reeve’s History English Law, p. 345.
+
+[23] State vs. Carroll, 27 N. C. (5 Ired.) 139.
+
+[24] II. Pollock and Maitland’s History English Law, p. 501.
+
+[25] Bracton, f. 401b; I. Pollock and Maitland’s History English Law, p.
+130.
+
+[26] II. Reeve’s History English Law, pp. 421, 422.
+
+[27] II. Reeve’s History English Law, p. 573.
+
+[28] III. Reeve’s History English Law, p. 197.
+
+[29] IV. Reeve’s History English Law, pp. 458, 463.
+
+[30] IV. Reeve’s History English Law, p. 466.
+
+[31] IV. Reeve’s History English Law, p. 468.
+
+[32] IV. Reeve’s History English Law, p. 468.
+
+[33] V. Reeve’s History English Law, p. 346.
+
+[34] American Com. Kentucky, p. 407.
+
+[35] IV. Reeve’s History English Law, pp. 458, 462; Keilw. 180b, to 185b.
+
+[36] Keilw. 180b, to 185b; IV. Reeve’s History English Law, pp. 458, 462.
+
+[37] IV. Reeve’s History English Law, p. 463.
+
+[38] This original old musty indictment was recently unearthed at the old
+Sessions House, in London, by a representative of the London Globe and
+was delivered to the Council of Middlesex county for preservation.
+
+[39] It is reported that the wily Ben really bribed the jailer to use
+cold steel in branding him, as no marks were found on his hand after his
+death. (London Globe, April, 1910.)
+
+[40] American Commonwealth, Massachusetts; Knapp’s “Sketches of Eminent
+Lawyers,” etc.
+
+[41] 2 Cranch, C. C. 137.
+
+[42] 4 Cranch, C. C. 118.
+
+[43] State vs. Gray, 5 No. Car. (1 Murph.) 147.
+
+[44] 11 No. Car. 4 Hawks. 187. And see, also, State vs. Kearney, 8 No.
+Car. 1 Hawks. 53.
+
+[45] State vs. Bosse, 8 Rich. Law. 276.
+
+[46] 24 No. Car. 2 Ired. 257.
+
+[47] Suab. 372.
+
+[48] State vs. Bosse, 8 Rich. Law. 276.
+
+[49] Fuller vs. State. 1 Blatchf. 63; State vs. Bilansky, 3 Minn. 246; 1
+Gil. 169.
+
+[50] Commonwealth vs. Posey, 4 Coll. 109; 2 Am. Dec. 560.
+
+[51] Commonwealth vs. Stewart, 1 Va. Cas. 114.
+
+[52] American Com. Ky. p. 407. Ch. 21.
+
+That Thackeray was thoroughly familiar with the law governing the Benefit
+of Clergy and the nature of the punishment inflicted on the culprit
+pleading guilty of an offense clergyable at common law, is evidenced by
+his presentation of the plea in favor of Lord Mohun, the Earl of Warwick,
+Col. Westbury and Henry Esmond, in his interesting plot, in “Henry
+Esmond.”
+
+
+
+
+CHAPTER IX.
+
+PRIVILEGE OF SANCTUARY.
+
+
+The privilege of sanctuary, sometimes called the privilege of asylum, was
+the exemption afforded criminals, taking refuge in certain consecrated
+places, from the ordinary operation of the law of arrest.
+
+The institution is no doubt older than the time of Moses and we find
+frequent references to it in the early books of the Bible.
+
+In the book of Exodus the old Mosaic law was stated to be: “He that
+smiteth a man, so that he die, shall be surely put to death,” but in the
+same book, it is written: “And if a man lie not in wait, but God deliver
+him into his hand; then I will appoint thee a place whither he shall
+flee.”
+
+Moses’ law thus distinguished between murder on malice aforethought and
+mere manslaughter, as we call it and according to the ancient law of the
+Israelites, there were cities of refuge to which a felon might flee, who
+killed a man unawares.
+
+Moses appointed six cities of refuge, three “on this side of Jordan”
+and three “in the land of Canaan,” in order that the slayer might flee
+thither which should kill his neighbour unawares, and hated him not in
+times past; and that fleeing to one of these cities, he might live.[1]
+
+Deuteronomy refers to the case of “the slayer which shall flee thither
+that he may live”; distinguishing the man who lies in wait, from the
+man who “killeth his neighbour innocently, whom he hated not in times
+past.”[2]
+
+In the book of Joshua it is provided that “When he that doth flee to one
+of those cities shall stand at the entering of the gate of the city, and
+shall declare his cause in the ears of the elders of that city, they
+shall take him into the city unto them and give him a place, that he may
+dwell among them. And if the avenger of blood pursue after him, then
+they shall not deliver the slayer up into his hand; because he smote his
+neighbour unwittingly and hated him not beforetime.”[3]
+
+Over a thousand years before Christ we find Adonijah claiming the
+privilege of sanctuary to protect him from the wrath of Solomon, for it
+is recorded in the first book of Kings:[4]
+
+ “And Adonijah feared because of Solomon, and arose, and went
+ and caught hold on the horns of the altar. And it was told
+ Solomon, saying, Behold, Adonijah feareth king Solomon, for,
+ lo, he hath caught hold on the horns of the altar, saying:
+ Let king Solomon swear unto me today that he will not slay
+ his servant with the sword. And Solomon said: If he will shew
+ himself a worthy man, there shall not an hair of him fall to
+ the earth; but if wickedness shall be found in him, he shall
+ die.”
+
+This case of Adonijah taking refuge in the temple, at the altar, as a
+protection against the supposed wrath of Solomon, is nothing more nor
+less than a claim of sanctuary, for even the hand of Solomon was stayed
+at the threshold of such a consecrated place and the sinner taking refuge
+at the altar was supposed to be surrounded by the protecting mantle of
+the Great Jehovah. This is only one of many thousand similar concrete
+cases that could be mentioned, no doubt, if the unwritten history of the
+unnoticed millions of patriarchial days could be known, for the right
+of sanctuary obtained generally in those ancient days. The ever-flowing
+flood of time has swept away all records of the ordinary mortals,
+however, and only the great peer out through the darkness of the past.
+
+The conditions upon which sanctuary was bestowed, in the ancient days
+of the patriarchs was that the refugee should not quit the city of
+refuge until the death of the High Priest, for on this solemn occasion,
+the great public grief was supposed to over-shadow all merely private
+affairs. As recorded in the book of Joshua, one claiming sanctuary must
+stand at the gate of the city and “declare his cause in the ears of the
+elders”[5]; the elders tried his case, to ascertain if he were guilty
+of malicious murder, or mere manslaughter, and if the case of murder
+was established by the “avenger of blood,” who acted as prosecutor, the
+criminal was given up, even though he clung to the altar,[6] but if the
+elders found that he was not guilty of wilful murder, he was retained
+as “a prisoner at large” in the city of refuge, until the demise of the
+High Priest, when he was allowed to return to his home, duly purged of
+the crime for which he had fled. If he departed from the “city of refuge”
+before the death of the High Priest, however, he was regarded as an
+outlaw and could be slain by any man, as such.[7]
+
+According to Plutarch and Dr. Pegge, the right of sanctuary was
+recognized among the ancient Greeks and the Oratory of Theseus was one of
+the places of refuge for persons of lowly station, who fled to avoid the
+oppression of the great and powerful “avengers of blood.” The privilege
+afforded these lowly ones soon became a license for the protection of
+criminals, however, and the most notorious criminals were protected from
+the civil authorities and the holy places and temples came to be used as
+asylums and resorts for the most notorious criminals.[8]
+
+From Greece, the right of sanctuary spread to Rome, and although, by the
+Roman law, murderers, escaped slaves, robbers, and public debtors were
+excluded from sanctuary privileges,[9] in the course of time, the priests
+refused to deliver up the slaves to their masters, the debtors to their
+creditors, or the murderers to the magistrates, and the temples and
+churches became regular dens for thieves, murderers and criminals of the
+worst kind.[10]
+
+Long after the civilizations of the ancient Jews and Grecians had passed
+away, the privilege of sanctuary, which they recognized, was perpetuated
+in various forms, and in most of the later civilizations we find
+evidences of similar customs obtaining.
+
+Before the privilege of sanctuary was guaranteed by written statute law,
+the right was recognized by the general usage of the Christian church,
+in accordance with the early Mosaic law and in all the countries whose
+civilization borrowed from the ancient Israelites, there is evidence of
+such a custom.
+
+The Emperor Constantine, as early as the year 324 caused laws to be
+enacted, extending and recognizing the privilege of sanctuary; Theodosus,
+in the year 392, made a law regulating the exemption to criminals of his
+day and Theodosus II. extended the freedom of sanctuary, from the altar
+and body of the church itself, to which it was previously confined, to
+all the buildings and places contained within the outer walls of the
+consecrated places, set apart for purposes of sanctuary.[11]
+
+Although the fact is not established by competent authority, it has been
+stated that the privilege of sanctuary obtained in England, as early as
+the close of the second century after Christ.[12] The right may have been
+recognized as early as this date, but the history of the period does not
+give us any very authentic record to sustain that it did. Soon after the
+conversion of the Saxons to Christianity, however, all places of public
+worship were looked upon as so consecrated that criminals taking refuge
+in any of them were temporarily protected from the process of the civil
+authorities.[13]
+
+Unlike the ancient Jews, the early Saxons received even the felons
+guilty of wilful murder, for a period of thirty days, if they paid
+the _Wehrgeld_, fixed by the officers of the church, according to
+the standing of the person killed; he was protected from the civil
+authorities for a period of thirty days, on payment of the _Wehrgeld_,
+if he provided his own sustenance, after which he was delivered to his
+friends.[14]
+
+As sanctuary was only extended to those, under the Mosaic law, who
+“declared their cause in the ears of the elders of the city,” so, under
+the Anglo-Saxon law, the criminal claiming sanctuary was required to
+confess his crime and declare that he sought the safety of the church to
+preserve his life.[15]
+
+Under the old Saxon law, however, the privilege was not extended for
+a longer period than forty days and at the end of that time, if the
+prisoner did not _abjure the realm_, he was delivered to his friends, or
+to the civil authorities. Under the practice known as _abjuration of the
+realm_ if the sanctuary felon, within forty days after taking sanctuary,
+went, in sackcloth, before the coroner and confessed his guilt and took
+an oath to quit the realm and not to return, without the king’s license,
+he was then attainted of the felony, but was given an additional period
+of forty days to prepare for his journey and to keep the privilege
+alive, he was compelled, within this period, to repair, with a cross in
+his hand, as an indicia of his crime, but an emblem of the protection
+afforded him by the church, to the port assigned him, and to there take
+his journey for some foreign shore.[16]
+
+Large numbers of the English felons, at an early day, by this practice
+known as _abjuration of the realm_, were induced to leave England and
+annually many such “undesirable citizens” took passage from Dover,
+to France or Flanders, under the threat of delivery to the civil
+authorities, to answer for their crime, if they did not voluntarily
+assume this perpetual banishment and suffer the forfeiture of their
+estate to the crown.[17]
+
+After _abjuration of the realm_, if the prisoner afterwards returned to
+England, without the license of the king, so to do, he was regarded as
+an outlaw and, when caught, was condemned to be hanged, unless he was a
+clerk, in which event, he was allowed to claim the _benefit of clergy_,
+and to be discharged, after the usual preliminaries and the punishment
+inflicted upon those claiming clergy for such a crime as the sanctuary
+criminal had committed.[18]
+
+During the period of the forty days, while the criminal was enjoying
+his privilege of sanctuary, the _villata_ where the crime was committed
+was required to watch the sanctuary, to prevent his escape, without
+_abjuration of the realm_; if the coroner did not come for the period of
+forty days, the township was required to watch the church for this full
+period and if the criminal escaped, because of the failure to do so, the
+township was amerced accordingly.[19]
+
+The privilege of sanctuary was recognized by the code of Ina, King of
+West Saxony, in 693, and the fifth section of the code provides that if a
+felon, who had been convicted of a capital offense fled to a church, or
+sanctuary, his life should be spared and if any criminal adjudged to be
+flogged, sought refuge in such consecrated place, the stripes, that he
+would otherwise receive, should be withheld from him.[20]
+
+In the year 887, under a statute of Alfred the Great, the privilege
+of three nights was allowed the criminal seeking the protection of
+the church, to enable him to prepare for his safety, and by this same
+provision of the law, if anyone violated the privilege of sanctuary,
+during the period named, by inflicting blows, wounds, or bonds, upon the
+sanctuary criminal, he was obliged to pay the sum of One hundred and
+twenty shillings to the ministers of the church, whose precincts had
+been invaded.[21]
+
+The Mirror of Justice, reports that King Alfred caused a judge to
+be hanged, who had invaded the jurisdiction of the holy orders and
+removed, by civil process, a criminal who had sought the protection of
+sanctuary[22] and it is certain that the right was not only safe-guarded
+by the law, in the time of Alfred, but that Ethelred and all subsequent
+Saxon kings expressly sanctioned the privilege.[23]
+
+With the advent of William the Conqueror, the law of sanctuary, with the
+other Saxon laws that he did not repeal, became more fixed and definite,
+but the extent of the privilege was more or less varied, by the laws or
+practices of the different subsequent kings.
+
+After the conquest the practice obtained of erecting a stone seat,
+beside the altar and several of these seats were erected in the English
+churches, and criminals fleeing to these seats were protected by the
+peace of the church, _pax ecclesiae_, and guarded by all its sanctity. To
+violate the protection afforded by this seat, or of the shrine of relics,
+was an offense too grave to be compensated by the payment of a mere money
+fine. One of these seats of stone still remains at Beverly and another at
+Hexham.
+
+The privilege at Beverley was granted by Athelstan and extended for a
+radius of a mile around St. John’s as the center. The outward and next
+outer boundaries of this circle were designated by crosses of rich
+carving. The third boundary began at the entrance to the church and the
+sixth embraced the high altar and the “fridstool.”[24]
+
+In the four roads leading to the monastery of Hexham, in Northumberland,
+the boundary stones were rude crosses, around which, in Saxon characters
+and letters was the word “Sanctuarium,” which meant so much to the
+criminals of early times, seeking the protection of the “Chair of Peace.”
+
+The “fridstool” at Hexham has been carefully preserved and is much more
+extensive and handsome than that at Beverly, as it has interlaced Saxon
+and Norman ornaments on the top of the chair and a moulding extends below
+and around the seat.[25]
+
+At Durham, the privilege extended to the church, the churchyard and the
+circuit. All who came within this solemn circle were protected, for
+the church was supposed to throw around them its protecting arms and
+the penalties for intruding upon this “charmed circle,” increased in
+proportion as the degree of holiness was desecrated.[26]
+
+William the Conqueror granted the charter to St. Martin’s le Grand and
+by the charter the privilege extended not only to the church, but to the
+college of St. Martin and the precincts thereof.[27]
+
+Westminster, perhaps the most famous sanctuary in England, received its
+charters from two of the kings of the Heptarchy and Edward the Confessor
+attempted to forever establish it as one of the perpetual sanctuaries of
+England, for all classes of criminals, in the following broad grant:
+
+ “I order and establish, forever, that what person, of what
+ condition or estate soever he be, from whence soever he come,
+ or for what offence or cause it be, either for his refuge in
+ the said holy place, he be assured of his life, liberty and
+ limbs. And over this, I forbid, under the pain of everlasting
+ damnation, that no minister of mine, or of my successors,
+ intermeddle with any the goods, lands, or possessions of the
+ said persons taking the said sanctuary.... And whomsoever
+ presumes or doth contrary to this my graunt I will he lose
+ his name, worship, dignity and power and that with the great
+ traitor Judas, that betrayed our Saviour, he be in everlasting
+ fire of hell; and I will and ordain that this my graunt endure
+ as long as there remaineth in England, either love or dread of
+ Christian name.”[28]
+
+So essential was it then regarded to maintain, at all hazards, the _pax
+ecclesiae_, that the red handed murderer, even, when he once reached
+the sacred precincts of the church’s domain, was to be protected from
+the mere temporal powers of the earth, because he thus placed his faith
+in a higher law and the mundane officers of the law, for attempting
+to preserve the peace of the realm, if they transgressed upon the
+sacred soil consecrated to the Lord and used also for the protection of
+criminals, were classed along with traitors to the Lord and a dire curse
+proclaimed against them. It is well for the race that such delusions have
+passed away, along with the delusions of witchcraft and other fanaticisms
+of that age.
+
+The Whitefriars, or Alsatia, an establishment of the Carmelites, was
+founded by Sir Patrick Grey, in the year 1241, upon a plot of ground,
+granted by Edward I., on Fleet street, located between what is now
+Salisbury street and the Temple, and Fleet street and the river
+Thames.[29]
+
+According to the law, as it finally developed, if a man fled to any one
+of the many sanctuaries, _chartered by the Crown_, and claimed protection
+from the civil authorities for a crime he had committed, regardless of
+the enormity of his crime, he could remain there undisturbed, for life
+and was not obliged to make his _abjuration of the realm_, as he was
+required to do in case the asylum was not such a chartered institution.
+Many of these chartered asylums were established, and aside from those
+mentioned, there were sanctuaries so chartered at Wells, Norwich, York,
+Manchester, Derby, Lancaster and Northampton.[30]
+
+In the absence of a special charter, however, the crime of treason was
+not a sanctuary crime and traitors were not protected, even though they
+sought the portals of such consecrated places.[31]
+
+During the reign of Edward I., about the year 1262, the Abbot of
+Westminster attempted to extend the privilege of sanctuary, to those
+guilty of treason, to debtors and other classes of criminals than those
+who had formerly enjoyed the right and he also contended that the civil
+officers were not allowed, under the conditions of the charter of that
+institution, to enter upon any places, however remote, that belonged to
+the abbey. A law suit resulted and notwithstanding the broad terms of the
+charter above quoted, it was decided by all the justices that sanctuary
+was confined to felons alone and that the sheriffs of London had a right
+to enter the town of Westminster and to proceed to the very gates of the
+abbey and to enter the houses of the abbey elsewhere in the county, to
+arrest felons.[32]
+
+The class of criminals who sought protection under the right of
+sanctuary, included the whole gamut of crimes known to English law,
+murder or homicide, debt, horse and cattle stealing, housebreaking,
+or burglary, escaping from prison, rape, harbouring a thief, treason,
+receiving stolen goods, counterfeiting, larceny and the other crimes
+common in the realm and made so by statute, or existing at common law.
+
+During the reign of Henry VII., it was decreed that when an offender fled
+to sanctuary, it was not enough for him to declare that he came there to
+save his life, but he must add that he had committed a felony; though
+he need not specify the felony, before the coroner came.[33] But if he
+failed to make such a general declaration, he could be dragged from the
+sanctuary and was not exempt from civil process.[34]
+
+The system whereby the felon fled to sanctuary and was accorded the
+privilege is described in the literature of the period descriptive of the
+manner of enjoying this right.
+
+A knocker was usually provided at the outer door of the abbey and one or
+two janitors roomed above the door, to admit such nocturnal visitors as
+called at different hours to claim their sanctuary. After the refugee was
+admitted to the sanctuary, the Galilee Bell was tolled, to announce to
+the outer world that another sanctuary criminal had been admitted. A gown
+of black cloth, with a yellow cross, was given to the culprit to wear and
+he was disarmed and assigned to his quarters.[35]
+
+The oath administered to the refugee has been preserved by the Harleian
+Manuscripts[36] and a form of confession and abjuration, administered by
+Sir William Rastall, Chief Justice of the Court of Common Pleas during
+the reign of Queen Mary, has been handed down to us.[37]
+
+While the right was held not to extend to cases of treason, generally,
+in different reigns, we find that it was extended to include treason, as
+well as the lesser felonies.
+
+Henry IV. wrote a letter to Cardinal Langley, which is preserved in the
+Treasury,[38] wherein that monarch respected the privilege of sanctuary,
+even in a case of treason, and asked the protection of St. Cuthbert for
+the person of Robert Marshall, “late comitted to prison for treason, now
+escaped and broken into the same into youre church of Duresme; we having
+tender zele and devocion to the honour of God and St. Cuthbert, ... wol
+that for that occasion nothyng be attempted that shal be contrarie to the
+liberties and immunitie of our church. We therefor wol and charge you
+that he be surely kept there, as ye wol answere unto us for him.—Yeven
+under our signet at our towne of Stanford, the xxvii day of July.”
+
+There was flagrant breach of the ancient privilege of sanctuary,
+in England, in 1378, in the case of Sir Robert Haule and Sir John
+Shackle. Having escaped from the Tower, these gentlemen took refuge in
+Westminster. Boxhall, the constable of the Tower, with fifty armed men
+pursued them and although the celebration of mass was in progress, when
+they entered the abbey, they pursued the prisoners and although Sir John
+Shackle escaped, they killed Sir Robert Haule, by hacking him, with their
+swords, while he ran around the choir, until he fell dead, with twelve
+serious wounds, near the prior’s cell.[39]
+
+Owen Tudor, the father of Henry VII. took refuge at Westminster and Queen
+Elizabeth, the widow of Edward IV., with her son, also took sanctuary
+there to escape the ferocity of her inhuman brother-in-law, Richard III.
+
+Sir Thomas More gives a graphic account of the sanctuary of Elizabeth:
+
+ “Therefore now she (Queen Elizabeth Woodville) toke her younger
+ sonne the Duke of Yorke and her daughters, and went out of the
+ Palays of Westminster, into the Sanctuary and there lodged in
+ the Abbote’s Hac and she and all her children and campaignie
+ were registered for Sanctuary persons. Whereupon, the Bishop
+ (Lord Chancellor Rotheram, Archbishop of Yorke) called up all
+ his servants and took with him the great seal and came before
+ day to the Queen, about whom he found much heavyness, rumble,
+ haste, businesse, conveighaunce, and carriage of her stuffe
+ into Sanctuary. Every man was busy to carry, bear, conveigh,
+ stuffe, chestes, and fardelles, no man was unoccupied, and some
+ carried more than they were commanded to another place. The
+ Queene sat belowe on the rushes, all desolate and dismayed.”[40]
+
+A pathetic picture, of this poor widowed Queen, sitting all alone,
+amid the green rushes, a refugee from the ferocity of her wolfish
+brother-in-law. One devoid of chivalry and possessing only common human
+instincts of pity would have offered protection to a lady in such sad
+plight, but history does not record it of “Crookbacked Richard,” for he
+determined early to prove a villain and, to clothe his naked villany
+“with old odd ends stol’n forth of holy writ”; he seemed a saint, when
+most he played the devil and was not only devoid of pity for others, but
+found, in himself, no pity for himself.[41]
+
+An instance of the temporary violation of the royal charter privileges
+granted to St. Martin’s le Grand, occurred in September, 1442, when
+an officer was conducting a prisoner from Newgate to Guildhall. When
+they reached Panyer Alley five of the prisoner’s friends rushed out
+and rescued him from the officer and took him to St. Martin’s claiming
+sanctuary. The sheriffs of London went to the Church and not only took
+the prisoner, but all five of his friends, with chains round their necks
+to Newgate. The matter was brought before the King’s Star Chamber, by the
+Dean and Chapter of St. Martin’s le Grand and the claim advanced that
+the ancient charter privileges of the Church had been violated by the
+Sheriffs and the King ordered the men to be sent back to St. Martin’s
+“there to abide freely, as in a place having franchises, whiles them
+liked.”[42]
+
+During the reign of Henry VII., the interesting case of Humphrey Stafford,
+was decided, wherein the right of sanctuary, in treason, was expressly
+denied. Stafford had been attainted of treason and claimed sanctuary but
+was taken from the sanctuary and imprisoned in the Tower. When brought to
+the Bar of the King’s Bench, he pleaded his right of sanctuary, but after
+solemn discussion and reflection, the judges gave a unanimous decision
+that treason was such an exalted crime against the prerogatives of the
+King, that it could not be included within the crimes for which sanctuary
+would be allowed, and they disregarded the ancient charters to the
+contrary and gave judgment that Stafford should be executed.[43]
+
+It was attempted to have this holding reviewed the year following the
+decision, when the Abbot of Abingdon appeared before the judges and
+produced his ancient charters, upon which he claimed his privileges were
+founded and the whole issue was gone into in exchequer chamber, before
+the judges. The Abbot claimed that the judges should confer with the
+prelates before pronouncing judgment, but one of the judges replied that:
+
+ “There can be no franchise without grant from the king. For the
+ king can grant that any person who enters such a place, having
+ committed treason, shall not be taken therefrom. And this shows
+ that it can be done without the assent of Pope or Bishop, and
+ that the Pope cannot do it within this realm. For to pardon or
+ dispense with treason, pertains exclusively to the king. And
+ a place of safety, is as a _privilege_, not as sanctuary. But
+ when the Pope has consecrated the place, then it is sanctuary,
+ not before.... But the principle of protection arises by our
+ law, of which the cognizance belongs to us.”
+
+And this view obtaining, the Abbot was denied his suit and it was
+finally held that no right of sanctuary existed in case of a charge of
+treason.[44]
+
+Illustrating the growing tendency to limit the privilege of sanctuary
+during the reign of Henry VII., another significant case, will not be
+studied in vain. Two felons were taken out of sanctuary, at Southwark
+and when arraigned for their crimes before Sir Thomas Frowike, Chief
+Justice, they pleaded their sanctuary and prayed to be restored. They
+were commanded to plead to the felonies with which they were charged,
+on the merits, but refused, claiming that as they were wrongfully taken
+out of sanctuary they were bound to plead to the indictment; the court,
+however, found that they had not been taken out of sanctuary and then,
+without arraigning them again, ordered that they be subjected to the
+terrible _peine forte et dure_, for standing mute and refusing to plead.
+So final judgment was entered, notwithstanding their right to sanctuary,
+that they be taken to the jail, from whence they came, and laid upon the
+bare ground, and that so much weight be laid upon them as they could
+suffer and more, and that they should have nothing to eat but bread and
+water; and that so they should be kept, continually, until they died.[45]
+
+As indicative of the cruelty and barbarism then obtaining, this judgment
+is an important index and that such a judgment should have been rendered
+against men claiming the privilege of sanctuary, was not only contrary
+to the law of _peine forte et dure_, which punishment was only assessed
+upon those standing mute and refusing to plead at all, and not to those
+claiming an exemption given them by such a well settled custom approved
+by the laws and decisions of the courts for many centuries, but it was
+certainly contrary to the spirit and intent of the law and condemns the
+judges pronouncing such a harsh judgment, even unto this late day.
+
+In Scotland, by the ancient canons of the Scottish Councils, much more
+sacredness was attached to the plea of sanctuary, than obtained during
+this period of English history. Excommunication was there incurred
+for the offense of taking criminals from sanctuaries and depriving
+them of the protection of the church. Scottish kings granted charters
+recognizing broader privileges in certain churches than in others, and
+many particular ecclesiastical asylums were established in Scotland, by
+special charters.
+
+One of the most celebrated sanctuaries in Scotland was the church of
+Wedale, now called Stow, for in this church there was an image of
+the blessed Virgin, believed to have been brought by King Arthur,
+from Jerusalem. David I., of Scotland, granted the “king’s peace,” in
+addition to the church’s protection, to those refugees taking sanctuary
+at the church of Lesmahagow, and it was, for centuries, one of the most
+prominent sanctuaries of Scotland.
+
+One of the most remarkable features of the custom of sanctuary, obtaining
+in Scotland, was that of the _Clan Macduff_, alleged to have been granted
+by Malcolm Canmore, on recovering the throne of his ancestors. Any person
+related within the ninth degree to the Chief of the Clan Macduff, who
+committed manslaughter, was entitled, when he fled to Macduff’s cross,
+in Fife, to have his punishment remitted to a fine, or at least to be
+repledged and exempted from trial in any other jurisdiction, by the Earl
+of Fife. History records that this privilege of sanctuary, saved the life
+of Hugh de Arbuthnot and his accomplices, from trial for the murder of
+John de Melvil of Glenbervie, in the year 1421.
+
+The Scotch law of sanctuary was more guarded than the English, in the
+middle ages, in affording too easy an immunity for crime, but in this
+country, there existed in most recent times, a sanctuary for debtors in
+the abbey and palace of Holyrood, with its precincts, including the hill
+of Arthur’s Seat and the Queen’s Park.[46]
+
+The privilege of sanctuary, while it obtained in England and Scotland
+gave rise to considerable legislation and litigation, to restrain the
+right within the proper limits and to interpret the laws governing the
+privilege as it had previously been enjoyed.
+
+In 1378 it was ordained that debtors claiming sanctuary with the intent
+of defrauding their creditors should have their goods and lands levied
+upon to discharge their debts.[47]
+
+In 1487 Pope Innocent VIII. authorized the arrest of persons who left the
+sanctuary, to commit murder, robbery or other felony, though they sought
+the sanctuary, the second time, for protection and he ordered at the same
+time that those inmates of sanctuaries who were guilty of treason should
+be prevented from leaving the realm.[48]
+
+Statutes of the time of Henry VIII. greatly curtailed the privilege of
+sanctuary. By act of Parliament, passed in the twenty-first year of his
+reign,[49] it was provided that the culprit:
+
+ “Immediately after his confession, and before his abjuration,
+ was to be branded by the coroner with a hot iron upon the brawn
+ of the thumb of the right hand, with the sign of the letter A,
+ to the intent he might be the better known among the king’s
+ subjects to have abjured.”
+
+It was found that the citizenship of the realm was becoming weakened
+by sanctuary men _abjuring the realm_, so Henry VIII., by statute
+provided,[50] That
+
+ “every person abjuring was to repair to some sanctuary within
+ the reign which himself should choose, and there remain during
+ his natural life; and to be sworn before the coroner upon his
+ abjuration so to do. But if he went out of that sanctuary,
+ unless discharged by the king’s pardon, and committed murder or
+ felony, he was liable to be brought to trial for that offense,
+ and was excluded from the right of sanctuary.”
+
+In the twenty-sixth year of the reign of this monarch, sanctuary was
+taken away where the crime was treason,[51] and in the thirty-second
+year of his reign it was enacted that “all sanctuary persons were to
+wear a badge or cognisance to be assigned and appointed by the governour
+of every sanctuary, openly upon their outer garment, of the compass,
+in length and breadth of ten inches under the pain of forfeiting the
+privilege of sanctuary.” They were also prevented from carrying knives
+or swords or other weapons and were not to leave their lodging except
+between sunrise and sunset, and the right of sanctuary was also confined,
+by Henry VIII., to parish churches, churchyards, cathedrals, hospitals
+and college churches and all dedicated chapels.
+
+One of the first acts of James I., when he began to rule over England,
+was to further abridge the right of sanctuary and twenty years afterward
+in 1624, the same monarch finally abolished the right of sanctuary for
+all kinds of crime, in England.[52]
+
+Various precincts continued to afford shelter for criminals, in and
+about London, however, long after the enactment of this statute of James
+I., intended to finally abolish the practice and it was not until the
+later act of 1697 that the custom was finally abrogated for good, in
+England.[53]
+
+Both while the practice of sanctuary obtained and years after it passed
+away, however, the institution furnished a theme for popular authors to
+weave romances around and Shakespeare, Shadwell, Sir Walter Scott, and
+other writers, whose names commence with other letters of the alphabet,
+have found the ancient law of sanctuary, an attractive source of legal
+reference.
+
+In describing the argument before the Council, as to the right of Queen
+Elizabeth, the widow of Edward IV. and her son, to claim sanctuary, when
+they had committed no crimes and the son had done nothing to entitle him
+to sanctuary, Shakespeare makes Buckingham say, in Richard III.:
+
+ “_Buck._ ... You break not sanctuary in seizing him.
+ The benefit thereof is always granted
+ To those whose dealings have deserv’d the place,
+ And those who have the wit to claim the place;
+ This prince hath neither claimed it, nor deserv’d it;
+ And therefore, in mine opinion, cannot have it;
+ Then, taking him from thence, that is not there,
+ You break no privilege nor charter there.
+ Oft have I heard of sanctuary men;
+ But sanctuary children, ne’er till now.”[54]
+
+Cardinal Wolsey sought the benefit of sanctuary, after his disgrace, at
+the Abbey of Leicester, in King Henry VIII., in the following touching
+plea:[55]
+
+ “O father Abbot, an old man, broken with the storms of State,
+ Is come to lay his weary bones among ye; Give him a little
+ earth, for charity.”
+
+The poor, desolate widow of Edward IV., after the death of her husband,
+whose plea of sanctuary we have already described, is thus made to
+reflect upon the protection in sanctuary, in 3’ Henry VI.:
+
+ “_Queen Elizab._ I’ll hence, forthwith, unto the sanctuary,
+ To save at least the heir of Edward’s right.
+ There shall I rest secure from force and fraud.”[56]
+
+And in Coriolanus, as if realizing that sanctuary was an institution that
+had out lived its usefulness, Shakespeare thus refers to it as a “rotten
+privilege”; when Aufidius is made to say:
+
+ “_Auf._ ... nor sleep nor sanctuary, being naked, sick; nor fane nor
+ capital;
+ The prayers of priests, nor times of sacrifice,
+ Embarquements all of fury, shall lift up
+ Their rotten privilege and custom ’gainst
+ My hate to Marcius.”[57]
+
+Already the trend of public thought was against the custom which afforded
+exemption to the criminal seeking refuge in the sacred places of the
+kingdom, and the ancient law of sanctuary, since the reign of Henry
+VII. had been gradually amended and so many different limitations were
+imposed upon the ancient privilege during the reign of Henry VIII., that
+the public were about ready for the final repeal of the law, by King
+James, so the gifted Shakespeare, ever alive to the popular views of his
+audiences, in referring to sanctuary, in Coriolanus, speaks of it as a
+“rotten privilege” that could not stay the hatred of Aufidius for Marcius.
+
+This old institution has passed away forever, in the ever flowing flood
+of time, carried away by the current of the centuries. The necessity
+for such a custom has long ceased to exist, but in the dim past, when
+the “avenger of blood” was abroad in the land and men, fed upon the
+delusions that were rampant, clamored, like wolves, for the life blood
+of the criminal, the old knockers on the sanctuary doors were most
+welcome sights to the fearful criminal, pursued by the howling mob. In
+our imagination we can see the cringing murderer, bent and fearful, as
+he hurries through the black browed night, followed by his blood-thirsty
+pursuers, like a hunted stag, fleeing for the blessed portals of the
+sacred places. What a sigh of relief he must have felt, when he reached
+the ancient altar of some of the old sanctuaries of the middle ages and
+with what exultation his heart must have throbbed, as he clung to the
+ancient “frith-stool” that for untold centuries had afforded protection
+to criminals from the vengeance of the pursuer.
+
+This obsolete custom of the inhabitants of the lost world of the past
+had for its recommendation the charitable and philanthropic object of
+saving men from the many “crimes against criminals,” then obtaining. Many
+instances, no doubt, existed, where the practice was used to prevent the
+civil authorities from enforcing the law and it was used as an instrument
+whereby “crimes went unwhipt by justice.” But in the harsh days when
+the extremes, in that regard, prevailed, it is as well that Mercy was
+thus used to temper Justice, and, upon the beneficent theory that “it is
+better for a thousand guilty men to go free than for one innocent man to
+suffer,” it was an institution accompanied with most benevolent results.
+
+The hands of the officers of the law were held up when they came to the
+charmed portals of the sacred sanctuary. The old Mosaic law and the time
+honored charters of the Crown decreed it. And while the officer was thus
+thwarted and Justice cheated, the “boys of Westminster Knoll”; “the birds
+of St. Martin’s”; the “Bravoes of Alsatia” and “Freemen of the Borough,”
+flourished and lived. Many of them, perhaps, belonged to the large class
+of the “predestined lost” and if their inner lives had been scanned,
+there were no doubt mitigating circumstances why they happened to be
+as they were. It may have been decreed, from the beginning that they
+should be criminals, instead of honest men. However this may be, they
+contributed to the quota of the crime of the world and with the right and
+wrong then obtaining, have past away forever. Let us be thankful that as
+many of them as did successfully embrace the privileges of sanctuary were
+spared through this merciful custom, for, in the end, it will make no
+difference whether this or that criminal suffered death just at this or
+that particular time, or a little later. He paid the penalty of the flesh
+certainly, without much delay and that he was allowed to consort with
+holy men, free from the war of the outside world, and feel the influence
+of their altruism for a time, and listen to the service of the sacred
+altar, with its superstitious chant, could but have had a softening and
+leavening influence upon his life.
+
+So while inconsistent with a proper administration of justice, which
+contemplates the visitation of equal punishment upon all alike, under
+similar conditions, for the same crimes, amid the rapine and murder
+of the middle ages it was often a shield for innocence, as well as a
+protection for crime and we can hardly regret that there was such an
+oasis in the desert, where the persecuted could find rest from the wild
+beasts of the desert domains—“wilder than wildest wolf or bear.” They all
+have gone, who suffered then—gone, “with the snows of yesterday”—the way
+the Mammoth went his way. So whether it was good or ill, since sanctuary
+gave to those who lived and suffered here below, “one little glimpse
+of Paradise, to ope the eyes and ears of men,” we would not have it
+otherwise.
+
+
+FOOTNOTES:
+
+[1] The six cities appointed in the book of Numbers were only for those
+who “killeth any person unawares.” (xxxv.)
+
+[2] Chapter XIX. 4.
+
+[3] Joshua, XX. 4, 5.
+
+“These were the cities appointed for all the children of Israel, and
+for the avenger that sojourneth among them, that whomsoever killeth any
+person unawares, might flee thither, and not die by the hand of the
+avenger of blood, until he stood before the congregation.” _idem._ 9.
+
+[4] Chapter I., 50, 52.
+
+[5] Joshua, XX., 4, 5.
+
+[6] I. Kings, 1, 50, 51.
+
+Nimrod, on the death of his eldest son, erected a golden statue of him
+in his palace and ordained that all criminals fleeing thither should be
+protected and this was a species of sanctuary. The Green Bag, vol. VIII.,
+1896, p. 422.
+
+[7] Chambers Journal, vol. 44, Jan.-June, 1867, p. 170.
+
+[8] The Green Bag, vol. 8, 1896, p. 423.
+
+[9] Chambers Journal, vol. 64, p. 513.
+
+[10] Plutarch, Dr. Pegge; Green Bag, vol. 8, 1896, p. 423.
+
+[11] Chambers Journal, vol. 64, p. 513. Papal sanction was expressly
+given in the year 620. _ante idem._
+
+[12] Chambers Journal, Vol. 64, August, 1887, p. 512.
+
+[13] Chambers Journal, Vol. 44, June, 1867, p. 170.
+
+[14] _Ante idem._
+
+[15] I. Reeve’s History English Law, p. 198.
+
+Reeves shows that at this early day the _pax ecclesiae_ was more sacred,
+before the law, than the _pax regis_, _ante idem._
+
+[16] Reville, L’Abjuratio regni, Revue historique, vol. 50, p. 1;
+M. Reville contends that the law of abjuration is purely an English
+institution and was adopted by the Normans, from the early Anglo-Saxons.
+See Pl. Cr. pi. 48, 49, 89; Britton, i, 63; Leg. Edw. Conf. c, 5.
+
+[17] II. Pollock and Maitland’s History English Law, p. 590.
+
+[18] _Ante idem._
+
+Speaking of the practice known as _adjuration of the realm_, Pollock and
+Maitland, in their excellent history of English Law, say: “The coroner
+came and parleyed with the refugee, who had his choice between submitting
+to trial and abjuring the realm. If he chose the latter course, he
+hurried, dressed in pilgrim’s guise, to the port that was assigned to
+him, and left England, being bound by his oath, never to return. His
+lands escheated; his chattels were forfeited, and if he ever came back,
+his fate was that of an outlaw.” (Vol. II., p. 590.)
+
+[19] I. Pollock and Maitland’s History English Law, pp. 565, 566; R. H.
+1, 308; Maddox, Hist. Exch. i, 541, 568.
+
+[20] Chamber’s Journal, Vol. 64, 1887, p. 513; Green Bag, vol. 8, p. 423.
+
+[21] _Ante idem._ I. Reeve’s History English Law, p. 198.
+
+[22] Mirror of Justice, c. 5.
+
+[23] I. Reeve’s History English Law, pp. 198, 199, note, Finlason’s
+edition.
+
+[24] This term is composed of the words “frith” and “stol,” meaning “the
+seat of peace.” It was a heavy stone chair, or seat and that at Beverly
+was devoid of decoration, but perfectly plain, in every particular. It
+has been broken and repaired with clamps of iron and we are informed that
+it formerly bore a Latin inscription, which stated that: “This stone
+chair is called Fridstool—that is, the Chair of Peace, to which what
+criminal soever flies to it hath full protection.” Chamber’s Journal,
+Vol. 64, 1887, p. 513.
+
+Littell’s Living Age, of July-Sept., 1907, Vol. 254, p. 700, produces a
+transcript of the register at Beverley, when one John Spret was entered
+as a sanctuary criminal, as follows: “John Spret, gentleman. Memorandum.
+That John Spret, of Barton, upon Umber, in the counte of Lyncoln, com to
+Beverlay, the first day of October, the vii year of the reen of Keing
+Henry the VII., and asked the lybertes of Saint John of Beverlay, for the
+death of John Welton, husbondman of the same town, and knawlig hymself to
+be at the kylling of the same John with a degart, the 15’ day of August.”
+And thus, this tragedy, which resulted in the death of husbandman John
+Welton, at the point of a dagger, in the hand of Mr. John Spret, has
+caused both of these gentlemen to be known in history after a period of
+many centuries, and this sad circumstance of their lives is quoted long
+centuries later, to illustrate the manner of an obsolete custom.
+
+[25] Chamber’s Journal, Vol. 64, p. 514.
+
+[26] Violators of the first and second boundary were punished by a fine
+of eight pounds; the third space by double that sum; and so on, but if
+a person penetrated into the charmed circle of the altar, no fine could
+save him, but he was regarded as a “botelas” man. _ante idem._
+
+[27] Chamber’s Journal, 1867, Vol. 44, p. 171.
+
+[28] _Ante idem._
+
+[29] Chamber’s Journal, Vol. 44, p. 171.
+
+[30] _Ante idem._
+
+[31] III. Reeve’s History English Law, p. 331.
+
+[32] 29 Ass. 34; II. Reeve’s History English Law, p. 81; Chamber’s
+Journal, Vol. 44, p. 171.
+
+Reeve says, speaking of the sanctuary at Westminster: “The resort of
+felons to this place, being in the metropolis of the kingdom, must have
+been very great and productive of great disorders.” _ante idem._
+
+The sanctuaries to which special charters had been granted, were known
+during the period of Henry VII., as private sanctuaries, while those that
+had not received special charters were called general sanctuaries and in
+distinguishing the two, a historian of that period has said:
+
+“If a man fled to such a sanctuary as Westminster Knoll, he might remain
+undisturbed for life; but if he chose to abjure within the forty days,
+the coroner was to appoint him a day to do it. The law of sanctuary is
+laid down in a reading of this period in the following manner: None shall
+take sanctuary but _in periculo vitae_, as for treason, felony, or the
+like and not for debt; for a grant or prescription to have sanctuary
+for debt was against law and void. But the reading lays down a strange
+quibble to evade this; for it admits, that if a man’s body was in
+execution, and he escaped, and came to a sanctuary, ordained as a refuge,
+and safeguard for a man’s life, he should have benefit thereof, _because
+by long imprisonment his life might be in jeopardy_. If a church was
+suspended for bloodshed, he who took it for sanctuary should still enjoy
+it for forty days and abjuration for felony, discharged all felonies done
+before the abjuration. A man could not abjure for petit larceny, however,
+but only for such felonies as induced the pain of death.” IV. Reeve’s
+History English Law, p. 255.
+
+[33] 3’ Henry VII., 12; IV. Reeve’s History English Law, 253.
+
+[34] _Ante idem._
+
+[35] Preface of Rev. James Raine’s to the Fifth Volume of the Surtees
+Society, gives the following description of the manner of claiming
+sanctuary at Beverley and Durham:
+
+“Persons who took refuge fled to the north door and knocked for
+admission.... As soon as anyone was so admitted the galilee bell was
+immediately tolled, to give notice that some one had taken sanctuary. The
+offender was required, before the shrine of the patron saint, and certain
+credible witnesses, to tell the nature of his offense, and to toll a
+bell, in token of his demanding the privilege of sanctuary.... Everyone
+who had the privilege of sanctuary was provided with a black gown and a
+yellow cross, called St. Cuthbert’s Cross, upon the left shoulder.... If
+one’s life was saved the third time, by the privilege of sanctuary, he
+became permanently a servant of the church.” Chamber’s Journal, Vol. 64,
+p. 514.
+
+[36] This is the oath administered by the Archbishop of York, at
+Beverley, as same is preserved in the register, according to the Harleian
+Manuscript: “Ye shal be trew and feythful to my Lord Archbishop of York,
+lord of this towne; to the Provost of the same; to the Chanons of this
+chirch, and all other ministers thereof. Also, ye shal here gude hert
+to the Baillie and Governors of this towne, to al burges and comyners
+of the same. Also, ye shal bere no poynted wapen, dagger, knyfe, nor
+no other wapen agenst the kyng’s pece. And ye shal be redy at all your
+power if there be any debate or stryf, or oder sotham case of fyre within
+the towne, to help to surcess it.... So help you God, and this holy
+Evangelistes.” Chamber’s Journal, Vol. 64, p. 514.
+
+[37] As reproduced, in Chamber’s Journal (Vol. 64, p. 514), this oath is
+as follows: “This hear thou, Sir Coroner, that I M of H. am a robber of
+sheep or of any other beast, or a murderer of one or mo, and a felon of
+our lord, the king of England; and because I have done many such evils
+or robberies, in his land, I abjure the land of our lord the king of
+England and I shall haste me toward the port of such a place which thou
+hast given me; and that I shall not go out of the highway; and if I do, I
+will that I be taken as a robber and a felon, of our lord the king; and
+that at such a place I will diligently seek for passage and that I will
+not tarry there but one flood and ebb, if I can have passage; and unless
+I can have it at such a place, I will go every day into the sea up to my
+knees, assaying to pass over; and unless I can do this within forty days,
+I will put myself again into the church as a robber and a felon of our
+lord the king; so God help me and his holy judgment.”
+
+[38] Chamber’s Journal, Vol. 64, p. 515.
+
+[39] The Green Bag, Vol. 8, p. 425. He was buried as a martyr, in the
+south transept of this abbey and was followed by Chaucer, a few years
+later, who was buried at his feet. _ante idem._
+
+[40] Littell’s Living Age, Vol. 254, July-Sept., 1907, 701.
+
+[41] Richard III., Act V., Scene III.
+
+[42] Chamber’s Journal, Vol. 44, p. 171.
+
+The debate at the Council Board, over the right to take refugees from the
+sanctuary, occasioned by Queen Elizabeth’s refuge to Westminster, is not
+without interest, in showing the views then obtaining on this custom.
+It was contended that no right of sanctuary existed, since no crime had
+been committed, as the right was only extended to criminals, in fear of
+their lives; that the little son had no right to sanctuary at all and
+that it was a flagrant abuse of the privilege for the Queen to claim it.
+Those who advocated roughly taking them away, were overcome by the mild
+persuasion urged by the Archbishop of York, who counseled that the child
+be obtained without force, if possible. See, Chamber’s Journal, Vol. 44,
+p. 171, Speed; Sir Thomas More.
+
+[43] Year Book, I. Henry VII., fol. 24; IV. Reeve’s History English Law,
+p. 253.
+
+[44] IV. Reeve’s History English Law, p. 254, Finlason’s note.
+
+This is one of the many instances of the struggle going on for centuries
+between the civil authority, in its attempt to narrow the right of
+sanctuary and the church, to enlarge or preserve it.
+
+[45] 21 Henry VII., Keilway, 70; IV. Reeve’s History English Law,
+Finlason’s note, p. 254.
+
+[46] Chamber’s Journal, Vol. 44, p. 170, 171; _idem._, Vol. 64, 515.
+
+Imprisonment for debt was abolished in Scotland, in 1880, and while the
+privilege still exists in form, at the places noted, in fact it has
+ceased to be a necessary legal exemption, since the repeal of this law.
+
+[47] Chamber’s Journal, Vol. 64, p. 515.
+
+[48] This bull was confirmed by Alexander VI., and Julius II., in 1493,
+and 1504. _ante idem._
+
+[49] 21 Henry VIII., c. 8.
+
+[50] 64 Chamber’s Journal, p. 515.
+
+[51] 26 Henry VIII.
+
+[52] 21 James I., c. 28.
+
+[53] 8 & 9 William IV., c. 26.
+
+[54] Richard III., Act III., Scene I. For discussion of this and other
+references in Shakespeare, to the Law of Sanctuary, see White’s “Law in
+Shakespeare,” Sec. 324, p. 354.
+
+[55] Act IV., Scene I.
+
+[56] 3’ Henry VI., Act IV., Scene IV.
+
+[57] Act I., Scene X.
+
+
+
+
+CHAPTER X.
+
+ANCIENT PUNISHMENTS.
+
+
+In the broader sense, punishment includes any pain or detriment suffered
+in consequence of wrong-doing, but as treated of in this chapter, it
+means the pain or other penalty imposed by an authority to which the
+offender is subject, for a crime or offense committed.
+
+The term punishment is properly restricted to the penalties imposed by
+competent authority, for violations of law; but as the subject of the
+following pages will bear evidence, it has been frequently imposed upon
+the weak and the innocent, as well as upon the guilty, and instead of
+being always confined to the authority acting only in pursuance of the
+fixed rules of law, it has too often resulted from the arbitrary will of
+someone in superior authority.
+
+“Man’s inhumanity to man” seems ever to have been a peculiar trait of
+the species and human cruelty exceeds that of all other animals, in the
+same proportion that man excels the lower species. In following the bent
+of his cruel impulses, man has never rect’ with good or ill, but like a
+ravenous beast of prey, far fiercer “than the wolf or bear, he slays his
+kind in cruel glee and sorrows he can slay no more.”
+
+When we read the history of the punishments of antiquity, we can but
+wonder that the people suffered so long and so continuously as a result
+of laws which had for their foundation the passions or wickedness of
+only a small per cent of the people, instead of the beneficent rules
+of conduct formulated by the “cool examiner of human nature,” familiar
+with the actions of the multitude and prompted by altruistic motives, to
+legislate for the greatest happiness of the greater number.
+
+Every just punishment should be limited to the necessity of defending and
+preserving the liberty of the masses of society from the usurpations and
+wrongs of individuals, hence, every punishment which does not arise from
+such necessity is tyranny.[1]
+
+Since the time of Beccaria men have realized that the groans of a
+tortured wretch cannot recall the time past, or reverse the crime once
+committed,[2] so punishments are now provided for, not to torment a
+sensible being, nor to attempt to undo the crime committed, but to
+prevent the criminal from doing further injury to society and to deter
+others from committing similar offenses. But it was not always thus.
+Torture, of the worst kind, in the handling of criminals, has been
+consecrated as a time honored custom by most of the older nations of
+the world. Mankind, for centuries, seemed to forget that all men were
+brothers; that a man, after he is dead is good for nothing and since
+punishments were invented for the good of society, that they ought to be
+useful and not destructive, still they universally persecuted each other,
+even to the death.
+
+All mankind have ever detested the violence of which they may themselves
+possibly be the victim, but the criminal is so far regarded as an enemy
+to society, that they universally desire the punishment inflicted upon
+another which they would never want inflicted upon themselves. Viewing
+all other men as inconsequential in the sum total of the universe, but
+each individual believing himself the center of the social unit, men have
+been ever ready to play the tiger and make the alleged criminal the lamb,
+because it was the other individual whose life was sacrificed.
+
+Viewing the whole plan of society by the standards of the past, in the
+punishment of criminals, it is difficulty to determine whether the
+crimes against society or those of society against the alleged criminal,
+have been the greater. But with the idea of reforming the criminal,
+the barbarous tortures of the past have been eliminated and the trend
+of modern criminologists is to further limit all punishments, not in
+themselves wholly reformatory in their nature.
+
+Excessive punishments have always increased, rather than diminished
+crime, yet authority to inflict punishment has never been much concerned
+about the welfare of the race or of society, as a whole, and the humane
+law of the philosophers has been disregarded far too long to curb the
+ingenious cruelty that has inflicted penalties and pains upon alleged
+criminals, frequently wholly innocent of any crime.
+
+The object of this chapter, however, is not to moralize about crimes and
+punishments, but to contribute something to the vast fund of historical
+information upon the subject of ancient punishments, with a few
+illustrations of the pains and penalties inflicted during the past ages,
+in the name of law, upon the unfortunate victims falling into the vortex
+of the current of a past civilization and hopelessly borne on to their
+destruction.
+
+_Capital punishment, by beheading_ was not practiced by the ancient
+Israelites, but was a custom of the Egyptians, Assyrians, Persians,
+Greeks and Romans,[3] and the French. We find that the “chief baker,”
+who incurred Pharoah’s ill-will, was accordingly decapitated;[4] John
+the Baptist lost his head on the order of Herod;[5] James the Apostle
+suffered a similar fate,[6] and many other of the early martyrs were
+beheaded.[7]
+
+_Burning_ to death was of pre-Mosaic authority, for we find that when
+it was reported to Judah that his daughter-in-law Tamar, was with child
+and had played the harlot, Judah said, “Bring her forth and let her be
+burnt.”[8] This was the punishment inflicted upon a priest’s daughter,
+under the Sinaitic law, for fornication,[9] and was also the form of
+punishment for incest with a wife’s mother.[10]
+
+_Drowning_ was a form of capital punishment in vogue among the ancient
+Babylonians, the Jews and the Romans and more recently among the French,
+English and Americans, during the witch craze in the seventeenth
+century.[11]
+
+Even before the witch craze, in England, in which death by burning and
+drowning was the usual mode of ending the lives of the poor unfortunates,
+accused of this hated and unprovable crime, there were precedents for the
+use of drowning, as a punishment, in that country.
+
+During the reign of Edward II. felons were put to death by drowning, for
+we find that in the sixth year of the reign of that monarch, the jury
+for the hundred of Cornylo, in Kent, exhibited a presentment to Hervi de
+Stanton, and his associate justices itinerant, sitting at Canterbury, in
+the Octaves of St. John the Baptist, importing, that the Prior of the
+Christ-church in Canterbury, did, about eleven years then past, divert
+the course of a certain stream, called Cestling, in which such felons as
+were condemned, to death, within the before-mentioned hundred, ought to
+suffer judgment by drowning.[12]
+
+Drowning was regarded as an especially appropriate punishment for women
+in Scotland, at an early day and according to Dr. Hill Burton, in 1624,
+eleven gipsy women were sentenced to be drowned in the North Loch,
+of Edinburgh, in the hollow where the Princess street Garden is now
+located.[13]
+
+In 1685 two women, Margaret M’Lauchlan, a widow, and Margaret Wilson,
+a young girl, of eighteen, were drowned at Wigtownshire, for their
+religious belief. They were bound to stakes where the swift tide of
+the Solway overflows twice a day. After a partial unconsciousness, the
+young girl was revived and was urged by her friends to say “God save the
+King.” She refused and as the waters closed over her for the last time,
+she gasped: “I am Christ’s.” And thus she gained a place in history, as
+a martyr to her belief, and her young life was forfeited as a penalty
+for having incurred the religious and political bigotry of a despotic
+monarch.[14]
+
+_Exposure to wild beasts_, was a common punishment of the Israelites,
+and Romans, for wickedness or unfaithfulness. Darius caused Daniel to be
+brought and cast into the den of lions,[15] for this was the law of the
+Persians, and the King had entered a decree that it should be so, and
+another ancient authority,[16] advises us that a disobedient prophet,
+named Jadon, met death from God, by being cast before the lions.
+
+_Hanging_ is one of the forms of capital punishment that has survived
+for thousands of years, for we find that it was in general use among
+the ancient patriarchs,[17] the Persians[18] and the Greeks[19] and has
+continued as a mode of capital punishment ever since, in other civilized,
+or rated civilized, countries.[20]
+
+_Precipitation, sawing asunder, slaying by spear or sword, stoning
+to death, strangling and suffocation_, were all different modes of
+inflicting the death penalty, practiced among the ancient Israelites and
+other ancient peoples, from the earliest time.
+
+The children of Judah cast 10,000 Edomites from a rock to their death,
+according to the second book of Chronicles;[21] even the valiant David,
+painful to relate, when he took the cities of the children of Ammon,
+brought forth all the people and “cut them with saws, and with harrows of
+iron, and with axes”;[22] the spear, javelin or dart, was to be used on
+trespassers, at the foot of Sinai;[23] the sword was taken by the Levites
+against the worshipers of the golden-calf;[24] Samuel hewed Agag to
+pieces with the sword;[25] stoning to death was the penalty for adultery,
+blasphemy, idolatry, for false prophesy and Sabbath breaking;[26]
+strangling was the proposed punishment for the Syrians, before Israel[27]
+and suffocation was used both by the ancient Jews and the Macedonians.[28]
+
+_Crucifixion_, was a refined mode of punishment used by the Jews and
+Romans, in the time of the Saviour. It was borrowed by the Romans and
+Grecians from the Phoenicians, Persians, Egyptians and Numidians, among
+whom it was in general vogue. Alexander is reported to have crucified
+two thousand Tyrians at one time, and the same number of rioters were
+crucified by Varos at one time, after the death of Herod.[29]
+
+Under Claudius and Nero, various Roman governors crucified large numbers
+of robbers, thieves, and political and religious criminals.[30]
+
+The method of crucifixion is accurately described in the New
+Testament.[31]
+
+After conviction, the victim was scourged with the _flagellum_, which was
+such a severe punishment that the afflicted one frequently died before
+the crucifixion occurred. In Jesus’ case, the scourging seems to have
+taken place before the crucifixion, as was the custom.
+
+The cross-bar was bound upon the back of the victim, or his head was
+placed in the _patibulum_, and he was then led through the city,
+accompanied by the centurions and soldiers having his execution in hand,
+amid the gibes and insults of the cruel crowd. The title, a piece of
+wood, covered with white gipsum, labeled with the crime for which he was
+to suffer, in letters of black, was usually carried before the condemned
+person, so that the curious might be advised of the cause of his death.
+
+At the place of crucifixion, the prisoner was stripped and his clothes
+given to the soldiers; he was then bound to the _patibulum_ and thus
+raised on ladders, until the notch was reached in the upright piece, to
+receive it, or the cross-piece was fastened to the upright post upon the
+ground and then raised into an upright position, with the afflicted one
+bound to the cross, with his hands nailed to the ends, there to suffer
+the slow agonies of a lingering death, which might last for hours or
+perhaps for days.
+
+The shame of this torture to which the Saviour was subjected has become
+not only the symbol of salvation, but the true type of that absolute
+renunciation of the world which characterizes the true Christian, for
+did not Christ Himself say: “If any man would come after me, let him
+deny himself, and take up his cross and follow me”?[32]
+
+_Burying alive_, was a form of capital punishment applied in Rome as a
+punishment to the vestal virgins, violating their oaths of chastity and
+it was also in vogue in France during the middle ages.
+
+According to the law of Numa, the unchaste Vestal was simply stoned to
+death,[33] but the cruel torture of burying her alive was devised by
+Tarquinius Priscus and inflicted from his time forward.[34]
+
+On her conviction, the poor creature was stripped of her _vittae_ and
+other indicia of office and after being scourged, was attired like a
+corpse and placed in a closed litter, and then borne through the Forum,
+attended by her weeping relatives and friends, with all the ceremonies
+of a real funeral, to the _Campus Sceleratus_, within the walls of the
+city, near the Colline gate. The vault, underground, was furnished
+with a couch, a lamp, and a table, with a little food. The pontifex
+maximus offered up a prayer to Heaven for the culprit and having thus
+performed his sacred office, delivered her to the executioner, who led
+her down into the subterranean cell and drew up the ladder and filled
+the pit with earth even with the ground,[35] thus forever consigning
+to mother earth the body of her wayward daughter, who, in pursuance of
+her God-given instincts, had violated the unnatural law of the barbarous
+pagan days of ancient Rome.
+
+The gallant French gentlemen also reserved this horrible punishment for
+women and we read that during the year 1302 by order of the Bailli of
+Sainte-Genevieve, a woman was buried alive for some petty thefts which
+she had committed.[36] Philip Augustus is said to have put a French
+provost to death in this cruel fashion, because of the crime of perjury,
+regarding a transaction in connection with a vineyard[37] and in the
+thirteenth century in Bigorre, this punishment was inflicted for murder,
+the murdered and his murderer being interred in the same grave.[38] One
+performing the unnatural crime was also buried alive, in England, at an
+early day, according to Fleta.[39]
+
+_Drawing and quartering_, is of Egyptian and Roman origin, for we find
+that it existed at Rome five hundred years before Christ and is mentioned
+in the Twelve Tables.[40]
+
+Hanging, drawing and quartering is said to have been first introduced in
+England in the case of William Maurice, a pirate, in 1241,[41] although
+it afterwards became quite common, as a punishment for treason.
+
+According to the terms of a sentence imposed by Lord Ellenborough, the
+criminal convicted of treason to be thus punished was addressed as
+follows: “You are to be drawn on hurdles to the place of execution,
+where you are to be hanged, but not until you are dead; for, while still
+living, your body is to be taken down, your bowels torn out and burnt
+before your face; your head is then to be cut off and your body divided
+into four quarters.”[42]
+
+Hugh Spenser, the favorite of King Edward II., was put to death at
+Bristol, in 1326, and his body was quartered, as was the custom of the
+period, in similar cases, and his head was sent to London, while each
+quarter of his body was sent to each of the four principal towns of the
+kingdom.[43]
+
+On the execution of the Jesuit, Garnet, in England, in 1606, James I.,
+who was more compassionate in this case than he was in the cases of
+witchcraft, where no punishment could be found too severe, gave orders
+that he should not be cut down until he was dead, so that he might be
+spared the tortures of drawing and quartering.[44] But no such mercy
+was shown to Guy Fawkes, who was tortured and drawn and quartered, the
+same year, after he was taken with the burning match in his hand, in his
+attempt to blow up the king and his parliament, in what was known as the
+gunpowder plot.[45]
+
+During the thirteenth century, in England, the usual punishment for petty
+treason was hanging and drawing for a man and burning for a woman.[46]
+
+_Boiling in oil_ during the reign of Henry VIII.,[47] was a punishment
+provided for poisoners.
+
+Under the reign of this monarch, the power of the Crown was extended to
+cover powers not before recognized and while it is difficult to concede
+how citizens reared under the broad influence of the common law, could be
+brought to consent to such unusual and cruel punishment for any crime,
+the inhuman crime which brought about this harsh statute was such as to
+call for unusual handling, if not for such barbarous punishment as this
+act provided.
+
+One Richard Roose had placed poison in a vessel of yeast in the Bishop of
+Rochester’s kitchen and as a result of eating bread in which this yeast
+was used, seventeen persons in the family of the Bishop and others of
+his friends were poisoned. The enormity of the crime caused wide-spread
+indignation and such crimes were made treason and the offender subject
+to attainder. Roose was ordered to be boiled to death and in order to
+deter others similarly situated from perpetrating such a cruel crime,
+it was also provided by the act that henceforth, every wilful murder by
+poisoning, should be high treason and that all such offenders should be
+boiled to death.[48]
+
+Shakespeare makes the indignant Paulina, refer to this statute, in
+her reproachful speech to the Lords, after the good Hermione’s
+incarceration, in Winter’s Tale, when she asks:
+
+ “What studied torments, tyrant, hast for me?
+ What wheels? racks? fires? what flaying? boiling
+ In leads or oils? What old or new torture
+ Must I receive, whose every word deserves
+ To taste of thy most worst?”[49]
+
+Margaret Davy, a young woman, convicted of murder by poisoning was also
+boiled to death, as provided by this statute, in 1542,[50] but this was
+the last victim to suffer such inhuman punishment and the act was soon
+afterward repealed.
+
+The misguided efforts of the Church of Rome to punish heresy by use of
+the _Inquisition_, brought about untold suffering and misery in the world.
+
+_The Inquisition_, was a tribunal of the Roman Catholic Church, for the
+discovery, repression, and punishment of heresy, unbelief and other
+offenses against religion. The emperors, Theodosius and Justinian,
+appointed officials known as Inquisitors, to look out and punish such
+offenders. They proceeded however in the name of the Emperors, in the
+secular courts, and no regular tribunal for the handling of this kind of
+alleged criminals, existed until the year 1248, after the fourth Lateran
+Council, held in the reign of Innocent III., when Innocent IV., established
+a permanent court for the prosecution and punishment of this class of
+offenders.
+
+The prosecutions under this constitution were purely in the
+ecclesiastical courts, and for the next century, in France, Italy,
+Spain and Germany, the Pope, by appeal, regulated the severity of the
+punishments inflicted by the local authorities and the punishments were
+not so severe as they afterwards became.
+
+In Spain, during the reign of Ferdinand and Isabella, on account of an
+alleged plot to overthrow the monarchy, by the Jews and Heretics, in the
+year 1478, on application to Pope Sixtus IV., they were permitted to take
+over, as it were, the whole tribunal formerly handled as a Church affair,
+into the hands of the State, and with this new regime, the Spanish
+Inquisition had its origin.
+
+Inquisitors were now appointed by the Crown, instead of the Church and
+under the career of Thomas de Torquemada, in 1483, the reign of terror
+commenced in Spain. Llorente, the historian of the Inquisition, places
+the number of persons burned to death, during Torquemada’s tenure of
+office, in sixteen years, in Spain, at 9,000, and during the term of
+office of the second head of the Inquisition, Diego Deza, in eight years,
+1,600 met a similar death, by fire, as this was the customary punishment
+inflicted upon this hated class of innocents who opposed the ruling
+powers in Church and State.[51]
+
+The procedure of the Inquisition is not without interest. The person
+suspected of heresy or unbelief, was arrested and thrown into prison,
+to be brought to trial when it suited the pleasure of his judges.
+The proceedings of the trial when the unfortunate one was brought
+into court, were secret; he was not faced with his accusers, nor were
+their names disclosed. The evidence of a guilty accomplice, without
+corroboration, was received against the accused and the person undergoing
+trial was liable to be put to torture, in order to extort a confession
+from him. When convicted, the punishment was death by fire, or on the
+scaffold, imprisonment in the galleys for life, or for a term of years,
+with forfeiture of his property, and civil infamy, if the offense was
+deemed not of sufficient gravity to justify burning to death.[52]
+
+After confession, under torture, the prisoner was customarily remanded
+to prison and when brought before the judge, if he persisted in his
+profession, he was condemned. If the confession was withdrawn, he was
+tortured again and if he recanted a second time, he was tortured a third
+time, for while the theory was that he could not be convicted, unless he
+let his confession stand, he was tortured until he confessed and was not
+allowed to voluntarily retract it, oftentimes.[53]
+
+Three judges were necessary to approve the infliction of torture to
+extract evidence from a person accused, in the reign of Ferdinand and
+Isabella,[54] but this law was often violated and the strappado, the
+scourge, hanging the accused by the arms, while his back and legs were
+loaded with heavy weights, fire, applied to the soles of the feet and
+pouring water down the throat were a few of the many tortures applied[55]
+to extort confessions from the poor unfortunates who fell into the hands
+of these religious zealots, imbued with a superhuman inclination to
+torture their fellow-men.
+
+Of course the subject of the Inquisition is too large a field to attempt
+to do more than refer to its influence upon secular law in these pages,
+for while it continued unabated for centuries in countries subject to
+the Church of Rome and was not abolished in Spain, until the reign of
+Joseph Bonaparte in 1808,[56] in inaugurating a system of punishment for
+extracting evidence from the accused, its influence was wide-spread in
+all other countries, where the same system of punishment was carried and
+with time the same vile procedure was used in most other countries of
+Europe, in one form or another,[57] and with its examples of torture,
+which were gradually adopted in other countries, the equally baleful
+influence of the secret procedure, which was exemplified in the Star
+Chamber in England and the _Chatelet_ of Paris, with the accompanying
+inquisitorial process, followed in the wake of this hateful institution
+of the middle ages.[58]
+
+_The Grand Chatelet of Paris_, as the seat of the criminal tribunal of
+the realm, has a record second to no other criminal court of the same age
+for atrocious punishments inflicted upon the poor unfortunates who were
+brought before the court, seeking justice.[59]
+
+It was the custom to torture all malefactors, or alleged criminals,
+brought before the criminal division of the _Chatelet_ of Paris, in the
+fourteenth century. The customary procedure was accordingly divided
+into two classes of cases, those known as _ordinaire_ and those called
+_extraordinaire_. In the former class of cases inquests were held to
+determine the guilt of the accused and in the latter inquisition was had,
+in which torture was habitually employed to secure a conviction.[60]
+
+The procedure was left entirely to the discretion of the criminal judge
+and in a short time the judge rarely found a case for inquest, but all
+cases were treated as within the rule _proces extraordinaire_ and a merry
+chronicle of crime against criminals was here inaugurated, for long and
+tedious years.[61]
+
+The only redeeming feature of the procedure of this court, was the
+universality of its punishments, for noble blood was made to flow equally
+with the plebeian, and none were exempt from the torture, who were
+brought before this court. If the culprit denied the alleged crime, he
+was tortured at once, to secure a confession and if he confessed he was
+tortured for confessing. On the other hand, if he failed to confess,
+there was no limit to the torture inflicted to extract a confession from
+him, so frequently it happened that in the effort to find out if a crime
+were really committed the poor unfortunate was killed by the torture to
+which he was subjected.[62]
+
+In 1338 one Jehannin Maci, was arrested and brought before this cruel
+court for stealing a brass pot, found in his possession. After torture,
+he confessed the crime and was drawn on a hurdle and hanged.[63]
+
+Gervaise Caussois—peace to his ashes—was brought before this august
+tribunal for stealing some iron tools and to induce him to confess he was
+tortured and promptly confessed. Thinking he might be guilty of other
+offenses, he was tortured again and then under the strain of the pain he
+suffered, he confessed to other petty crimes, when he was again tortured
+by use of the _tresteau_, when he again confessed to another petty
+misdemeanor when the judges mercifully caused him to be hanged, without
+more ado, thus ending his misery.[64]
+
+In 1390 poor Fleurant de Saint-Leu, was arraigned before this heartless
+tribunal for the awful crime of stealing a silver buckle. He denied the
+crime and was twice tortured, with increasing severity, when he finally
+confessed, but protested that it was his first offense. The merciful
+judges, out of the goodness of their hearts, decided this offense, being
+the first, did not merit death, so on the same day he was tortured
+thrice, to ascertain if he was not guilty of some other offense for
+which he could be killed; this failing to bring the desired result, he
+was again twice tortured, when he admitted that three years before he had
+unwittingly married a prostitute, when he was afterwards hanged, as this
+was found to be a sufficient offense, together with the stealing of the
+buckle, to justify the death penalty.[65]
+
+Poor Marguerite de la Penele, accused of stealing a ring, was tortured
+until she confessed and as she could not satisfy the human hyenas who
+were trying her, for some money found upon her person, she was again
+severely tortured and although no further confession was extracted from
+her she was buried alive.[66]
+
+The question _ordinaire_ and _extra-ordinaire_, as put to the wretches
+brought before this criminal court at Paris, was to be answered by the
+accused while fastened to the wall, on a trestle or sliding table, with
+his wrists fastened in two rings; his mouth was forced open with a horn
+and water was poured down his throat, until he answered the question
+whether or not he was guilty of the offense charged against him.[67]
+
+Another form of torture used in the _Chatelet_ at Paris, was what was
+called the “boots,” being solid boards, pierced with holes, encasing
+the legs, up to the knees. Ropes were inserted through the holes and
+drawn so tight, by means by pegs of wood, driven into the holes, as to
+almost break the bones and twist the flesh off the legs, if the accused
+persisted in refusing to confess the crime charged against him.[68] This
+horrible and barbarous practice was not completely abolished in France,
+until the year 1788, when the monarchy repealed the law authorizing such
+cruelty, for the alleged reason that under such stress of punishment men
+would confess to anything.[69]
+
+_The Guillotine_ was not a French invention, as generally supposed,
+but was imported from Italy, where a similar instrument, known as the
+_Mannaya_, had been used for centuries before it was used either in
+France or England.[70] It had been used in England long before it was
+used in France and was known as the _Halifax Maiden_, because of the
+special charter, giving this town a right to use it for petty larceny of
+any article exceeding thirteen halfpenny.[71] It was used in France in
+the sixteenth century and at Toulouse, in 1632, it was the engine which
+accomplished the execution of the Duc de Montmorency.[72] Doctor Joseph
+Guillotin brought the same engine of death before the National Assembly,
+in December, 1789 and he is generally recognized as the inventor of this
+terrible machine, which was used to decapitate so many of the nobility
+during the terrible French Revolution,[73] but a similar instrument had
+executed thousands in Italy centuries before it was known or used in
+France.[74]
+
+_The Massola_ was used in Italy, at an early date, along with the
+_Mannaya_ or guillotine, as it was afterwards called, in France, and by
+use of the former machine, the criminal was stunned with a blow from a
+mace, much as the butcher slaughters the ox or hog by striking him on the
+head and then while stunned, his throat was pierced with a long knife and
+his chest was ripped open.[75]
+
+But let us turn from the contemplation of other instruments used to
+accomplish the death of the criminals of the middle ages, and examine
+some of the milder forms of punishments in vogue.
+
+These were only some of the most prominent methods of inflicting
+capital punishment upon alleged criminals, among the old Israelites,
+Persians, Greeks and Romans, and other lesser punishments, such as
+mutilation consisting in blinding,[76] cutting off the hands or ears,[77]
+branding,[78] plucking off the hair,[79] flaying,[80] scourging with
+thorns,[81] the stocks, stripes,[82] the wheel, the rack, the comb with
+sharp teeth, the burning tile, the low vault in which the culprit was
+bent double, the heavy hog-skin whip, and the injection of vinegar into
+the nostrils, were a few of the lesser punishments inflicted by these
+and other peoples for many long and tortuous years, upon all classes of
+criminals and accused persons.[83].
+
+_Blinding_, under the Mosaic dispensation, was claimed to have been
+authorized under the law of retaliation, “an eye for an eye,”[84] etc.,
+but it was seldom used among the patriarchs in old Israel.
+
+The Assyrians and Babylonians used this means of torturing the criminals
+convicted of rebellion or revolt, in order to prevent them from doing
+further harm and to furnish an example to others of the enormity of the
+punishment for such an offense against the government.[85] We read in
+the book of Esther that such criminals were not permitted to look upon
+the king,[86] and in Persia this method of punishment was inflicted for
+rascality, thieving and rebellion.[87]
+
+According to the Code of Hammurabi, adopted some 2,500 years before
+Christ’s time, a surgeon of Babylon who performed an unsuccessful
+operation, lost the hand that operated upon the patient and for other
+offenses, mutilation and blindness was provided for by this ancient code
+of laws.[88]
+
+William the Conqueror prohibited his nobles from inflicting the death
+penalty upon criminals who formerly suffered death by hanging, but
+in lieu of this more humane punishment, he authorized that criminals
+convicted of certain felonies should be blinded, by having their eyes
+pulled out; they were subjected to castration and to mutilation, by
+having their _hands and feet cut off_, according to the greatness of the
+offense, to the end that they might live and furnish a horrible example
+to others committing such crimes.[89]
+
+According to Wigorn, in his annals, certain Welchmen, convicted of
+treason, in the eleventh century, had all these several kinds of
+punishment inflicted upon them.[90]
+
+Fox, in his work on Martyrology, reports a miracle in the case of
+Elivard, of Weston Regis, in Bedfordshire, who, being convicted of
+stealing a pair of hedging gloves and a whetstone, in the reign of Henry
+II., lost his eyes and genitals, and through his devout prayers, at the
+shrine of St. Thomas of Canterbury, they were restored to him again.[91]
+
+This punishment by blinding and mutilation continued but a short time, in
+England, however, for King Henry I., in the year 1108, in the ninth year
+of his reign repealed this law and provided hanging for felons convicted
+of theft or robbery,[92] who had formerly been subject to the punishment
+of blinding or mutilation, by this harsh law of William the Conqueror.
+
+In Switzerland, at an early day, blasphemers were subject to having their
+_lips and tongue cut off_[93] and under the custom of Avignon, in 1243, a
+perjurer was liable to punishment by having his lips and nose removed.[94]
+
+_Cutting off the ears_ was a punishment inflicted upon religious and
+political criminals in England, as late as the seventeenth century and
+the notable case of Bastwick, Burton and Prynne, who had their ears
+removed all at one time, in the Palace Yard, in London, in the year 1637,
+illustrates the barbarous cruelty then obtaining as to this class of
+criminals.
+
+The prisoners were all favorites with the crowd, who strewed flowers and
+nose-gays around them, at the place of execution. The sheriff commenced
+with Burton, who was an especial favorite with the by-standers and when
+he removed each ear the people wept and groaned and roared as if each one
+in the assembly had his own ears removed. Bastwick loaned his own knife
+to the officer and made use of his professional information to advise him
+just how to remove his ears, so as to injure him the least and asked him
+to lop them close, that it might not be necessary for him “to come there
+again.” Prynne had had his ears roughly cropped off three years before
+and when the officer again attempted to remove what remained, it gave him
+great pain, but the stern old Puritan endured it without a groan, such
+was the religious zeal with which they were all three sustained in this
+act of martyrdom. After the fearful ordeal was completed they were all
+three returned by the officer to the prison,[95] and thus ended another
+fearful example of misguided authority and religious bigotry, in thus
+pillorying and torturing three patriotic citizens who violated no law and
+who had committed no other offense than to speak plainly and then dared
+to refuse to bow the knee to an authority they did not recognize.
+
+_Branding with a hot iron_, was a punishment inflicted by the Persians,
+upon the class of criminals who were deported, in order that they could
+subsequently be identified and to furnish an example to others of the
+fact that they had paid the penalty of the law as a result of their
+misdeed.[96] In Biblical days, when burning was inflicted as a punishment
+for adultery or fornication, branding on the forehead was also used, as
+a mark of shame.[97] Slaves were sometimes branded on the hand, by the
+ancient Jews,[98] much as horses are branded by the owner, in the western
+country, to identify the animal, but this was not in accordance with the
+Mosaic law, for such disfigurement was forbidden by the code of the old
+Israelites.[99]
+
+Formerly, in England, branding was used in the case of all clergyable
+crimes, by burning in the hand, but this law was repealed in 1829. In
+the middle ages, in England, branding with a hot iron, was a mode of
+punishment used for various offenses. The iron used had the form which
+it was desired to leave on the culprit’s skin. It has not been in use
+for years, except in desertions from the army or navy, and this form
+of branding is regulated by statute and of late years ink, or other
+material is used, instead of a hot iron. By the Mutiny Act, of 1858,[100]
+it was provided “On the first and on every subsequent conviction, for
+desertion, the court-martial, in addition to any other punishment, may
+order the offender to be marked, on the left side, two inches below the
+arm-pit, with the letter D, such letter not to be less than an inch
+long, and to be marked upon the skin with some ink or gun-powder, or
+other preparation, so as to be visible and conspicuous, and not liable
+to be obliterated.” This, in old England, as late as the Victorian age,
+shows the early training of the English upon the custom of punishment by
+branding.
+
+_Plucking off the hair_, or scalping, was not always confined to the
+American Indians, but according to the inspired word of the Jews, it was
+a form of punishment, in ancient Israel, inflicted upon Jews who had
+indulged in mixed marriages.[101]
+
+According to the prophet, in Isaiah, scalping, as a judicial practice was
+common in his time, for he says: “I gave my back to the smiters and my
+cheeks to them that _plucked off the hair_: I hid not my face from shame
+and spitting.”[102]
+
+And according to the Biblical account of this ancient and severe
+punishment, inflicted upon criminals in old Israel, they were not as
+compassionate as the American Indians, who first killed their man, then
+removed the scalp with a knife, but they tore off the hair in such a
+brutal and barbarous manner, as to remove the skin by main force, with
+the hair, without the use of a knife or other instrument to augment or
+ameliorate the suffering of the criminal.[103]
+
+_Flaying_, was a punishment in vogue among the Persians and Assyrians,
+and according to Rawlinson, the Assyrians would flay the victim, even
+after life was extinct[104] and the Persians were accustomed to flay and
+then crucify the criminals and Herodotus states that they used the skins
+of human beings thus obtained.[105]
+
+Along with this atrocious punishment of flaying, the Persians also seem
+to have been addicted to the recall of judges,[106] for Herodotus tells
+how King Cambyses not only recalled an unpopular judge, known as Sisamnes
+but actually flayed him alive, and covered the judgment-seat with his
+skin, as a warning to the next judge to be more careful in his judgments
+and decrees.[107]
+
+Manes is said to have been flayed alive, by Behram, king of Persia, in
+the year 277 and his skin was afterwards stuffed with straw, much as
+modern taxidermists stuff the skins of wild animals, and in this shape it
+was posted at one of the gates of Djondischaour.[108]
+
+In the sixth century Chosroes punished Nacoragan, one of his generals by
+flaying him alive, on account of his cowardice and his skin, when torn
+backward off his body, from his head to his heels, retained the form of
+the limbs, from which it had been stripped, and in this manner, it was
+sown up and inflated and exposed on a high projection, as a terrible
+example to other soldiers, of the punishment they would be subjected
+to if also guilty of cowardice in the discharge of their duty as
+soldiers.[109]
+
+Flaying is of rare appearance in Europe, but one or two cases are
+recorded. Philip the Fair is said to have inflicted such punishment upon
+the lovers of his sister-in-law, in 1314, and Pope John XXII., after the
+conviction of Hugues Geraldi, Bishop of Cahors, in 1317, for sorcery,
+handed him over to the Judge of Avignon, who caused him to be flayed
+alive and then torn asunder by four horses, after which his remains were
+burnt.[110]
+
+_The Wheel_ was used as a method of punishment in France and England
+and other countries, during the middle ages and down to a comparatively
+recent period. St. Catherine, of Alexandria is said to have been put to
+death on a wheel, with jagged edges or spikes, which tore and cut her
+tender limbs, after the fashion of a modern chaff-cutter. According to
+the report of her case, the wheel was shattered, during the torture, by
+Divine Grace, hence the embroidered tunic worn by the Knights of Mount
+Sinai, a religious order, instituted in her honour, in 1063, representing
+a broken wheel, with spikes.[111]
+
+Bouchard, who was implicated in the murder of Charles le Bon, Count of
+Flanders, in the twelfth century, was bound to a wheel suspended in
+mid-air, so that the vultures could pluck out his eyes and otherwise
+torture him. After his eyes were torn from their sockets and his face
+slit and torn by the sharp beaks of the birds of prey, he was finally put
+out of his misery, by darts and javelins, shot into his quivering body,
+by the blood-thirsty mob below.[112]
+
+_Scourging with thorns_, was another form of punishment inflicted upon
+the peoples of other tribes, by the good old Jewish patriarchs.
+
+Gideon threatened that when the Lord of Israel should deliver Zebah and
+Zalmunna into his hands that he would tear their flesh with the thorns of
+the wilderness and with briars.[113] And according to the Divine word,
+when the men of Succoth were delivered into his hand he took the elders
+of the city and with briars and thorns, he scourged them.[114]
+
+Knotted sticks, or ropes, with thorns, or iron points were customarily
+used as instruments of chastisement by the Jews, when they were
+successful in subjugating another race of people[115] and they did not
+hesitate to apply the scourge on all occasions, as they regarded this as
+a method of teaching foreign nations their strength and their power to
+punish, so that it would be advertised abroad and cause other timorous
+nations to voluntarily submit to their authority.
+
+David smote the Moabites with a line and cast them down to the ground
+and he scourged them and they became his servants and brought him gifts,
+to avoid being further scourged in this manner.[116] And he brought the
+children of Ammon out from the cities and not only scourged them with
+thorns and knotted sticks, with iron pikes in the sticks, but subjected
+them to saws and arrows of iron and made them to pass through the brick
+kiln.[117]
+
+_The Bilboes_, were used in Spain and England, at an early day, for
+slanderers and other petty offenders. By means of this instrument, the
+culprit was held with his feet aloft, on his back, exposed to the public
+gaze and ridicule of the passers-by.
+
+The American Colonists made frequent use of this instrument of punishment
+and we read that in good old Massachusetts, in August, 1632, one “James
+Woodward was sett in the bilbowes, for being drunk at the Newetowne,” the
+name Cambridge then went by.[118]
+
+_The Ducking-stool_, a stool or seat, arranged at the end of a rope tied
+to a long pole, so it could be lowered into the water, was used as a
+punishment for “scolds” and “slanderers” in old England and by the early
+American Colonies. Virginia, Maryland and other of the American Colonies,
+provided for the use of the ducking-stool and other similar correctionary
+punishments, by statutes.[119]
+
+As late as the year 1811, in Georgia, one Miss Palmer was sentenced to
+be ducked, as a scold or slanderer, in the Oconee River[120] and in
+Washington, according to the interesting book on “Curious Punishments
+of By-Gone Days,” by Alice Morse Earle, almost in our own day, Mrs.
+Anne Royal, Editor of the “Washington Paul Pry,” was sentenced before
+Judge William Cranch to suffer punishment by being ducked in the Potomac
+River.[121]
+
+_The Stocks_ graced each parish, in England, at an early day and along
+with the _pillory_ and the _rack_, were used on different classes of
+petty criminals. Many criminals were also punished by the American
+Colonists by use of the stocks and the pillory, and in Massachusetts, New
+Hampshire, Virginia and Maryland, the manners and morals of many an early
+patriot were mended by the use of these instruments.[122]
+
+_The Rack_ was a wooden framework, in which the culprit was fastened and
+by means of ropes and pulleys his arms and legs were violently stretched
+and pulled until the tension caused the most intense pain and frequently
+the bones were broken by the use of this fearful appliance. According to
+Lord Coke, the appliance was first introduced into the Tower, in England,
+by the Duke of Exeter, in 1467, and for this reason it was called, “The
+Duke of Exeter’s Daughter.” The Tower rack was in the long vaulted
+dungeon below the Armoury and continued as an instrument of torture for
+many centuries. During the reign of Elizabeth, it was a customary means
+of torture and in 1580 the Jesuit Priests concerned in the alleged Jesuit
+Invasion, were terribly racked to compel them to disclose the names of
+their leaders.[123]
+
+Shakespeare makes frequent references to this instrument of torture, so
+generally used during his time, in England. Thus, in Merchant of Venice,
+Portia refers to the enforced statements of Bassanio:
+
+ “Ay, but I fear, you speak upon the rack,
+ Where men enforced do speak anything.”[124]
+
+_The Brank_, known as the “Scold’s bridle,” was an iron hood, with a
+ring, around the face, with a flat tongue of iron to be placed in the
+mouth, over the tongue. It was applied, with the “scold” or slanderer
+tied in a public place, where she was subjected to the ridicule of the
+passers-by and was generally used to correct scolds and fussy women,
+for many years, in both England and America. It was used on the poor
+unfortunates during the Salem Witchcraft craze and many an old dame in
+good old England was made to bridle her tongue and desist from gossiping
+or henpecking her husband, because of the fear of the “scold’s bridle”
+and the gag, used indiscriminately, in all such cases.[125]
+
+Fortunately, with the dawn of better days, this torture system began to
+decline and in most civilized countries, such “crimes against criminals”
+are now but curious and quaint, yet oft-times terrible and fearful
+examples of the customs and procedure of other days.
+
+The strange thing is that such things lasted as long as they did in a
+growing, increasing world of knowledge, with men who sought the truth and
+attempted to attain the higher ideals and who should have been imbued
+with the love of their fellow-man, which the sufferings and mistakes of
+the past had, for centuries, led them to emulate.
+
+With the striking example in history of the horrible punishment by
+Crucifixion, all men now dread to think of the time when innocence and
+goodness could be so crucified, yet for two thousand years, in the slow
+evolution of the human race, other innocents and good men and women have
+been tortured and racked by men and women holding the superior power and
+authority over the masses, who through superstition and delusion, were
+led to endorse the cruel domination of such misused force.
+
+When we stop and contemplate the enormity of “Man’s inhumanity to man,”
+as recorded in the lessons of the past, “the marvel is that man can
+smile, dreaming his ghostly, ghastly dream.”
+
+The basis of such misanthropy lies in the fact that criminals have been
+treated as enemies, to such an extent that mankind has warred upon them
+and committed deeds of war, when, in point of fact, the alleged criminal,
+frequently was less guilty than his judges, and, if guilty, he was only a
+mistaken man, needing correction, but not torture or death, to teach him
+the better path to tread. Would that future generations might be fully
+emancipated from the selfish creed which calls that good, which works
+_me_ weal and holds that ill, which _me_ alone doth harm or hurt.
+
+For our lives, like ravelled skeins, cross back and forth, connect and
+blend,
+
+ “They change with place, they shift with race; and, in the veriest
+ span of Time,
+ Each Vice has worn a Virtue’s crown; all Good was banned as Sin or
+ Crime.”
+
+
+FOOTNOTES:
+
+[1] Justice is the bond which keeps the interest of individuals united
+and without this virtue men would return to their original state of
+barbarity. Marquis Beccaria, on “Crimes and Punishments,” 9.
+
+Carlyle has well said: “Cruel is the panther of the woods, the she-bear,
+bereaved of her whelps; but there is in man a hatred crueler than that.”
+
+[2] Beccaria’s “Crimes and Punishments,” p. 41.
+
+The three theories regarding lawful punishment, are, retribution,
+prevention and reformation. According to the first of these theories, the
+object of punishment is the vindication of the law upon the offender, by
+the infliction of such pain or penalty as his crime deserves, hence, the
+motto for this theory, might be properly said to be Justice. The second
+idea, makes prevention of further crime, the sole object, the criminal
+being placed where he can do no further wrong to society, and the motto
+of this school of legal philosophers, can therefore properly be said to
+be protection. The third and by far the most philanthropic doctrine of
+punishment regards the object of correction as the primary one to be
+attained and that all punishment should cease when the criminal has been
+reformed. The motto for the last school of philosophy, might properly be
+said to be Brotherly Love.
+
+[3] Rawlinson’s “Ancient Monarchies.”
+
+[4] Genesis, XL., 19, 22.
+
+[5] Matthew, XIV., 8, 10.
+
+[6] Acts, XII., 2.
+
+[7] Revelation, XX., 4. A common punishment during the French Revolution.
+
+[8] Genesis, XXXVIII., 24.
+
+[9] Leviticus, XXI., 9.
+
+[10] Leviticus, XX., 14.
+
+[11] John’s “Babylonian Laws,” etc., Josephus; Matthew, XVIII., 6.
+
+The Emperor Tiberius, after torturing the victims of his wrath, cast
+them into the sea, where they were drowned. Sueton. Tiberii, lxii; Lea,
+“Superstition and Force,” (3 ed.) p. 377.
+
+In France, death by drowning was inflicted upon the incontinent, as late
+as the sixteenth century and it was revived again during the revolution
+by the infamous Carrier, at Nantes, in the eighteenth century.
+
+Ninety priests were loaded into the _gabare_ and sunk in the river
+Seine. Then a hundred and thirty-eight persons were similarly drowned,
+but the _gabare_ was soon done away with and men, women and children
+were stripped naked and thrown into the river, in broad daylight and not
+even under the cover of darkness. They were tied together, feet and feet
+and hands and hands, and in their hideous death struggles they churned
+the water, for the edification of the cruel crowd, until the last poor
+struggler had sunk to his final rest. (See article by W. H. Davenport
+Adams, “Pains and Penalties,” in The Gentleman’s Magazine, Vol. 46, p.
+362.)
+
+[12] Herbert’s Antiquities (1804), 154; Ex. vet. cod. M. S. pene’s Rog.
+Twysden bar. p. 108.
+
+[13] Gentleman’s Magazine, Vol. 46, p. 501.
+
+[14] Archibald’s Stewart’s “Wigtoun Martyrs.”
+
+[15] Daniel, VI., 16.
+
+[16] Josephus, Ant. VIII., IX., 1.
+
+[17] 2 Samuel, IV., 12.
+
+[18] Rawlinson’s Anc. Mon. i, 477; Layard’s Ninevah and Babylon, 295 note.
+
+[19] Herodotus, iii, 159; Josephus, Ant. VI., XIV., 8.
+
+[20] Beccaria’s “Crimes and Punishments.”
+
+[21] 2 Chronicles, XXV., 12.
+
+[22] 1 Chronicles, XX., 3.
+
+[23] Exodus, XIX., 13.
+
+[24] Exodus, XXXII., 27.
+
+[25] 1 Samuel, XV., 33.
+
+[26] Hasting’s Dict. Bible, vol. I., p. 527.
+
+[27] 1 Kings, XX., 31.
+
+[28] Rawlinson’s Ancient Monarchies, iii, 246.
+
+Hanging was ordained by the Laws of Ina, in England, twelve hundred years
+ago. (Herbert’s Antiquities, p. 153.) Until 1783 Tyburn Tree, at the west
+end of Oxford Road (now street), was the usual place for execution of
+felons by hanging, in England.
+
+[29] Josephus, Ant. XVII., X., 9.
+
+[30] _Idem._, XX., V., 2.
+
+[31] John, XIX.
+
+[32] Matthew, XVI., 24; Mark, VIII., 14; Luke, IX., 23.
+
+All authorities agree that of all deaths crucifixion was the most
+abhorrent, not only because of the pain resulting, but also because
+of the shame of such a death. Cicero, in his Oration against Varres,
+declared that it was impossible to find a fit word to describe such an
+outrage as the crucifixion of a Roman citizen, yet the gentle Galilean
+suffered this horrible death, with perfect resignation.
+
+[33] Cedrenus, Hist. Comp. p. 148, 259.
+
+[34] Dions, iii. 67: Zonaras, vii, 8.
+
+[35] Dions, ix, 40; Smith’s Dict. Gr. & Rom. Ant. By a beneficent law,
+the poor lady’s paramour was simply scourged to death, for his complicity
+in her awful crime.
+
+[36] Gentleman’s Magazine, Vol. 46, p. 366.
+
+[37] _Ante idem._
+
+[38] _Idem._, p. 367.
+
+[39] Fleta, p. 54; II. Pollock and Maitland’s History English Law, p. 556.
+
+[40] Rawlinson’s _Anc. Mon._; Niebuhr, ii, 313.
+
+[41] Gentleman’s Magazine, Vol. 46, p. 368.
+
+[42] _Ante idem._
+
+[43] Gentleman’s Magazine, Vol. 46, p. 496.
+
+[44] _Ante idem._, p. 368.
+
+[45] Green’s History of England.
+
+[46] Select Pl. Cr. pl. 191; Munim. Gildh. i, 101; II. Pollock and
+Maitland’s History English Law, p. 511.
+
+[47] 22 Henry VIII. c. 9. This statute was passed in 1531.
+
+[48] IV. Reeve’s History English Law, p. 427.
+
+[49] The Winter’s Tale, Act III., Scene II.; White’s “Law in
+Shakespeare,” p. 186, Sec. 146.
+
+[50] Gentleman’s Magazine, Vol. 46, p. 364.
+
+As late as the sixteenth century, in England, counterfeiters were
+punished by being thrown into boiling water. Gentleman’s Magazine, Vol.
+46, p. 364.
+
+[51] Llorente, ii, 147, 237.
+
+[52] Lea’s “History of the Inquisition.”
+
+[53] Lea’s “Superstition and Force,” (3 ed.) p. 404.
+
+[54] Lea’s “Superstition and Force,” (3 ed.) p. 409.
+
+[55] _Ante idem._ 407, 409.
+
+[56] Llorente’s _Istoria de la Inquisition_; Lea’s “History of the
+Inquisition.”
+
+[57] _Ante idem._
+
+[58] Lea’s “Superstition and Force,” (3 ed.) 451.
+
+[59] Du Cange’s _Questionarius_.
+
+[60] L. Tanon, Registre Crimenel de la Justice de S. Martin-des-Champs,
+Introd. p. 85.
+
+[61] _Ante idem._
+
+In applying the ordinary and extraordinary question, in France, by
+means of the _estrapado_, an iron key was placed between the palms of
+the accused’s hands, and they were tied behind his back and, by means
+of a rope passed through a pulley, in the ceiling, he was raised twelve
+inches above the floor with a weight of one hundred and eighty pounds
+to his right foot. This was the “ordinary” question. In applying the
+“extraordinary” interrogation, the same process was used, but the accused
+was raised up to the ceiling, with a two hundred and fifty pound weight
+tied to his foot, in a running line, two or three times, with the result
+that he usually swooned before the ceiling was reached the last time.
+(Gentleman’s Magazine, Vol. 46, p. 504.)
+
+[62] Lea’s “Superstition and Force,” (3 ed.) 441, 442.
+
+[63] Registrae Criminel de Chatelet de Paris, 1, 36.
+
+[64] _Ante idem._, p. 36.
+
+[65] Register Criminal du Chatelet de Paris, 201, 209.
+
+[66] _Idem._, p. 322.
+
+[67] Lalanne, Recueil des anciennes Lois Francaisse, tome xx, pp. 284,
+etc.
+
+[68] _Ante idem._
+
+[69] Article by W. H. Davenport Adams, in Gentleman’s Magazine, Vol. 46,
+p. 506, entitled “_Pains and Penalties_.”
+
+[70] History of Jean D’Auton; Holinshed’s History.
+
+[71] Holinshed; Gentleman’s Magazine, Vol. 46, p. 371.
+
+[72] _Ante idem._
+
+[73] The Gentleman’s Magazine, Vol. 46, p. 372.
+
+[74] _Ante idem._
+
+[75] The Gentleman’s Magazine, Vol. 46, p. 370.
+
+[76] Exodus, XXI., 24; 2 Kings, XXV., 7; Rawlinson’s Anc. Mon.
+
+[77] 2 Samuel, IV., 12; Rawlinson’s Anc. Mon. iii, 7.
+
+[78] Rawlinson’s Anc. Mon. iii, 194.
+
+[79] 2 Samuel, X., 4.
+
+[80] Rawlinson’s Anc. Mon. i, 478; iii, 246; Herodotus, IV., 64.
+
+[81] Samuel, VIII., 2; XII., 31; Stanley’s History Jew. Ch.
+
+[82] Leviticus, XIX., 20. 2 Corinthians, XI., 24; Josephus, Ant. IV.,
+VIII., 21.
+
+[83] Lea’s “Superstition and Force,” (3 ed.) 375.
+
+[84] Exodus, XXI., 24; Leviticus, XXIV. 20.
+
+[85] John’s “Babylonian Laws,” etc.; Rawlinson’s _Anc. Mon._
+
+[86] Esther, VII., 8.
+
+[87] Rawlinson’s _Anc. Mon._ Josephus, _Ant._
+
+[88] John’s “Babylonian Laws,” etc.
+
+[89] Herbert’s Antiquities, p. 153; Michelet.
+
+[90] Flor. Wigorn, Annals, _Ann._ 1098.
+
+[91] Fox’s Martyrology, lib. IV., fol. 229.
+
+[92] Herbert’s Antiquities (1804), p. 154.
+
+[93] Gentleman’s Magazine, Vol. 46, p. 495.
+
+[94] _Ante idem._
+
+[95] Gentleman’s Magazine, Vol. 46, 373.
+
+[96] Rawlinson’s _Anc. Mon._ ii, 194.
+
+[97] Hastings Dict. of Bible, i, p. 523.
+
+[98] Isaiah, XLIV., 5.
+
+[99] Leviticus, XIX., 28.
+
+[100] 21 Victoria, c. 9, sec. 35.
+
+Branding was used by the American Colonists and in New England was a
+common punishment for Quakers, who were branded with red hot iron, on the
+shoulder, with a letter “H” for Heretic. (Alice Morse Earle’s “Curious
+Punishments of By-Gone Days,” pp. 138, 148.)
+
+[101] “In those days, also saw I Jews, that had married wives, of Ashdol,
+of Ammon, and of Moah.... And I contended with them, and cursed them, and
+smote certain of them, and _plucked off their hair_, and made them swear,
+by God, saying Ye shall not give your daughters unto their sons, nor take
+their daughters unto your sons, or for yourselves.” Nehemiah, XIII., 23,
+25.
+
+[102] Isaiah, L., 6.
+
+[103] 2 Mac. VII., 7.
+
+[104] Ancient Monarchies, i, 478; Layard’s Ninevah and Babylon.
+
+[105] Rawlinson’s Ancient Monarchies, iii, 246; Herodotus, iv, 64, v, 25.
+
+[106] John’s “Babylonian Laws,” etc.
+
+[107] Herodotus, _ante_.
+
+[108] Gibbon’s Rome.
+
+[109] Agathiu’s “Life of Justinian.”
+
+[110] Bertrandy’s “Un Eveque Supplicie.”
+
+[111] Martin’s “_Les Vies des Saints_.”
+
+[112] Segur’s Memoirs and Anecdotes.
+
+[113] Judges, VIII., 7.
+
+[114] Judges, VIII., 16.
+
+[115] 1 Kings, XII., 11.
+
+[116] 2 Samuel, VIII., 2.
+
+[117] 2 Samuel, XII., 31.
+
+[118] “Curious Punishments of By-Gone Days,” by Alice Morse Earle, p. 5.
+
+[119] “Curious Punishments of By-Gone Days,” by Alice Morse Earle, pp.
+17, 20.
+
+[120] _Ante idem._, p. 25.
+
+[121] _Ante idem._, p. 28.
+
+[122] The Gentleman’s Magazine, Vol. 46, p. 373; Alice Morse Earle’s
+“Curious Punishments of By-Gone Days,” pp. 29, 43.
+
+[123] The Gentleman’s Magazine, Vol. 46, p. 499.
+
+[124] Act III., Scene II. For many other references to this instrument
+of torture, by Shakespeare, see note, to section 82, in White’s “Law in
+Shakespeare,” pp. 116, 118.
+
+[125] Alice Morse Earle’s “Curious Punishments of By-Gone Days,” pp. 96,
+105.
+
+
+
+
+CHAPTER XI.
+
+WILLS, QUAINT AND CURIOUS.
+
+
+A last will and testament is the instrument whereby one disposes of his
+property, to take effect after his death.[1]
+
+The right to dispose of one’s property, by will, consistent with existing
+rules of law, is one of the results of man’s social condition, based
+upon an instinctive sentiment, akin to self love, which looks to the
+preservation and alienation, according to the intent of the owner, of the
+individual acquisitions, resulting from personal endeavor.
+
+There is a vast amount of interesting information, in connection with
+the history and forms of antique wills, and testamentary dispositions of
+property, in one form or another, are of extremely ancient origin.[2]
+
+Historians and law writers have told us that the will, as we know it,
+is a Roman invention, but in this statement the testimony of others is
+accepted as establishing the fact, rather than the knowledge, or want of
+knowledge of the fact asserted. Indeed, writers are frequently given to
+accepting and repeating the statements of others, without investigating
+the facts upon which such statements are based, much as the court
+did, that decided that a given windstorm was not a cyclone, where the
+conclusion was based wholly upon the evidence showing that the clouds
+lacked the funnel shape and circling motion, while the effect of the
+storm, evidenced by the twisted trunks of giant trees, the houses awry
+and other primary evidence of the fact asserted, was wholly over-looked,
+in reaching the conclusion.[3]
+
+There is evidence that wills were used in Egypt centuries before they
+were known in Europe;[4] Solon is said to have introduced them into
+Greece,[5] and wills were used in Rome, long before the date of the
+Twelve Tables.[6]
+
+Abraham, in his lament of the want of a legitimate heir, appointed the
+steward and servant born in his house to take his estate, after his death
+and this was, virtually, the appointment of an heir by will.[7] And the
+Hebrew Patriarch, Jacob, before taking his departure from his sons, with
+the knowledge of approaching death, said unto Joseph:[8]
+
+ “Behold, I die; but God shall be with you and bring you again
+ unto the land of your fathers. Moreover, I have given to thee,
+ one portion above thy brethren, which I took out of the land
+ of the Amorite with my sword and with my bow. And Jacob called
+ unto his sons and said, gather yourselves together, that I may
+ tell you that which shall befall you in the last days.”
+
+Of course this is but an oral bequest, but it has all the elements of
+a death-bed disposition, made under the apprehension of approaching
+death and it sets forth the “portion” to Joseph, after mentioning the
+derivation of the testator’s title, and the symbolic emblems to the other
+sons are distributed, with all the solemnity of a will, in fact.
+
+From these illustrations, it will be seen, that from the beginning of
+the history of man, as we know him, or at least in the patriarchial
+days of the ancient Hebrews, the custom obtained of making testamentary
+dispositions of property, and there is also evidence extant that this
+custom was not confined alone to the ancient Israelites.
+
+An Egyptian will, dating back to patriarchial times, was recently
+unearthed at Kahun, by the English Egyptologist, William Petrie.[9] By
+this document, written 2548 B. C. one Sekrehen, a citizen of the time of
+Amenemhat IV., settles upon his wife, Teta, all the property given him
+by his brother, for life, with a condition against the commission of
+waste, and one Siou, a lieutenant, is appointed guardian for the infant
+children. Two scribes attest the execution of this will in solemn form
+and thus we have the indisputable evidence, by this document executed
+forty-six hundred years ago, that the statement of modern historians that
+wills are of Roman origin and were invented by the clergy of mediaeval
+times,[10] is in error.
+
+The written will of the Assyrian monarch, Sennacherib, assassinated in
+the year 681, B. C., is preserved in the royal library of Kenyunjik[11]
+and in the form customarily used in that period, he bequeathed to his
+son, Esarhadden, his bracelets, coronets and other gifts of gold, ivory
+and precious stones, deposited, for safekeeping, “in the temple of Nebo.”
+
+The will of the philosopher, Plato, 348 B. C., who left “no debts,” but
+devised his farms, with a provision against alienation,[12] to his son,
+Adimantes, together with his vase, gold, cash, slaves, “also all my
+chattels, as specified in an inventory, held and possessed by Demetrius,”
+is a model of brevity and concise legal form, such as the experienced
+lawyer of today would have prepared for his client.
+
+The will of the great Aristotle, who, at sixty-eight entered upon his
+final long sleep of death, in the year 322 B. C., after appointing
+Antipater his executor, with other named friends to assist him in
+the management and care of his estate, proceeds to dispose of his
+acquisitions, in a most reasonable business-like manner, from the
+provision for his daughter, in case of her marriage, including the
+disposition of his various slaves, the finishing of his statues and the
+depositing of the bones of his wife, Pythias, in his tomb, “even as she
+desired,” to the final arrangements for the offering of the four stone
+animals, for the preservation of Nicanor, to Jupiter and Minerva, is just
+such a sane, sensible testamentary provision as one would expect from
+such an astute philosopher.[13]
+
+Virgil died ten years before Christ and his will left his manuscript of
+the Aeneid to his friends and executors, Tucca and Varus, and divided his
+property between his half-brother, Proculus and Valerius, after leaving a
+fourth to Augustus, a twelfth to Macaenas and the rest to Varus.[14]
+
+But we cannot devote more space in this chapter to the wills of the most
+gifted of men of this ancient period, however interesting it would be to
+follow the testamentary devises of the statesmen, poets and philosophers
+of the period before Christ, but to trace the origin and growth of
+English wills, with a few illustrations of the quaint and curious, will
+sufficiently lengthen the scope of the present subject-matter.
+
+Forms of testamentary disposition of personalty obtained in Great Britain
+at a very early period,[15] but until the Statute of Wills, in 1540,[16]
+there was no right of disposition by will, in England, on the part of the
+owner of real estate.[17]
+
+The Anglo-Saxon will is not a product of the Roman will at all, but
+is purely a creature of the manners and customs of the English people
+themselves.[18] In the early Anglo-Saxon law wills were unknown, but
+owed their origin to the privilege accorded the crowned heads and great
+ones to make testamentary disposition and death-bed gifts of their
+property.[19] In Cnut’s day it was not unusual for a man to make a post
+obit gift of his land or goods, and after the Norman conquest this custom
+continued and one could dispose of his land, after his death, by a
+charter, effective upon his own death, or that of his wife,[20] but the
+testamentary devise, as we know it, was not a common instrument in this
+day.
+
+After the middle of the thirteenth century the king’s court condemned
+the post obit gift of land, by charter, but allowed it only in certain
+boroughs where the custom obtained; primogeniture was held to destroy
+the existing law of succession; the church asserted the right to execute
+the last will and testament of every person and the horror of intestacy
+increased, as the church assumed the right to administer the goods of the
+deceased, for the good of his soul.[21]
+
+We read, in the old books, that a great man, Eude, died in Normandy,
+during the reign of Henry I., and made a certain division or devise of his
+property, leaving his manor to the abbey he had built at Colchester,
+with a hundred pounds and a gold ring, together with a cup and horse
+and mule; but before the King would confirm the devise of the manor, he
+compelled the surrender of the cup, horse and mule to the Crown.[22]
+
+And the post obit gift to Walden Abbey attempted by William de
+Mandeville, Earl of Essex, during the reign of Henry II. was also set
+aside by Geoffrey Fitz Peter, one of Glanville’s successors as Chief
+Justiciar,[23] under Henry II., and his successor.
+
+Of course the church-men frequently procured confirmations from the
+heirs of these post obit gifts of land to the church, by the threat of
+a dying father and the disapprobation of the church, if the gift was
+not confirmed, but in the law these gifts were not recognized, for, as
+Glanville puts it, in this period it was an axiom of the law that “God
+alone and not man can make an heir.”[24]
+
+Glanville speaks of the probate of wills, as if that mode of
+authenticating these documents had been long in use, when he wrote,
+but just when this custom was crystalized into law, in England, it is
+difficult to determine.[25] In the reign of Henry III. the ecclesiastical
+courts assumed jurisdiction in the probate of wills and soon thereafter
+attempted quite generally to enforce the execution of them in payment
+of legacies, for since the reign of Henry I., the estate of one dying
+intestate, was subject to division by those succeeding thereto, _pro
+anima ejus_.[26] The church seemed best suited to make this division,
+for the benefit of the intestate’s soul and this finally gave rise to
+the grant of letters by the ordinary to the next of kin, from which
+the custom of issuing letters of administration no doubt arose, in
+after-times.[27]
+
+The church continued to execute the powers concerning wills and the
+estates of decedents—and this is no doubt the reason why Glanville and
+Bracton do not treat at length of wills, further than to mention the
+custom, in certain boroughs, of devising land by will[28]—until the
+people complained of oppression by the bishops and ordinaries in the
+exaction of fines for probating wills, when the statute of 31 Edward
+III., was enacted, giving the justices of the king’s court jurisdiction
+to enquire into such exactions and oppressions, either at the instance
+of the king, or that of the injured person.[29]
+
+Having thus assumed the jurisdiction over the estates of deceased
+persons, by this statute, which was the entering wedge to oust the
+jurisdiction of the ecclesiastical courts, in the gradual processes of
+time, the courts learned in the law, instead of those concerned only
+about spiritual affairs, assumed larger control and jurisdiction over the
+estates of decedents. While the church retained control over the estates
+of decedents, the bishop exercised practically the same authority that
+the probate judge exercises under our law, in the granting of letters
+of administration, the listing and inventorying of the property and
+the accounting by the trustee to the ordinary, granting the letters of
+administration.[30]
+
+From the delegation of the trust to some personal friend to carry out
+the will of the decedent, the clergy, in compelling fidelity in the
+performance of the trust, no doubt developed that particular kind of a
+trustee known to our law of today as an executor or administrator and
+with the appearance of this legal personality, the devise may be said to
+first legally assume the dignity analogous to our present testamentary
+devise.[31]
+
+One of the earliest wills, with executors, that the older books refer
+to, is that of King Henry II.,[32] made at Waltham, in the year 1182 in
+the presence of ten witnesses, among whom we note the name of Ranulf
+Glanville, his justiciar, the author of the first English law book. The
+English bishops and Glanville were to make division among the religious
+houses of five thousand marks; Norman bishops were to make division
+of certain sums among Norman elemosinary institutions; his sons were
+charged with the distribution of a fund to be expended in providing
+marriages for poor free women; God’s curse was invoked upon all those
+who violate his laws and the Pope was said to have confirmed the devise,
+no doubt because all the legacies were for pious purposes. The will,
+however, had executors,[33] for one set of the trustees looked after
+the English behests; another set after the Norman legacies; others,
+still, those left to institutions in Maine and Anjou, and all of these
+several executors, save only Glanville, were from among the clergy, and
+this evidences the high regard in which this monarch held his learned
+justiciar.
+
+But few of the thirteenth century wills have come down to us, although
+we have an ampler supply in the fourteenth century. In the thirteenth
+century, the will was usually made in Latin and wills written in the
+English language first began to appear generally in the second half of
+the fourteen century.[34]
+
+In the year 1268, or the 53 year of Henry III., William de Beauchamp
+executed a will[35] that looks very like the modern documents, except
+that it only provided for specific legacies and behests of personalty
+other than to the church. It provided that his horse, fully harnessed,
+with all military caparisons, should precede the hearse bearing his
+corpse; provided for masses for his soul; gave a house to the church for
+his own soul and that of his wife; a behest to his son, Walter, to defray
+his expenses in a pilgrimage to the holy-land; to his daughter, Joane,
+a canopy and a book of Lancelot; a silver cup to his daughter Isabel,
+rings for his friends, with small legacies to others and a house for the
+church, are the principal features of this ancient will. The testator
+finally closed this interesting old will, in the following form:
+
+ “And I appoint my eldest son, William, Earl of Warwick, Sir
+ Roger Mortimer, Sir Bartholomew de Sudley, and the Abbots of
+ Evesham and of Great Malverne, my executors.”
+
+So here we have, in modern form, the recognition of the custom to appoint
+executors, by testamentary devise, just as today.
+
+Primogeniture, under the feudal law of the middle ages, in England,
+created the necessity for wills of real estate, for although all children
+of the Germanic races took equally and this was true, at Rome, under
+the feudal law all the children were practically disinherited in favor
+of the eldest son; some method of devising the estate to the eldest son
+was essential, on the part of the testator of real estate, so the Clergy
+adopted the Roman will as the instrument for accomplishing the purpose
+and thus it is sometimes called “an accidental fruit of feudalism.”[36]
+
+The liberty taken by the Church with the estates of deceased persons was
+a matter of such scandal and oppression, during the reigns of Henry III.
+and Edward II., that Parliament on several occasions imposed rules for
+the government of the bishops in the administration of the estates of
+intestates. Executors were required, during the reign of Henry III., to
+make a true inventory of the property of the deceased, and exhibit it to
+credible persons, acquainted with the property of the deceased,[37] and
+this is no doubt, the foundation for this provision of our modern law,
+requiring inventories, in such cases.
+
+During the reign of Edward IV. the _testamentum_ and _ultima voluntas_
+came to be regarded in much the same legal aspect, although the former
+was the more solemn act and the execution of the testament was always in
+accordance with the forms prescribed in the older law books and if these
+preliminaries were omitted it was but a mere _ultima voluntas_.[38]
+
+In the reign of Edward VI. the reformers of that period objected to the
+promiscuous use of wills by all classes, so an act was passed preventing
+the execution of wills by wives, _servi_, by minors under fourteen, by
+heretics, criminals, condemned to death, exile, or chains; those who did
+not dismiss their concubines before they were in extremis, people with
+two wives or husbands, libelers, prostitutes or procuresses and usurers.
+The indulgence was granted to those keeping concubines, however, and to
+those with two wives or husbands—perhaps because of the leniency with
+which such crimes were looked upon at this period—of disposing of their
+goods _in pias causas_, or for the relief of the poor, afflicted, for
+young women, the support of students and the reparation of highways.[39]
+
+Under the old law, the division of the decedent’s property, whether by
+will or otherwise, was one-third to his wife, a third to his children
+and the other third, the owner himself could dispose of. If no will was
+left, the wife and children took their one-third each and the rest was
+divided by the administrator. If no children survived, the widow took
+half and the owner could dispose of the other half, or, if the owner died
+intestate, the administrator disposed of the remaining half and the same
+was true, if there were no children, but a widow survived.[40]
+
+The modern statutes of descents and distributions, in the United States,
+are no doubt founded upon the customs, which had taken the fixed form of
+law, at this early period of English history.
+
+In the written English wills that have come down to us, from the middle
+ages, we find the dispositions of property governed, largely, by the
+customs and laws of the period when the will was written and the forms
+and dispositions of property devised by these instruments is as varied as
+the imaginations and whims of the testators.
+
+The will of Guy de Beauchamp, Earl of Warwick, dated at Warwick Castle,
+Monday, next after the feast of St. James, the Apostle, 1315, provided
+for the interment of his body in the Abbey of Bordsley, without funeral
+pomp. To Alice, his wife, he left a portion of his plate, a crystal cup
+and half his bedding, with all the books in his chapel; to his daughters,
+he left the other half of his bedding, rings and jewels; to his son,
+Thomas, he left his best coat of mail, helmet and suit of harness, and to
+his son, John, he left his second best coat of mail, helmet and harness,
+and the remainder of his armour, bows, and other warlike implements were
+to remain in Warwick castle, for his heir.[41]
+
+Noticeable among the wills of the fourteenth century is the specific
+provision for the place and manner of the interment of the body of the
+deceased. The testators of this period of the world’s history, prompted
+by their superstition, wrote their wills as if they thought that the
+angel of the Lord, on the resurrection day, would scan their wills, to
+find the place of their interment. They talked “of graves, of worms, and
+epitaphs,” just as the Great Bard makes the weak King Richard speak, who
+had naught to bequeath, save his deposed body “to the ground.”[42]
+
+We find that old John of Gaunt, Duke of Lancaster, in 1399, directs, in
+his will,[43]
+
+ “If I die out of London, I desire that the night my body
+ arrives there it be carried direct to the Friars Carmelites, in
+ Fleet Street, and the next day be taken straight to St. Paul’s,
+ and that it be not buried for forty days, during which I charge
+ my executors that there be no embalming of my corpse.”
+
+Sir Walter Manney, on St. Andrew’s day, in 1371, in London, provided for
+his interment, “at God’s pleasure,” in the midst of the Quire of the
+Carthusians, near Smithfield, in the suburbs of London, without any great
+pomp. He directed twenty masses be said for his soul and that every poor
+person attending his funeral, be given a penny to say a prayer for his
+soul and the remission of his sins. He left ten pounds to his sister, the
+nun, Mary; left a provision for each of his two bastard daughters and to
+his dear wife, the plate which he bought of Robert Francis, also a girdle
+of gold, a garter of gold and all of his beds and girdles, except his
+folding bed, which he left to his daughter of Pembroke. He willed that a
+tomb of alabaster with his own image thereon, as a knight and his arms
+thereon should be constructed, like unto that of Sir John Beauchamp, at
+Paul’s London, and that prayers should be said for his soul and also for
+that of Alice de Henalt, the Countess Marshal and Sir Guy Bryan, Knt.,
+was appointed executor of his will.[44]
+
+Queen Katherine of Aragon, wife of Henry VIII., who died in 1536, after
+providing for the burial of her body in the Convent of Observant Friars,
+supplicated the King in her last will,[45] to return the property that
+she had brought to him from Spain, out of which she stipulated for
+the payment of the annual wages due her physician, her druggist, her
+laundress, goldsmith and tailor; she left the collar of gold she had
+brought from Spain to her daughter and provided for masses for her soul
+and legacies to different priests and lady friends.
+
+Harris, in his recent book on “Ancient, Curious and Famous Wills,”[46]
+reproduces, verbatim, many curious and strange testaments, evidencing the
+weaknesses, humors, whims and caprices, and sometimes, even the vengeance
+of the various testators, whose wills he has collected.
+
+William Pym, for instance, a gentleman of Somerset, England, who crept
+to his long sleep of death on January 10’, 1608, after providing for
+different charitable behests, thus speaks of his wife, in his will:[47]
+
+ “I give to Agnes, which I did a long time take for my wyfe—till
+ she denyd me to be her husband, all though wee were marryd
+ with my friends’ consent, her father, mother, and uncle at
+ it; and now she sweareth she will neither love mee nor evyr
+ bee perswaded to, by preechers, nor by any other, which hath
+ happened within these few years. And Toby Andrewes, the
+ beginner, which I did see with mine own eyes when he did more
+ than was fitting and this, by means of others, their abettors.
+ I have lived a miserable life this six or seven years, and now
+ I leve the revenge to God—and ten pounds to buy her a gret
+ horse, for I could not, this menny years, please her, with one
+ gret enough.”
+
+Dispositions of property for the use and benefit of horses and other
+domestic animals are not uncommon, in the list of quaint and curious
+wills to be met with by the student of ancient testaments.
+
+Harris cites the curious will of a childless peasant, who died near
+Toulouse, in 1781, by the terms of which he left his house and land and
+other property to his riding horse, in these words:
+
+ “I declare that I appoint my russet cob my universal heir, and
+ I desire that he may belong to my nephew, George.”
+
+Upon the will being brought before the court for construction, it was
+held that the intent of the testator would be given effect and the horse
+and the bequests he had bestowed upon it, would go to the nephew named in
+the will.[48]
+
+Madame Dupuis, who died in 1677,[49] left a legacy of a fixed amount to
+her executor, with a detailed menu for her cats, which her sister and
+niece were to visit three times a week to see that at least thirty sous a
+week were expended for their living and care.
+
+As an illustration of the generosity and magnanimity of certain Jews,
+the will of the wealthy Israelite, Pinedo, who died at Amsterdam, in the
+eighteenth century, is not without interest. He left to the city of
+his adoption, five tons of gold; to every Christian church in Amsterdam
+and at the Hague, the sum of 10,000 florins each; to each Christian
+orphanage in these two towns, 10,000 crowns; to the poor of Amsterdam,
+forty shiploads of peat; to his synagogue two and a half tons of gold; he
+lent to the government, at three per cent, ten tons of gold, on condition
+that the interest should be paid to the Jews domiciled at Jerusalem; he
+then left certain legacies to his wife and nephew and other members of
+his family and to every unmarried person of either sex, attending his
+funeral, 100 florins; to every Christian priest at Amsterdam and the
+Hague, 100 crowns and to every sacristan, fifty crowns.[50]
+
+Space will not permit the long list of charitable and philanthropic
+devises that could be collated from ancient and mediaeval times, which
+many of the testators of today would do well to emulate.
+
+John Wardell, of London, by his will dated August 29’, 1656, devised
+his tenement, called the “White Bear,” in trust, to light the travelers
+passing to and fro along the watersides.[51]
+
+Charles Jones, of Lincoln’s Inn, by will dated January 17’, 1640,
+established a charitable trust for the maintenance of a house to be used
+as a hospital, near Pullhelly, for twelve poor men.[52]
+
+George Butler, of Coleshill, Warwickshire, by his testament dated
+September 2’, 1591, gave his house in trust for the lodgment of “any
+poor travelers” who should desire lodgment, not to exceed one night.[53]
+
+And Valentine Goodman, of Hallaton, England, by his will in 1684,
+left eight hundred pounds to be invested and the interest spent for
+the benefit of the “most indigent, poorest, aged, decrepit, miserable
+paupers.”[54]
+
+Among the freakish wills collected by Harris, may be mentioned that of
+the nobleman of the house Du Chatelet, who died in 1280,[55] and directed
+that one of the pillars of the church at Neufchateau should be hollowed
+out and his body stood upright therein, so that the vulgar might not walk
+upon his corpse.
+
+The strange request of the great English jurist, Jeremy Bentham,[56] that
+his corpse might be embalmed and placed in his favorite chair at the
+banquet table of his friends, on all occasions of state, was carefully
+carried out by his friend, Dr. Southwood Smith. By some scientific
+process the body of the philosopher and law writer was preserved, by a
+French artist and in his usual suit of clothes, with his broad-brimmed
+sombrero and his favorite walking-stick, in his old armed-chair, the
+lifeless body of this gifted man graced the meetings of his friends,
+until it was removed by Dr. Smith to University College.
+
+The will of the great Bard of Avon, has been discussed so frequently
+that its terms are known to many, but as the last writing of the Poet,
+like everything connected with his life, it is always of interest to
+posterity.
+
+The first paragraph of his will, along with the many other prayers and
+Bible references which he places in the mouths of his characters in the
+plays,[57] evidences the Poet’s firm belief in Jesus Christ and the “life
+everlasting.”
+
+In the entailment of his real estate to the bodily heirs male of his
+daughters, this will evidences the most careful legal preparation and
+the conclusion is not unreasonable that the same discrimination which
+characterizes this disposition of his real estate and other property,
+recognized the futility of any attempted disposal of his literary
+productions, which lacked the attribute of property, in law, in England,
+until 1709.[58]
+
+His legacies to his sister and his nieces and nephews is characteristic
+of his deep affection for his own family; his benevolence is established
+by his bequests to the “poor of Stratford”; his good-fellowship and love
+for his friends by the many legacies for rings for his different friends;
+his indifference toward his wife, by the fact that he only left her his
+“second best bed, with the furniture,” while all his landed acquisitions,
+with his gold and silver plate and other property were distributed among
+his sisters, daughters, nieces and nephews and his trust and confidence
+in his daughter, Susanna Hall, and her husband, John Hall, is finally
+established by the fact that he made them his executors and trustees.[59]
+
+The wills of the statesmen and patriots of the past century, in our own
+country are equally interesting with those of our brothers of yesterday
+across the sea.
+
+After leaving his land in Nova Scotia, with his books and the debts owing
+to him by his son, William Franklin, former Governor of the Jerseys, the
+great statesman, philosopher and patriot, Benjamin Franklin, referred
+to his son’s part in attempting to deprive him of his property, during
+the war, as an excuse for not leaving him more of his estate. He left
+his dwelling house and three new houses, printing office, silver plate
+and household goods, to his daughter, Sarah Bache, and her husband, in
+entirety with remainder to their heirs, “as tenants in common and not
+as joint tenants.”[60] The picture of the king of France, set with four
+hundred and eight diamonds, he left to his daughter, with the admonition
+not to use the diamonds to make ornaments for herself, so as not to
+thereby “introduce the expensive, vain and useless pastime of wearing
+jewels in this country.” He desired his philosophical instruments in
+Philadelphia, to go to his ingenious friend, Francis Hopkinson, and by
+a codicil, he left his “fine crab-tree walking-stick” to his friend and
+“the friend of mankind, General Washington. If it were a sceptre, he
+has merited it and would become it. It was a present to me from that
+excellent woman, Madame de Forbach, the Dowager Duchess of Deux Ponts,
+connected with some verses, which go with it.” He left a bond to his
+son-in-law, on the condition that he manumit and set free his negro man.
+This great patriot and friend of mankind, like General Washington, in his
+last testament, therefore, registered his opposition to human slavery,
+an institution that was to be finally abolished a half century later in
+the United States, through the efforts of the great “Emancipator.”
+
+The will of the great Chief Justice John Marshall, is declared by him
+to be “entirely in my own handwriting”; he left his estate equally to
+his only daughter and his five sons and accompanying the will is a
+splendid eulogy to his deceased wife, whom he characterized as the “most
+affectionate of mothers.”[61]
+
+The will of Captain Miles Standish, Longfellow’s hero, was made March
+7’, 1656. He desired his just debts to “bee paied”; that his body
+should be “buried in Decent manor ... as near as conveniently may bee
+to my two daughters, Lora Standish, my daughter, and Mary Standish, my
+daughter-in-law.” His dear and loving wife, Barbara Standish, was left
+a third of his estate; forty pounds were left to each of four sons and
+to his son Josias, upon his marriage, he left “one young horse, five
+sheep and two heifers,” with his forty pound legacy, if his estate “will
+bear it att p’sent.” His friends, Mr. Timothy Hatherly and Capt. James
+Cudworth, were appointed “supervisors” of his will, for he knew that they
+would “be pleased to Doe the office of Christian love to bee healpfull to
+my poor wife and Children by their Christian Counsell and advice.”[62]
+
+The “Father of our Country,” General George Washington, left the bulk
+of his estate to his wife, Martha Washington, for life,[63] with the
+“liquors and groceries” on hand at his death, to dispose of as she saw
+fit. Upon her death he willed that all slaves owned by him, in his own
+right, should have their freedom and that the old and infirm and sick
+ones should be protected and maintained by his heirs so long as they
+lived and the younger ones educated and maintained the same as other poor
+children.
+
+He left the fifty shares in the Potomac Company, given him for his
+services in the Revolutionary War, to endow a University within the
+limits of the District of Columbia; some of his lands were distributed
+among the sons of his deceased brothers; his military and state papers
+were left to his nephew, Bushrod Washington; he recommitted the “box
+of oak that sheltered the great Sir William Wallace,” to the Earl of
+Beuban; to his brother, Charles, he left the gold headed cane left him by
+Dr. Franklin and among the “mementos of esteem and regard,” to his many
+friends, are a pair of pistols to General De La Fayette. He desired that
+in case of any dispute over his will that the disputants select each an
+arbitrator, the two thus selected to agree upon a third and the finding
+of any two as to his intentions, he desired to be “as binding upon the
+parties as if it had been given in the Supreme Court of the United
+States.”
+
+Like Washington, and many other of the patriots of the past century,
+William Penn prepared his own will, in 1718, so as to cause no little
+concern to his friend, James Logan, as to the different constructions
+that could be placed upon it.
+
+The Government of the Province of “Pennsylvania and territories thereto
+belonging,” he devised in trust to the Earls of Oxford, Mortimer and
+Powelett, “and their heirs, upon trust, to dispose thereof to the Queen”
+or to any other person to the best advantage to carry out the object of
+the devise.
+
+He further devised to his wife, Hannah Penn; to her father, Thomas
+Callowhill; to his sister, Margaret Lowther; to his friends “Gilbert
+Heathcote Physitian, Samuel Waldenfield, John Field, Henry Gouldney,
+all living in England” and to his friends, Samuel Carpenter, Richard
+Hill, Isaac Norris, Samuel Preston and James Logan, “liveing in or near
+Pensilvania and their heires” all his lands, tenements and hereditaments,
+with “other profitts scituate, lyeing and being in Pensilvania and the
+territores thereunto belonging,” in trust, first for the payment of his
+debts, second, to convey 10,000 acres each to the three children of his
+son, William, a like quantity to his daughter, Aubrey, and the rest to
+be divided among the children of his present wife, “in such proporcon
+and for such estates as my said wife shall think fit.” His wife was made
+executrix and all his personal estate was left to her.
+
+Penn was a man of far more than the ordinary ability and wisdom in the
+customary affairs of life, but as his friend, James Logan, foresaw, from
+the contents of this will, which left such a large and varied estate
+to so many people to convey, with so little instructions regarding his
+intentions, it is not strange that litigation covering a period of nine
+years should have resulted from such a testament.[64]
+
+The searcher for the curious in testaments, will find wills in poetry as
+well as in prose, collated in Harris’ Ancient Wills.
+
+William Jackett, of the parish of St. Mary, Islington, died in 1789 and
+his will in the following form was admitted to probate:
+
+ “I give and bequeath,
+ When I’m laid underneath,
+ To my two loving sisters most dear,
+ The whole of my store,
+ Were it twice as much more,
+ Which God’s goodness has given me here.
+
+ And that none may prevent
+ This my will and intent,
+ Or occasion the least of law-racket,
+ With a solemn appeal
+ I confirm, sign and seal
+ This, the true act and deed of Will Jackett.”[65]
+
+William Hicklington, who dubbed himself, the Poet of Pocklington, penned
+his will in rhyme, in 1770, as follows:
+
+ “Do give and bequeath,
+ As free as I breathe,
+ To thee, Mary Jarum,
+ The Queen of my Harum,
+ My cash and my cattle,
+ With every chattel,
+ To have and to hold,
+ Come heat or come cold,
+ _Sans_ hindrance or strife,
+ Though thou art not my wife,
+ As witness my hand,
+ Just here as I stand,
+ The twelfth of July,
+ In the year seventy.”[66]
+
+Apropos this will, is the rhymed testament of the sacriligious Irishman,
+who, as the old books record, in this quatrain disposed of his earthly
+effects:
+
+ “In the name of God, Amen:
+ My featherbed to my wife Jen;
+ Also my carpenter’s saw and hammer;
+ Until she marries; then, God damn her.”[67]
+
+This, however, suggests the “Will in literature,” and in turning over
+the pages of the work above referred to, the “Lesser Testament,” of
+the plaintive poet, Francois Villon, who died in 1484, is not without
+interest.
+
+His gloves and silken hood are bequeathed to a friend in the following
+verse;
+
+ “Item, my gloves and silken hood
+ My friend Jacques Cardon, I declare,
+ Shall have in fair free gift for good;
+ Also the acorns willows bear
+ And every day a capon fair
+ Or goose; likewise a tenfold vat
+ Of chalk-white wine, besides a pair
+ Of Lawsuits, lest he wax too fat.”
+
+He desired his friends to record of him in his epitaph:
+
+ “Acre or furrow had he none.
+ ’Tis known his all he gave away;
+ Bread, tables, tressels, all are gone,
+ Gallants, of him this Roundel say.”[68]
+
+Among the wills in fiction and poetry, collated by Mr. Harris, in his
+recent work,[69] are those of Olivia, in Twelfth Night; that of Don
+Quixote; the wills of Dickens, George Eliot, Dumas and other English
+writers. But it is not the object of this chapter to deal with wills in
+fiction, since testaments are founded in certainties, as real as life
+and death themselves. We have always made our wills in pursuance of a
+natural inclination, associated with the idea of property and intimately
+connected with the ties that bind us here on earth. As Hazlitt said, a
+century ago:
+
+ “We consign our possessions to our next of kin, as mechanically
+ as we lean our heads on the pillow and go out of the world in
+ the same state of stupid amazement that we came into it.”
+
+And as certain as we are to die, so certainly do we owe it to ourselves
+and to those who are the objects of our bounty, to provide for the proper
+disposition of our acquisitions, even as the men and women of antiquity
+did, before they pressed the pillow for the last time.
+
+The hands that wrote the wills referred to in the foregoing pages have
+been stilled with the silence of the centuries, e’en as the fingers
+that wove the figures in your antique rug; the voice that expressed the
+dying intent of the testator, like the nightingale that sang among the
+trees—ah, “whither hath it gone again, who knows” can be heard again
+no more. Like scattered threads from the warp and woof of the lives
+from which these skeins are taken, each age-scented document marks the
+close of a human life and the fact that other lives have fallen, like
+the leaves from trees, but emphasizes the pathos of our lives, since
+humanity, as one man, with a universal agony still strives and strains
+“to gain the goal where agonies shall cease to be.” Streams have been
+wept into the vast ocean of time since the first will and testament was
+made by dying man.
+
+ “A myriad races came and went; this Sphinx hath seen them come
+ and go.”
+
+True, a human life, is but “a drop in ocean’s boundless tide,” but as
+truly said by Burton:[70]
+
+ “Our deaths are twain; the Deaths we see
+ Drop like the leaves in windy Fall;
+ But ours, our own, are ruined worlds, a globe
+ Collapst, last end of all.
+
+ We live our lives with rogues and fools,
+ Dead and alive, alive and dead,
+ We die ’twixt one who feels the pulse and
+ One who frets and clouds the head.
+
+ Hardly we learn to wield the blade, before
+ The wrist grows stiff and old;
+ Hardly we learn to ply the pen, ere Thought
+ And Fancy faint with cold.
+
+ And still the weaver plies his loom, whose
+ Warp and woof is wretched Man
+ Weaving th’ unpattern’d dark design, so dark
+ We doubt it owns a plan.
+
+ But ah, what vaileth man to mourn; shall
+ Tears bring forth what smiles ne’er brought;
+ Shall brooding breed a thought of joy? Ah
+ Hush the sigh, forget the thought.
+
+ Silence thine immemorial quest, contain
+ Thy nature’s vain complaint
+ None heeds, none cares for thee or thine;
+ Like thee how many came and went.
+
+ ...
+
+ Wend now thy way, with brow serene, fear
+ Not thy humble tale to tell:—”
+ ’Tis wisdom’s part to make thy will;
+ The testament is not death’s knell.
+
+
+FOOTNOTES:
+
+[1] 1 Redfield, on Wills, Ch. II., p. 4; 2 Bl. Comm. 499.
+
+[2] Redfield, on Wills, Ch. I., p. 1; Harris, Ancient Wills. Introd. XII.
+
+[3] Judge John F. Philips advised the writer that an opinion was prepared
+by a member of the federal court and submitted to him for his concurrence
+when he was on the bench, in a case similar to that referred to in the
+text, but it was changed when the attention of the writer was called
+to the existing facts, which the opinion failed to note. It is to be
+regretted that historians and law writers cannot so amend their works.
+
+[4] Harris, Ancient Wills, p. 12.
+
+[5] Plutarch’s Life of Solon; IV. Kent’s Comm. 503.
+
+[6] Chitty’s note, to 2 B. Comm. 491.
+
+The reason for recognizing, in law, a right of disposition of property
+by will, is the same as the law governing the descent and distribution,
+in case of intestacy. If there were no such provision, on the vacancy of
+the property, on the death of the last owner, an unseemly scramble would
+result, which would be both undesirable and contrary to a sound public
+policy. “Title,” or authority to make a will, is thus based upon the
+social instinct and both wills and intestacy statutes are in furtherance
+of this purpose. The owner, in case of a testamentary devise and the
+State, in case of intestacy, as a mediary, accomplish practically the
+same purpose, in the division of property, the prevention of a vacancy
+and the failure of the social instinct, which furnishes the foundation
+for society and order. (See interesting Essay by Professor Bigelow, in
+III. Essays in Anglo-American Legal History, pp. 776, 778.)
+
+[7] Genesis, Ch. XV.
+
+[8] Genesis, 48 and 49 Chapters.
+
+[9] Harris, Ancient Wills, p. 12.
+
+[10] I. Reeve’s History English Law, 313; II. Pollock and Maitland’s
+History English Law, p. 314.
+
+[11] Harris, Ancient Wills, p. 13.
+
+[12] Harris, Ancient Wills, p. 14.
+
+[13] Harris, Ancient Wills, pp. 15, 16.
+
+[14] Harris, Ancient Wills, p. 16.
+
+[15] 2 Bl. Comm. 491.
+
+[16] 32 & 34 Henry VIII.
+
+[17] I. Redfield, on Wills, sec. 4, p. 2; II. Pollock and Maitland’s
+History English Law, p. 315; IV. Reeve’s History English Law, 510, 511.
+
+[18] II. Pollock and Maitland’s History English Law, pp. 316, 317.
+
+[19] II. Pollock and Maitland’s History English Law, p. 322.
+
+[20] _Ante idem._, p. 323.
+
+[21] II. Pollock and Maitland’s History English Law, pp. 325, 326.
+
+The statute of wills ordained that all persons having manors, lands,
+tenements or hereditaments could give and dispose of them, as well by
+last will, or testament in writing, as by any act executed in their
+lifetime. (IV. Reeve’s History English Law, p. 374.)
+
+[22] II. Pollock and Maitland’s History English Law, p. 326.
+
+[23] II. Pollock and Maitland’s History English Law, p. 327.
+
+[24] _Ante idem._; Beame’s Glanville, p. 118.
+
+[25] I. Reeve’s History English Law, p. 313.
+
+[26] I. Reeve’s History English Law, p. 313.
+
+[27] I. Reeve’s History English Law, p. 314.
+
+[28] III. Reeve’s History English Law, 215.
+
+[29] III. Reeve’s History English Law, 125.
+
+[30] IV. Reeve’s History English Law, 123, 124.
+
+[31] II. Pollock and Maitland’s History English Law, p. 335.
+
+[32] Nicholas’ “Testamenta Vetusta.”
+
+[33] II. Pollock and Maitland’s History English Law, pp. 334, 335.
+
+[34] II. Pollock and Maitland’s History English Law, p. 337.
+
+[35] Harris, Ancient Wills, p. 22.
+
+[36] Maine, Ancient Law, ch. 7, p. 217; III. Essays in Anglo-American
+Legal History, pp. 780, 781.
+
+[37] IV. Reeve’s History English Law, p. 115.
+
+[38] IV. Reeve’s History English Law, 117.
+
+[39] V. Reeve’s History English Law, pp. 81, 82.
+
+[40] V. Reeve’s History English Law, p. 82.
+
+[41] Harris, Ancient Wills, p. 25.
+
+[42] King Richard II., Act II., Scene I.
+
+[43] Harris, Ancient Wills, p. 25.
+
+[44] Harris, Ancient Wills, p. 29.
+
+[45] Harris, Ancient Wills, p. 39.
+
+[46] Published by Little, Brown & Co., 1911.
+
+[47] Harris, Ancient Wills, p. 87.
+
+[48] Harris, Ancient Wills, p. 94.
+
+[49] _Ante idem._, 101.
+
+[50] Schutt’s Memorabilia Judaica, lib. iv, cap. 18.
+
+[51] Harris, Ancient Wills, p. 105.
+
+[52] _Ante idem._, p. 105.
+
+[53] _Ante idem._, p. 107.
+
+[54] _Ante idem._, p. 111.
+
+[55] _Ante idem._ p. 123.
+
+[56] _Ante idem._ p. 139.
+
+[57] For collection of the many beautiful prayers in the plays, see the
+interesting book by Mary A. Wadsworth, “Shakespeare and Prayer,” by The
+Welch Publishing Co., Chicago.
+
+[58] White’s “Law in Shakespeare,” p. 5.
+
+[59] Harris, Ancient Wills, pp. 305, 309.
+
+[60] Harris, Ancient Wills, p. 369.
+
+[61] Harris, Ancient Wills, p. 407.
+
+[62] Harris, Ancient Wills, p. 427.
+
+[63] Harris, Ancient Wills, p. 439.
+
+[64] Dixon’s “Life of Penn”; Stoughton’s “William Penn”; Harris, Ancient
+Wills, p. 291.
+
+The will of Penn, and other of the earlier patriots of the United
+States who drew their own wills, in such manner as to cause protracted
+litigation, suggests the old poem, tuned to the toast of a century ago,
+“The lawyer’s best friend—the man who makes his own will,” inscribed to
+“The jolly testator who makes his own will.”
+
+ “He premises his wish and his purpose to save
+ All dispute among friends when he’s laid in his grave;
+ Then he straightway proceeds more disputes to create
+ Than a long summer’s day would give time to relate.
+ He writes and erases, he blunders and blots,
+ He produces such puzzles and Gordian knots,
+ That a lawyer, intending to frame the thing ill,
+ Couldn’t match the testator who makes his own will.
+ ...
+ You had better pay toll when you take to the road,
+ Than attempt by a by-way to reach your abode;
+ You had better employ a conveyancer’s hand,
+ Than encounter the risk that your will shouldn’t stand.
+ From the broad beaten track, when the traveler strays,
+ He may land in a bog, or be lost in a maze;
+ And the law, when defied, will avenge itself still,
+ On the man and the woman who make their own will.”
+
+For reproduction of this quaint poem in full, see, Harris, Ancient Wills,
+p. 209.
+
+[65] Harris, Ancient Wills, p. 67.
+
+[66] Harris, Ancient Wills, p. 67.
+
+[67] _Ante idem._ 68.
+
+[68] Harris, Ancient Wills, p. 64.
+
+[69] Harris, Ancient Wills, pp. 49, 62.
+
+This bequest of Francois Villon, may have suggested to Mr. Williston
+Fish of Chicago, the “Insane Man’s Will,” published in Harper’s Weekly,
+in 1898, wherein he makes an imaginary will that has become a classic
+in English literature, among the bequests being “all good little words
+of praise and encouragement,” to good fathers and mothers, in trust for
+their children; to children, subject to the rights of lovers, he devises,
+the flowers, the banks of brooks, the blossoms of the woods, the golden
+sands and waters of the brooks, the white clouds floating high over the
+giant trees and the Milky Way, to wonder at, at night; to lovers, he
+devises the imaginary world, with the stars in the sky, the red roses
+by the wall, the sweet strains of music and all else by which they
+may figure to each other the lastingness and beauty of their love. To
+those no longer children or lovers, he bequeaths the pleasures of sweet
+memories, the poems of Burns and Shakespeare and other poets, and to
+those with snowy crowns he leaves the happiness of old age, with the love
+and gratitude of their children, until they fall asleep.
+
+[70] “The Kasidah.”
+
+
+
+
+INDEX.
+
+_References are to Pages_
+
+
+ A
+
+ Abjuration, in case of sanctuary, 250.
+
+ Adonijah, sanctuary claimed by, 245, 246.
+
+ Adulteress, lost dower, in England, 26.
+
+ Agrippina, her marriage to Claudius, 18.
+
+ Alcibiades, recall of, 83.
+
+ Alexander III., decree concerning consent marriages, 22.
+
+ Alfred, administration of justice under, 89, 90.
+
+ Alfred, jury trials under, 151.
+
+ Alfred, sanctuary under, 251.
+
+ Alfred, wager of law, under, 197.
+
+ Amber witch, 71.
+
+ Ancient punishments (see punishment), 273, 306.
+
+ Anglo-Saxon courts, 90.
+
+ Anglo-Saxon law against witchcraft, 49.
+
+ Anglo-Saxon wills, 312.
+
+ Anglo-Saxons, judicial recall under, 88, 90.
+
+ Anglo-Saxons, recognized sale-marriages, 20.
+
+ Animals, wills to, 322.
+
+ Appellee, meaning of, in trial by battle, 115.
+
+ Approver, in trials for felony charges, 117.
+
+ Aristeides, recall of, 83.
+
+ Aristotle, on judicial recall, 82, 86.
+
+ Aristotle, will of, 310.
+
+ Arrowsmith, case of, Anthony, 183.
+
+ Arthur, king, and Flollo, trial by battle between, 127.
+
+ Ashford, trial by battle with Thornton, 133.
+
+ Assize, a substitute for battle, under Henry II., 119.
+
+ Assyrian marriages, 13.
+
+ Astrology in mediaeval times, 49.
+
+ Athelstan, laws of, governing ordeals, 149.
+
+ Athelstan, sanctuary, under, 252.
+
+ Athenian judges, recall of, 83.
+
+ Athens, recall in, 81.
+
+ Attainder, standing mute to avoid, 173.
+
+ Aunts and nephews, marriages between, 18.
+
+ Authorities upon witchcraft, 70.
+
+
+ B
+
+ Babylon, effect of recall in, 103, 104.
+
+ Babylon marriages, 13.
+
+ Babylon, trials in ancient, 79.
+
+ Babylon, wager of law, in ancient, 197.
+
+ Babylonian judges (note), 74.
+
+ Balance, ordeal by, 143.
+
+ Banishment, in ancient Greece, 82.
+
+ Banns, custom of, 21.
+
+ Banns, legal advantages of, 22.
+
+ Barabas, release of, by Pilate, 102.
+
+ Battle, trial by, 109, 140.
+
+ Battle, origin of trial by, 109.
+
+ Battle, traced to ancient periods, 109.
+
+ Battle, regulated by Burgundians, 501 A. D., 111.
+
+ Battle, regulated by Otho, in 983 A. D., 112.
+
+ Battle, adjudged legal method of trial by Ld. Ellenborough, 133.
+
+ Battle, intended to prevent perjury, when established, 112.
+
+ Battle, London exempted from, by charter, 119.
+
+ Battle by use of “Approvers”, 117.
+
+ Battle, under military form, 125, 126.
+
+ Battle, in case William of Eu, 126.
+
+ Battle, in finance, 118.
+
+ Battle, in trials on debt, 119.
+
+ Battle, under writ of right, in full, 120, 122.
+
+ Battle, trial before Henry III., 129.
+
+ Battle, trial before Henry VI., 131.
+
+ Battle, discouraged by Edward III., 118.
+
+ Battle, trial by, before Henry VII., 132.
+
+ Battle, under felony charge, 116.
+
+ Battle, superceded by assize, under Henry II., 119.
+
+ Battle, under charge of treason, 116.
+
+ Battle between Hereford and Norfolk, 130.
+
+ Battle, introduced into England by Normans, 114.
+
+ Battle, between King Arthur and Flollo, 127.
+
+ Battle for treason, under Priscot, C. J., in reign of Henry VI., 118.
+
+ Battle, effect of chivalry upon, 113.
+
+ Battle under writ of right, 116.
+
+ Battle, trial before Edward III., 129.
+
+ Battle between Essex and Montford, 128.
+
+ Battle, under Queen Elizabeth, 132.
+
+ Battle between men and women, in Germany, 127.
+
+ Battle, abolished by St. Louis, in France, in 1260, 134.
+
+ Battle, abolished by 59’ George III., 134.
+
+ Battle, used by Chaucer, 135.
+
+ Battle, Shakespeare’s references to, 136, 137.
+
+ Battle, reference of Scott, to, 137, 138.
+
+ Battle, referred to, by Thackeray, 139.
+
+ Beccaria, his views on punishment, 274.
+
+ Beheading, punishment by, 276.
+
+ Bekker’s work on witchcraft, 69.
+
+ Benefit of clergy, 233, 243.
+
+ Benefit of clergy, definition of, 224.
+
+ Benefit of clergy, Biblical foundation for, 228.
+
+ Benefit of clergy, condition contributing to, 225.
+
+ Benefit of clergy, none, in desertion, 234.
+
+ Benefit of clergy, did not extend to treason, 228.
+
+ Benefit of clergy, nuns entitled to, 228, 229.
+
+ Benefit of clergy, “clergyable” and “unclergyable crimes,” 233.
+
+ Benefit of clergy, burning in hand, in, 231.
+
+ Benefit of clergy, practice in reading, in, 230.
+
+ Benefit of clergy, in Bracton’s time, 229.
+
+ Benefit of clergy, case of Ben Jonson, 238, 239.
+
+ Benefit of clergy, under Henry II., 226.
+
+ Benefit of clergy, under Edward III., 229.
+
+ Benefit of clergy, under Edward IV., 230.
+
+ Benefit of clergy, under Henry VI., 231.
+
+ Benefit of clergy, under Henry VII., 231.
+
+ Benefit of clergy, under Henry VIII., 234, 235.
+
+ Benefit of clergy, abolished, in England, in 1825, 236.
+
+ Benefit of clergy, claimed in United States, 239, 241.
+
+ Benefit of clergy, abolished in U. S. in 1790, 236.
+
+ Bentham, Jeremy, will of, 324.
+
+ Berkeley, marriage of Lord Thomas, 28.
+
+ Betrothals, in Anglo-Saxon days, 36.
+
+ Betrothal-rings, 34.
+
+ Biblical theory of marriage, 14.
+
+ Bier, ordeal of, 143, 145.
+
+ Bilboes, punishment, by, 303.
+
+ Blinding, punishment, by, 295.
+
+ Boaz, his espousal of Ruth, 36.
+
+ Boiling in oil, punishment by, 285.
+
+ Bracton, does not refer to ordeals, 157.
+
+ Bracton, benefit of clergy, in time of, 229.
+
+ Bracton, description of law wager, by, 201, 202.
+
+ Bracton, standing mute, during time, of, 179.
+
+ Branding, punishment, by, 297.
+
+ Brank, punishment, by, 305.
+
+ Brazil, marriages of infants in, 29.
+
+ Burgundian code, on trial by battle, 111.
+
+ Burning in hand, in benefit of clergy, 231.
+
+ Burning, punishment by, 276.
+
+ Burnworth, case of, in 1726, 186.
+
+ Burr, Aaron, trial of, 100.
+
+ Burn’s idea of the devil, 69.
+
+ Burying alive, punishment by, 282.
+
+
+ C
+
+ Caesar, Augustus used the recall, 88.
+
+ Caesar’s reference to marriage-settlements among Gauls, 32.
+
+ Calverly, case of Walter, in 1605, 184.
+
+ Cambyses, recall of Sisamnes (note), 78.
+
+ Canute, ordeals under, 152.
+
+ Capture, marriage by, 13.
+
+ Cardunville, William’s case, 22.
+
+ Cathay, marriages in (note), 13.
+
+ Catholic marriage forms, 34.
+
+ Cato, loaning of wife by, 27.
+
+ Ceylon, polyandry in, 16.
+
+ Chancery, jurisdiction of, 90.
+
+ Charitable wills, 323.
+
+ Charlemagne, law of, against witchcraft, 50.
+
+ Charlemagne, edict, of, on trials by ordeal, 147, 148.
+
+ Charles le-Gros, accusation and trial of his wife, 159.
+
+ Chatelet, of Paris, punishments, at, 289, 292.
+
+ Child marriages, 29.
+
+ Child of concubine, property right of, 18.
+
+ Chinese marriage customs, 12.
+
+ Chivalry, influence of, on battle, 112, 113.
+
+ Church and witchcraft, in early times, 49.
+
+ Churchmen, trials of, by wager of law, 210.
+
+ Church’s influence on trials by ordeal, 168, 169.
+
+ Cimon, recall of, 83.
+
+ Circassians, capture-marriages among (note), 13.
+
+ Clarendon, assize of, 154.
+
+ Clarendon, assize of, and law wager, 209.
+
+ Claudius, law allowing marriage to niece, 18.
+
+ Cleisthenes, on judicial recall, 82.
+
+ Clergy, benefit of (see benefit of clergy), 223, 243.
+
+ Clergy, neck-verse used in, 229.
+
+ Clitherow, Margaret, case of, 180, 183.
+
+ Clovis’ marriage to Clotilde, 32.
+
+ Cnut, proceedings in “false judgment” under, 106.
+
+ Cnut, wills, under, 312.
+
+ Cnut’s law against witchcraft, 49.
+
+ Cnut’s law against certain sale-marriages, 20.
+
+ Code of Hammurabi, on recall of judges, 78.
+
+ _Coemptio in manum_, definition of, 16.
+
+ Coke, on Slade’s case of law wager, 213.
+
+ Coke, on wager of law, 200.
+
+ Colynbourgh, Alice, trial of, by law wager, in 1435, 211.
+
+ Combat, trial by (see Battle, trial by), 109.
+
+ Common pleas courts, in old England, 90.
+
+ Compurgators, character of, in wager or law, 198.
+
+ Compurgators, as witnesses, 158.
+
+ Compurgation by fire ordeal, 142, 143.
+
+ Concubinage, definition of, 18.
+
+ Concubine, property right of progeny of, 18.
+
+ _Concubinatus_, under Roman law, 18.
+
+ _Confarreatio_, definition of, 16.
+
+ _Confarreatio_, obsolete, by end of Roman Republic (note), 17.
+
+ Congress, abolished benefit of clergy, in 1790, 236.
+
+ Constantine, law of, against witchcraft, 48.
+
+ Constantine, sanctuary, under, 248.
+
+ Corey, Giles, trial for witchcraft, 66.
+
+ Corey, Giles, case of pressing to death, in 1692, 187, 189.
+
+ Corey, Martha’s trial for witchcraft, 65.
+
+ Corsned, ordeal, by, 143, 144.
+
+ County Court, of Anglo-Saxons, 90.
+
+ Courts, in ancient England, 90.
+
+ Crimes, unclergyable, 233.
+
+ Criminal cases, wager of law, in, during 14th century, 204.
+
+ Crucifixion, punishment by, 280.
+
+ Cross, ordeal by, 143, 144, 148.
+
+ Cumanus, cruelty of, in witch persecutions, 54.
+
+ _Curia regis_, in early England, 90.
+
+ Custom, of throwing rice, 34.
+
+ Custom, of throwing shoes, 34.
+
+ Custom, of throwing stockings, 34.
+
+ Custom, of throwing bouquets, 34.
+
+ Customs, of marriage, 12, 44.
+
+
+ D
+
+ David and Goliath, trial by, 109.
+
+ David’s Psalms, authorizing benefit of clergy, 228.
+
+ Debt, wager of law, in (note), 207.
+
+ Debt, battle in trials for, 119.
+
+ Definition of benefit of clergy, 224.
+
+ Definition of _Confarreatio_, 16.
+
+ Definition of trial by ordeal, 141.
+
+ Definition of wager of law, 196.
+
+ Descent from concubine, 18.
+
+ Detinue, wager of law, in (note), 207.
+
+ Dinah’s proposed marriage to Shechem, 14.
+
+ Diocletian, prohibition of polygamy by, 16.
+
+ Divorcement, under Hammurabi, 31.
+
+ _Donatio propter nuptias_, of Roman law, 31.
+
+ Dower, at church door, 32.
+
+ Dower, under Anglo-Saxons, 32.
+
+ Dower, under reign of Edward I., 26.
+
+ Dower, Shakespeare’s reference to law of (note), 33.
+
+ Dowry, under Hammurabi’s code, 31.
+
+ Dowry, origin of, 31.
+
+ Drawing and quartering, punishment by, 283.
+
+ Drowning, punishment by, 277.
+
+ Ducking, punishment by, 303.
+
+ Durant, John, case of, in 1734, 187.
+
+ “Dusty-foot courts”, 90.
+
+
+ E
+
+ Ears, cutting off, punishment, by, 296.
+
+ “Earthenware-scourge”, recall known as, in Athens, 83.
+
+ Edda, Elder, song of, 165.
+
+ Edward, the Confessor, sanctuary, under, 254.
+
+ Edward, the Confessor, ordeals, under, 152.
+
+ Edward, the Confessor, accusation against his mother, 159, 160.
+
+ Edward, the Elder, ordeals, under, 152.
+
+ Edward I., his marriage to Marguerite, in 1299, 32.
+
+ Edward I., sanctuary, under, 256.
+
+ Edward I., timidity of judges, under, 93.
+
+ Edward I., standing mute, under, 175.
+
+ Edward I., statute on dower, 26.
+
+ Edward II., punishment by drowning, under, 278.
+
+ Edward III., benefit of clergy, under, 229.
+
+ Edward III., _peine forte et dure_, under, 180.
+
+ Edward III., battle, discouraged by, 118.
+
+ Edward III., marriages of infants, under, 28.
+
+ Edward III., wager of law, under, 202.
+
+ Edward III., trial by battle before, 129.
+
+ Edward IV., benefit of clergy, under, 230.
+
+ Edward IV., wills, under, 317.
+
+ Edward VI., wills, under, 318.
+
+ Egypt, wills, in ancient, 309.
+
+ Elizabeth, abolished law wager, in ecclesiastic courts, 208.
+
+ Elizabeth, statute of, on benefit of clergy, 231.
+
+ Elizabeth, trial, by battle, under, 132.
+
+ Elizabeth, statute of, against witchcraft, 57.
+
+ Elizabeth, Queen, sanctuary claimed by, 260, 261.
+
+ Ellenborough, on trial by battle, in 1817, 133.
+
+ Ellsworth, Oliver, framed judiciary bill, in U. S., 96.
+
+ Emma, Queen, trial of, by ordeal, 159, 160.
+
+ England, administration in ancient, of justice, 89, 90.
+
+ England, witchcraft in, 70.
+
+ Essex, trial by battle with Montford, 128.
+
+ Eucharist, ordeal by, 143, 144.
+
+
+ F
+
+ “Fair Maid of Perth”, ordeal of bier, in (note), 166.
+
+ False-judgment, in Anglo-Saxon days, 92.
+
+ Fejee-Islanders, marriages by (note), 13.
+
+ Felony, attainder in, 173.
+
+ Felony, trial by battle for, 116.
+
+ Felton, case of John, in 1628 (note), 185.
+
+ Fiction, wills, in, 332.
+
+ Fisher’s, trial by battle, 131.
+
+ Flaying, punishment, by, 300.
+
+ Flollo and King Arthur, battle between, 127.
+
+ Fou-hi, Emperor, established marriage, in China, 12.
+
+ Fourteenth century wills, 319.
+
+ Franklin, will of Benjamin, 326.
+
+ Freakish wills, 324.
+
+ France, witchcraft in, 70.
+
+
+ G
+
+ Gallows-marriages, 41, 43.
+
+ Galzu, the judge, 74.
+
+ Garnier, case of, on witchcraft persecution, 55.
+
+ Gauls, marriage among, 32.
+
+ Gaunt, John of, and Catherine Swinford, 19.
+
+ Gaunt, John, will of, 320.
+
+ Gemot court, of Anglo-Saxons, 90.
+
+ Genesis, law of marriage traced to, 14.
+
+ George II., law of, regarding marriage, 24.
+
+ George III., abolished _peine forte et dure_, in 1772, 189.
+
+ George III., judges under, 95.
+
+ George III., abolished trial by battle, in England, 134.
+
+ Germans, trial by battle among, at early day, 109, 110.
+
+ Glanville, law of marriage stated by, 21.
+
+ Glanville, on trial by battle, under writ of right, 120, 122.
+
+ Glanville, ordeals, in time of, 155.
+
+ Glanville, wills, during time of, 313.
+
+ Glanville, wager of law, during time of, 200.
+
+ Glazier’s company case, 214.
+
+ Godwin, Duke, trial of, by ordeal, 160, 161.
+
+ Goliath, trial with David, 109.
+
+ Goths, trial by battle among, 111.
+
+ “Great Law”, wager by, in 14th century, 204.
+
+ Greece, recall in, 81.
+
+ Greece, effect of recall in, 103, 104.
+
+ Greece, sanctuary in, 247.
+
+ Gregory of Tours, case of law wager, 209.
+
+ Guillotine, punishment by, 293.
+
+ Gundibald, law of, regulating trial by battle, 111.
+
+
+ H
+
+ Hair, plucking off, punishment by, 299.
+
+ Hale, Sir Mathew’s, trial of witches, 60.
+
+ Hammurabi’s prerogatives, in decision of causes, 79.
+
+ Hammurabi, made infallibility the test of the judge, 106.
+
+ Hammurabi’s law against witchcraft, 45.
+
+ Hammurabi, code of, regarding marriage dowry, 31.
+
+ Hammurabi’s code, on judicial recall, 77, 80.
+
+ Hand, marriages by, in Rome, 17.
+
+ Hanging, punishment by, 279.
+
+ Hawes, Nathaniel, case of, in 1721, 186.
+
+ Hebrews, practiced polygamy, 15.
+
+ Henry II., benefit of clergy, under, 226.
+
+ Henry II., justices itinerant, under, 91.
+
+ Henry II., will of, 315.
+
+ Henry III., abolished ordeals, 157.
+
+ Henry III., _peine forte et dure_, under reign of, 178.
+
+ Henry III., trial by battle before, 129.
+
+ Henry IV., sanctuary, in reign of, 259.
+
+ Henry IV., _peine forte et dure_, under, 180.
+
+ Henry VI., law wager, under, 212.
+
+ Henry VI., wager of law, under, 206, 207.
+
+ Henry VI., _peine forte et dure_, under, 180.
+
+ Henry VI., trial by battle, before, 131.
+
+ Henry VII., benefit of clergy, under, 231.
+
+ Henry VII., trial by battle, before, 132.
+
+ Henry VII., sanctuary, under, 262.
+
+ Henry VII., sanctuary, under, 257.
+
+ Henry VII., _peine forte et dure_, under (note), 180.
+
+ Henry VIII., benefit of clergy, under, 234, 235.
+
+ Henry VIII., sanctuary curtailed by, 267.
+
+ Henry VIII., law wager, under, in 1527 (note), 213.
+
+ Hereford, battle with Norfolk, 130.
+
+ Hexham, sanctuary, at, 253.
+
+ Hincmar, views of, on ordeals, 162.
+
+ Holt, chief justice, cases by, on law wager, 214, 216.
+
+ Holt, lord chief justice’s trial of witches, 61.
+
+ Hopkins, Matthew, his cruelty against witches, 59.
+
+ Horsey, Doctor’s case, 236.
+
+ Hundred court, of Anglo-Saxons, 90.
+
+ Hungarians, marriages of infants, among, 29.
+
+ Huntingdon witch trials, 61.
+
+ Hutchinson’s work on witchcraft, 69.
+
+ Hyperbolus, recall of, in Athens, 86.
+
+
+ I
+
+ Ina, sanctuary, under, 251.
+
+ Independence of judges, established by William III., 94.
+
+ Independence of judges, under Constitution of U. S., 97.
+
+ Independence of judges, wisdom of, demonstrated, 106.
+
+ India, polyandry in, 16.
+
+ Ine, laws of, governing ordeals, 149.
+
+ Infallibility, the test of judicial action in Hammurabi’s time, 106.
+
+ Infant marriages, 28.
+
+ Infant marriages, in Brazil, 29.
+
+ Innocent III., marriage under, 21.
+
+ Inquisition, punishment by, 286, 288.
+
+ Iron, ordeal by hot, 143.
+
+ Isaac and Rebekah, 33.
+
+ Israelites, taking a wife, by (note), 13.
+
+ Israelites, wager of law, under ancient, 197.
+
+ Itinerant justices, 91.
+
+
+ J
+
+ Jacob’s will, 309.
+
+ James I., repealed right to sanctuary, 268.
+
+ James of Scotland, his belief in witchcraft, 57.
+
+ Jealousies, law of, 141, 142.
+
+ Joan of Arc, persecution of, 52.
+
+ Jonson, clergy, claimed by Ben, 238, 239.
+
+ Judge, definition of, 74.
+
+ Judges, in patriarchial days, 75, 76.
+
+ Judges, servants of king, in old England, 91.
+
+ Judges, liability of, in England, 95.
+
+ Judicial recall, 74, 108.
+
+ Judicial tenure in American colonies, 98.
+
+ Judgment in _peine forte et dure_, 172, 173.
+
+ Jury trials under King Alfred, 151.
+
+ Jury trials used instead of battle, under Edward III., 118.
+
+ Justice, King, the fountain of, in England, 90.
+
+ Justice, sale of, in ancient England, 90.
+
+ Justices, itinerant, in England, 91.
+
+ Justinian’s definition of marriage, 12.
+
+
+ K
+
+ Katherine, of Aragon, will of, 321.
+
+ Kent, Chancellor, on common-law marriages, 23.
+
+ Kentucky, clergy claimed, in, 241.
+
+ King, the fountain of justice, in England, 90.
+
+ King Alfred’s courts, 89, 90.
+
+ King’s bench, court of, in England, 90.
+
+ Knighthood, effect upon trial by battle, 113, 114.
+
+
+ L
+
+ Lamech, established polygamy, 15.
+
+ Law, wager of (See wager of law), 196, 220.
+
+ Law suits under Hammurabi, 80.
+
+ Legitimacy, of mantle-children, 18, 19.
+
+ Leo, Emperor, law against concubinage, 18.
+
+ Littleton, on benefit of clergy, 230.
+
+ Littleton, law of dower, by, 32.
+
+ London, charter of, exempting trials by battle, 119.
+
+ Longfellow, presents case of Giles Cory, 187, 189.
+
+ Louis le Debonnaire, abolished ordeal of the cross, 148.
+
+ Luther, marriage ceremony, by (note), 36.
+
+ Law, of marriage, 12, 44.
+
+
+ M
+
+ Maiden-rent, 30.
+
+ Majestas, under Roman Republic, 88.
+
+ Mantle-children, law of, 18, 19.
+
+ Marriage, laws and customs of, 12, 44.
+
+ Marriage, definition of, 12.
+
+ Marriage, three forms of, 15.
+
+ Marriage, Biblical theory concerning, 14.
+
+ Marriage, under Mosaic law, 14.
+
+ Marriage, _per verba de praesenti_, at common law, 23.
+
+ Marriage, _in facie ecclesiae_, 23.
+
+ Marriage, by sale, 13.
+
+ Marriage, by rape, 13.
+
+ Marriage, by capture, 13
+
+ Marriage, Morganatic (note), 17.
+
+ Marriage, putative, 26.
+
+ Marriage, retroactive, 26.
+
+ Marriage, required to be celebrated by clergy, in 1753, 24.
+
+ Marriage, a civil contract, under English law of 1836, 24.
+
+ Marriage, within Levitical degree prohibited, 17.
+
+ Marriage, between uncles and nieces, 18.
+
+ Marriage, between aunts and nephews, 18.
+
+ Marriage banns, 21.
+
+ Marriage dowry, origin of, 31.
+
+ Marriage, not a religious ordinance, 20.
+
+ Marriage, religious ceremony required in 1563, 20.
+
+ Marriage, legitimates, mantle-children, 18, 19.
+
+ Marriage-ring, origin of, 33.
+
+ Marriage, forms of, by Roman law, 16.
+
+ Marriage, under Twelve Tables, of Romans (note), 21.
+
+ Marriage, exalted by Roman law, 16.
+
+ Marriage, by hand, in ancient Rome, 17.
+
+ Marriage, a partnership, by Roman law, 16.
+
+ Marriage, among Gauls, Caesar’s reference to, 32.
+
+ Marriage, in Pericles’ time, 27.
+
+ Marriage, appertained to spiritual forum, in 12th century, 21.
+
+ Marriage, in Glanville’s time, 21.
+
+ Marriage, by infants, 28.
+
+ Marriage, in United States, 23.
+
+ Marriage, form of, in Persia, 34.
+
+ Marriage, among Hungarians, 29.
+
+ Marriage, at gallows, 41.
+
+ Marriage, in a “shift”, 37, 42.
+
+ Marriage, between Shechem and Dinah, proposal of, 14.
+
+ Marriage, between Claudius and Agrippina, 18.
+
+ Marriage of Richard de Anesty, in 1143, 21.
+
+ Marriage between John of Gaunt and Catherine Swinford, 19.
+
+ Marriage between Duke Richard and Gunnora, 19.
+
+ Marriage laws, in England, in 7th century, 21.
+
+ Marshal, trial for treason must be before, 118.
+
+ Marshall, Chief Justice, on independence of courts, 101.
+
+ Marshall, Chief Justice, probable recall of, 100.
+
+ Marshall, will of Chief Justice, 327.
+
+ Mary, Queen, law against witches, in Scotland, 56.
+
+ Mary, Queen, sanctuary, under, 259.
+
+ Massachusetts, clergy claimed in, 239.
+
+ Massola, punishment by, 293, 294.
+
+ Meinhold’s “Amber Witch”, 71.
+
+ Menu, institutes of, on marriage (note), 13.
+
+ “Middle Law”, wager by, in 14th century, 204.
+
+ Millis case, 24, 25.
+
+ Milton’s idea of the devil, 69.
+
+ Minnesota, clergy claimed in, 241.
+
+ Minority alone protected by the courts, 103.
+
+ “Minstrelsy of Scottish Border”, ordeal of bier, in, 166.
+
+ Mischief of recall in Athens, 86.
+
+ Molay, persecution of, under charge of witchcraft, 52.
+
+ Monogamy, definition of, 15.
+
+ Monogamy, best suited to civilization, 15.
+
+ Monogamy, in ancient Greece and Rome (note), 16.
+
+ Morganatic marriages, 17.
+
+ Mosaic code, sanctuary traced to, 244.
+
+ Mosaic code, wager of law, under, 196.
+
+ Mosaic conception of judicial functions, 75, 76.
+
+ Mosaic law, against witchcraft, 46.
+
+ Mosaic law, requiring marriage to brother’s widow, 35.
+
+ Moses, law of marriage, 14.
+
+ Moses, advice to judges, 75, 76.
+
+ Moses, warning, of, in rendering judgment, 101.
+
+
+ N
+
+ Narada, institutes of, 145.
+
+ Nazarene, delivery of, to multitude, 122.
+
+ Neck-verse, in benefit of clergy, 229.
+
+ Necromancy in mediaeval times, 49.
+
+ Neilson, trial by battle by, 129.
+
+ “New England Tragedies”, case of Giles Cory, in, 187, 189.
+
+ New Zealand, marriages, in (note), 13.
+
+ _Nil debit_, wager or law, in cases of, 197.
+
+ Norfolk, battle with Hereford, 130.
+
+ Normans, introduced battle, into England, 114.
+
+ Northampton, assize of, 154.
+
+ North Carolina, clergy claimed in, 240.
+
+ Nuns, entitled to clergy, 228.
+
+ Nurse, Rebecca’s trial for witchcraft, 67.
+
+
+ O
+
+ Oath-helpers, in wager of law, 205, 207.
+
+ Oil, ordeal by, 143.
+
+ Ordeal, trial by, 141, 170.
+
+ Ordeal, definition of, 141.
+
+ Ordeal, antiquity of, 141.
+
+ Ordeal of the bier, 143.
+
+ Ordeal, by the corsned, 143.
+
+ Ordeal, by red hot iron, 143.
+
+ Ordeal, by the Eucharist, 143.
+
+ Ordeal, by fire, 142, 143.
+
+ Ordeal, by the cross, 143.
+
+ Ordeal, of the bier, as presented in Richard III., 166.
+
+ Ordeal, by balance, 143.
+
+ Ordeal, by poison, 143.
+
+ Ordeal, by water, 143.
+
+ Ordeal, by hot oil, 143.
+
+ Ordeal, influence of Church on trials by, 168, 169.
+
+ Ordeal, under Ine, 149.
+
+ Ordeal, trials, under Richard I., 163.
+
+ Ordeal, trials, reported by Palgrave, 163, 164.
+
+ Ordeal, of bier, as presented in “Minstrelsy of Scottish Border”, 166.
+
+ Ordeal, of bier, in “Fair Maid of Perth” (note), 166.
+
+ Ordeal, to establish paternity of children, 159.
+
+ Ordeal, under Athelstan, 149.
+
+ Ordeal, under Canute, 152.
+
+ Ordeal, under Edward the Elder, 152.
+
+ Ordeal, under Edward the Confessor, 152.
+
+ Ordeal, under William Rufus, 156.
+
+ Ordeal, under Charlemagne, 147, 148.
+
+ Ordeal, under William the Conqueror, 153.
+
+ Ordeal, under Henry II., 154, 155.
+
+ Ordeal, in time of Glanville, 155.
+
+ Ordeal, abolished by Henry III., 157.
+
+ Ostracism, in ancient Greece, 81.
+
+ Otho, established trial by battle, in 983 A. D., 112.
+
+
+ P
+
+ Partnership, marriage, a, by Roman law, 16.
+
+ Palgrave’s record of ordeal trials, 163, 164.
+
+ Parson’s, Chief Justice, on marriages at common law, 23.
+
+ Paynel, William and Margaret’s case, in 1302, 26.
+
+ _Peine forte et dure_, 172, 195.
+
+ _Peine forte et dure_, definition of, 172.
+
+ _Peine forte et dure_, proceeding in, 174.
+
+ _Peine forte et dure_, judgment in, 172, 173.
+
+ _Peine forte et dure_, applied in 1215 (note), 174.
+
+ _Peine forte et dure_, case of, in 1219, 178.
+
+ _Peine forte et dure_, statute of Westminster on, 178.
+
+ _Peine forte et dure_, under Edward I., 175, 176.
+
+ _Peine forte et dure_, under Henry III., 178.
+
+ _Peine forte et dure_, under Edward III., 179, 180.
+
+ _Peine forte et dure_ during Bracton’s time, 179.
+
+ _Peine forte et dure_, under Henry IV., 180.
+
+ _Peine forte et dure_, under Henry VII. (note), 180.
+
+ _Peine forte et dure_, cases of, in 1221, 179.
+
+ _Peine forte et dure_, from 15th to 18th century, 177.
+
+ _Peine forte et dure_, from 16th to 17th century, 184.
+
+ _Peine forte et dure_, abolished in 1772, 189.
+
+ _Peine forte et dure_, in United States, 187, 190.
+
+ _Peine forte et dure_, abolished by act of Congress, in U. S., in
+ 1825, 191.
+
+ _Peine forte et dure_, case of Giles Cory, in 1692, 187, 189.
+
+ _Peine forte et dure_, case of Walter Calverly, 184.
+
+ _Peine forte et dure_, case of Margaret Clitherow, 180, 183.
+
+ _Peine forte et dure_, case of John Durant, in 1734, 187.
+
+ _Peine forte et dure_, case of John Felton, in 1628 (note), 185.
+
+ _Peine forte et dure_, case of Anthony Arrowsmith, 183.
+
+ _Peine forte et dure_, case of Burnworth, in 1726, 186.
+
+ _Peine forte et dure_, case of Phillips, in 1720, 186.
+
+ _Peine forte et dure_, case of Nathaniel Hawes, in 1721, 186.
+
+ _Peine forte et dure_, illustrations of, from Shakespeare, 192, 193.
+
+ _Peine forte et dure_, case of Sir Richard Weston, in 1615, 184, 185.
+
+ _Peine forte et dure_, case of Major Strangeways, in 1657, 185.
+
+ _Peine forte et dure_, case of Juliana Quick, 180.
+
+ _Peine forte et dure_, case of Cecelia Rygeway, 180.
+
+ _Peine forte et dure_, in 1827, 190.
+
+ _Peine forte et dure_, conclusions regarding, 193, 195.
+
+ Penn, William’s trial of witches, 62.
+
+ Penn, will of William, 328.
+
+ Pericles, marriage under, 27.
+
+ Perjury, battle established to prevent, 112.
+
+ Persia, form of marriages in, 34, 35.
+
+ Petalism, law of repealed, 452 B. C., 87.
+
+ Petalism, in Syracuse, 86.
+
+ Phillips, of Newgate, case of, in 1720, 186.
+
+ _Piepoudre_ courts, under Anglo-Saxons, 90.
+
+ Plato, will of, 310.
+
+ Poetic wills, 330, 333.
+
+ Poison, ordeal by, 143, 146.
+
+ Pelagius I., Pope, case of law wager, in 6th century, 209.
+
+ Poland, capture-marriages in (note), 13.
+
+ Political methods, trial of judges by, in Greece, 105.
+
+ Polygamy, definition of, 15.
+
+ Polygamy, established by Lamech, among Hebrews, 15.
+
+ Polygamy, among Hebrews, 15.
+
+ Polygamy, prohibited by Diocletian, 16.
+
+ Polygamy, in Persia, 15.
+
+ Polygamy, in Turkey, 15.
+
+ Polygamy, in Rome, 15.
+
+ Polyandry, definition of, 15.
+
+ Polyandry, origin of, 16.
+
+ Polyandry, practiced in India, Thibet and Ceylon, 16.
+
+ Preators, recalled in Rome, 87.
+
+ Precipitation, punishment by, 279.
+
+ Pressing to death (See _peine forte et dure_), 172, 195.
+
+ Primogeniture, effect of, on law of wills, 317.
+
+ Priscot, C. J., on trial by battle for treason, 118.
+
+ Privilege of sanctuary (See sanctuary), 244, 272.
+
+ Procedure of recall, in Athens, 82.
+
+ Property rights of wife, by Roman law, 16.
+
+ Property, protected by courts, alone, 103.
+
+ Punishment, as viewed by Beccaria, 274.
+
+ Punishment, definition of, 273.
+
+ Punishment, by Chatelet, of Paris, 289, 292
+
+ Punishment, by beheading, 276.
+
+ Punishment, by Bilboes, 303.
+
+ Punishment, by blinding, 295.
+
+ Punishment, by boiling in oil, 285.
+
+ Punishment, by branding, with hot iron, 297.
+
+ Punishment, by crank, 305.
+
+ Punishment, by burning to death, 276.
+
+ Punishment, by burying alive, 282.
+
+ Punishment, by crucifixion, 280.
+
+ Punishment, by cutting off ears, 296.
+
+ Punishment, by drawing and quartering, 283, 284.
+
+ Punishment, by drowning, 277.
+
+ Punishment, by ducking, 303.
+
+ Punishment, by exposure to wild beasts, 279.
+
+ Punishment, by flaying, 300.
+
+ Punishment, by guillotine, 293.
+
+ Punishment, by hanging, 279.
+
+ Punishment, by inquisition, 286, 288.
+
+ Punishment, by Massola, 293, 294.
+
+ Punishment, by plucking off the hair, 299.
+
+ Punishment, by precipitation, 279.
+
+ Punishment, by rack, 304.
+
+ Punishment, by sawing asunder, 279.
+
+ Punishment, by scourging with thorns, 302.
+
+ Punishment, by stocks, 304.
+
+ Punishment, by strangling, 279.
+
+ Punishment, by stoning to death, 279.
+
+ Punishment, by wheel, 301.
+
+ Punishments (See ancient punishments), 273, 306.
+
+ Purchase of justice, in England, 91.
+
+ Putative marriages, 26.
+
+
+ Q
+
+ Quaint and curious wills (See wills, quaint and curious), 307, 334.
+
+ Quick, Juliana, case of, 180.
+
+
+ R
+
+ Rack, punishment, by, 304.
+
+ Rape-marriages, 13.
+
+ Recall of judges, 74, 108.
+
+ Recall of judges, meaning, of, 74.
+
+ Recall, among Medes and Persians (note), 78.
+
+ Recall, effect of, in Babylon and Greece, 103, 104.
+
+ Recall, established by Cleisthenes, in Greece, 82.
+
+ Recall, in ancient Greece, 81.
+
+ Recall, in Athens, explained by Aristotle, 82.
+
+ Recall, discarded in Athens, 86.
+
+ Recall, in ancient Rome, 87.
+
+ Recall, by Augustus Caesar, 88.
+
+ Recall, by King, in England, 94.
+
+ Recall, by “false-judgment” trials, in England, 93.
+
+ Recall, in case of Rebecca Nurse, 102.
+
+ Re-hearings, none, under Hammurabi’s code, 78.
+
+ Retroactive marriages, 26.
+
+ Rice, an emblem of fruitfulness, 35.
+
+ Rice-throwing, 34.
+
+ Richarda, Empress, trial of, by ordeal, 159.
+
+ Richard de Anesty’s marriage, in 1143, 21.
+
+ Richard, Duke of, and Gunnora, 19.
+
+ Richard I., ordeal trials under, 163.
+
+ Richard III., ordeal of bier, as presented in, 166.
+
+ Right, writ of, procedure in battle under, 116.
+
+ Ring, in marriages, origin of, 33.
+
+ Roland, song of, 135.
+
+ Roman forms of marriage, 16.
+
+ Roman marriage laws basis of our own, 16.
+
+ Roman marriage exalted, 16.
+
+ Roman marriage a partnership relation, 16.
+
+ Romans, wager of law, under, 197.
+
+ Rome, recall of judges in ancient, 87.
+
+ Rome, sanctuary in, 247.
+
+ Ruth and Boaz, espousal of, 36.
+
+
+ S
+
+ Sabines, rape of the (note), 13.
+
+ Saint Louis, abolished trial by battle, in France, in 1260, 134.
+
+ Sale-marriages, 13.
+
+ Sale-marriages, in Cnut’s time, 20.
+
+ Sale-marriages, recognized by church, 20.
+
+ Salem witch trials, 62, 68.
+
+ Sale, of justice in old England, 90.
+
+ Samuel, Mother, persecution of, 56.
+
+ Sanctuary, privilege of, 244, 272.
+
+ Sanctuary, definition of, 244.
+
+ Sanctuary, how claimed, 258, 259.
+
+ Sanctuary, under Mosaic code, 244.
+
+ Sanctuary, in Greece and Rome, 247.
+
+ Sanctuary, under Alfred, 251.
+
+ Sanctuary, under Constantine, 248.
+
+ Sanctuary, under Anglo-Saxons, 249.
+
+ Sanctuary, under Athelstan, 252.
+
+ Sanctuary, under Ina, 251.
+
+ Sanctuary, under Edward the Confessor, 254.
+
+ Sanctuary, under William the Conqueror, 252.
+
+ Sanctuary, abjuration of realm, in, 250.
+
+ Sanctuary, under Edward I., 256.
+
+ Sanctuary, in reign of Henry IV., 259.
+
+ Sanctuary, under Henry VII., 257, 262.
+
+ Sanctuary, curtailed by Henry VIII., 267.
+
+ Sanctuary, repealed by James I., 268.
+
+ Sanctuary, in Scotland, 265.
+
+ Sanctuary, under Queen Mary, 259.
+
+ Sanctuary, claimed by Queen Elizabeth, 260.
+
+ Sanctuary, at Hexham, 253.
+
+ Sanctuary, in literature, 269, 270.
+
+ Sawing asunder, punishment by, 279.
+
+ Saxons, sanctuary under, 249.
+
+ Saxons, wager of law, under, 197.
+
+ Scipio, trial by battle before, 126.
+
+ Scotland, persecutions for witchcraft in, 57.
+
+ Scotland, sanctuary, in, 265.
+
+ Scott, Sir Walter’s references to trial by battle, 137, 138.
+
+ Scott’s “Minstrelsy of Scottish Border”, 166.
+
+ Scourge, recall known as, in Athens, 83.
+
+ Scourging, with thorns, punishment, by, 302.
+
+ Selden, gives origin of marriage-ring, 33.
+
+ Selden, on trial by battle, 111.
+
+ Selden, procedure of trial by battle by, 122, 124.
+
+ Sennacherib, will of, 310.
+
+ Shakespeare’s reference to trial by battle, 136, 137.
+
+ Shakespeare’s reference to maiden-rent (note), 30.
+
+ Shakespeare, mention of the gemmal ring, by (note), 35.
+
+ Shakespeare, illustrations of _peine forte et dure_, by, 192, 193.
+
+ Shakespeare’s reference to sanctuary, 269.
+
+ Shakespeare’s will, 324.
+
+ Shechem’s negotiation for Dinah, 31.
+
+ Shells, used for votes on Athenian recall, 82.
+
+ Shoe, custom of throwing, 35.
+
+ Sisamnes, recall of (note), 78.
+
+ Smock-marriages, 37, 42.
+
+ Solomon, polygamy of, 15.
+
+ Sorcery, law of, 45, 70.
+
+ Spartans, marriages by capture, among (note), 13.
+
+ Stafford, Humphrey, sanctuary claimed by, 262.
+
+ St. Cunigundi, trial of, by ordeal, 159.
+
+ Standing mute (See _peine forte et dure_), 172, 195.
+
+ Standing mute, plea of not guilty, for, in 1827, 190.
+
+ Stedinger, persecutions of, 51.
+
+ Stocking-throwing, 34, 37.
+
+ Stocks, punishment, by, 304.
+
+ Stone’s case of clergy, 232.
+
+ Stoning to death, punishment by, 279.
+
+ Strangeways, case of Major, in 1657, 185.
+
+ Strangling, punishment by, 279.
+
+ Surgeons, under Hammurabi, 81.
+
+ Sweden, trial by battle in, 111.
+
+ Syracuse, the recall in, 86.
+
+
+ T
+
+ Tartars, marriages by (note), 13.
+
+ Templars, persecutions of, 52.
+
+ Testimony, value of, in time Henry II., 154.
+
+ Teutberga, trial of, by ordeal, 161, 162.
+
+ Themistocles, recall of, 83.
+
+ Testament (See wills, quaint and curious), 307, 334.
+
+ Thackeray’s references to trial by battle, 139.
+
+ Theodosius, law against marriages by, 17.
+
+ Thibet, polyandry in, 16.
+
+ “Third Law”, wager by, in 14th century, 204.
+
+ Thomas A’Becket, and benefit of clergy, 226.
+
+ Treason, battle could be stopped during trial of, 116.
+
+ Treason, benefit of clergy did not extend to, 228.
+
+ Trent, Council of, requiring religious ceremony, 20.
+
+ Trials in ancient Babylon, 79.
+
+ Trial by battle, 109, 140.
+
+ Trial by ordeal, 141, 170.
+
+ Trial of witches, 60, 70.
+
+ Tudor, Owen, claimed sanctuary, 260.
+
+
+ U
+
+ Unclergyable crimes, 233.
+
+ Uncles and nieces, marriages between, 18.
+
+ United States, clergy claimed in, 239, 241.
+
+ United States, clergy abolished in, in 1790, 236.
+
+ United States, cases of _peine forte et dure_, in, 187, 190.
+
+ United States, abolished _peine forte et dure_, by act of Congress,
+ in 1825, 191.
+
+ United States, punishment by ducking, in, 303, 304.
+
+ United States, law wager in, 219.
+
+ Upton, trial by battle of, 130.
+
+ _Usus_, marriage by, under Roman law, 16.
+
+
+ V
+
+ Varus, Quintilius’ observations on trial by battle, 110.
+
+ Virgil, will of, 311.
+
+ Vladimir, his espousal of the daughter of Raguald, 36.
+
+ Votes, in Athenian recall, 82.
+
+
+ W
+
+ Wager of law, 196, 220.
+
+ Wager of law, definition of, 196.
+
+ Wager of law, origin of, 199.
+
+ Wager of law, procedure in, 197, 198.
+
+ Wager of law, in ancient Babylon, 197.
+
+ Wager of law, under Mosaic code, 196.
+
+ Wager of law, under Alfred, 197.
+
+ Wager of law, under Wihtraed, 200.
+
+ Wager of law, description of, by Bracton, 201, 202.
+
+ Wager of law, compurgators in, 198.
+
+ Wager of law, by oath-helpers, 205, 207.
+
+ Wager of law, observations of Coke, on, 200.
+
+ Wager of law, in cases of _Nil debit_, 197.
+
+ Wager of law, kinds of, in criminal cases, 204.
+
+ Wager of law, in debt and detinue (note), 207.
+
+ Wager of law, trial of churchmen by, 210.
+
+ Wager of law, case of Pope Pelagius I., in 6th century, 209.
+
+ Wager of law, under Saxons, 197.
+
+ Wager of law, under Glanville, 200.
+
+ Wager of law, irrational nature of procedure in, 208.
+
+ Wager of law, and assize of Clarendon, in 1166, 209.
+
+ Wager of law, under Edward III., 202.
+
+ Wager of law, under Henry VI., 206, 207, 212.
+
+ Wager of law, under Henry VIII., in 1527 (note), 213.
+
+ Wager of law, statute of Elizabeth on, 208.
+
+ Wager of law, abolished in England, in 1833, 208.
+
+ Wager of law, in United States, 219.
+
+ Wager of law, case of Gregory of Tours, 209.
+
+ Wager of law, trial of Alice Colynbourgh, by, in 1435, 211.
+
+ Wager of law, Slade’s case, 213.
+
+ Wager of law, case of Robert Welby, in 1492, 213.
+
+ Wager of law, miscellaneous cases of, 203, 204.
+
+ “Waking” witches, 59.
+
+ Waldenses, persecution of the, 53.
+
+ Warbois, witches of, 56.
+
+ Washington, will of General, 327.
+
+ Water, ordeal by, 143, 144, 149.
+
+ Webster, Daniel, plea of law wager by, 219, 220.
+
+ Welby, case of Robert, in law wager, in 1492, 213.
+
+ Wenham, Jane’s’ trial for witchcraft, 61.
+
+ Westminster, statute of, on _peine forte et dure_, 178.
+
+ Weston, Sir Richard, case of, in 1615, 184.
+
+ Wheel, punishment, by, 301.
+
+ Wild beasts, punishment by exposure to, 279.
+
+ Will, definition of, 307.
+
+ William Rufus, ordeals under, 156.
+
+ William the Conqueror, ordeals, under, 153.
+
+ William the Conqueror, sanctuary, under, 252.
+
+ William III., judges under, 94.
+
+ William IV., abolished wager of law, in 1833, 208.
+
+ Will, of Jacob, 309.
+
+ Will, of Sennacherib, 310.
+
+ Will, of Aristotle, 310.
+
+ Will, of Plato, 310.
+
+ Will, of Virgil, 311.
+
+ Will, of Henry II., 315.
+
+ Will, of John of Gaunt, 320.
+
+ Will, of Katherine of Aragon, 321.
+
+ Will, of Shakespeare, 324.
+
+ Will, of Jeremy Bentham, 324.
+
+ Will, of William Penn, 328.
+
+ Will, of Benjamin Franklin, 326.
+
+ Will, of Chief Justice Marshall, 327.
+
+ Will, of General Washington, 327.
+
+ Wills, quaint and curious (See quaint and curious wills), 307, 334.
+
+ Wills, in ancient Egypt, 309.
+
+ Wills, under Cnut, 312.
+
+ Wills, in Anglo-Saxon, days, 312.
+
+ Wills, during Glanville’s time, 313.
+
+ Wills, under Edward IV., 317.
+
+ Wills, under Edward VI., 318.
+
+ Wills, effect of primogeniture on, 317.
+
+ Wills, effect of church’s influence, on, 314.
+
+ Wills, of 14th century, 319.
+
+ Wills, with charitable objects, 323.
+
+ Wills, to animals, 322.
+
+ Wills, poetic, 330, 333.
+
+ Wills, in fiction, 332.
+
+ Wisdom of independent judiciary, 106.
+
+ Witch, definition of, 45.
+
+ Witchcraft, law of, 45, 70.
+
+ Witchcraft, under Mosaic law, 46.
+
+ Witchcraft, under Constantine, 48.
+
+ Witchcraft, law of Charlemagne against, 50.
+
+ Witchcraft, prohibited by Anglo-Saxon laws, 49.
+
+ Witchcraft, persecution of the Stedinger under law of, 51.
+
+ Witchcraft, in England, 70.
+
+ Witchcraft, laws against in England, 57, 58.
+
+ Witchcraft, in France, 70.
+
+ Witchcraft, in Scotland, 57.
+
+ Witchcraft, in Scotland, under Queen Mary, 56.
+
+ Witchcraft, persecutions of the Templars, 52.
+
+ Witchcraft, authorities upon, 70.
+
+ “Witch of Walkerne”, 61.
+
+ “Witch-finder General”, 59.
+
+ Witches, trial of by Hammurabi’s code, 46.
+
+ Witches, trial of by Mosaic law, 46.
+
+ Witches, trial of by law of Twelve Tables, 47.
+
+ Witches, punishment of, 59.
+
+ Witches, of Warbois, 56.
+
+ Witch-mania in Europe, 54, 59.
+
+ Witch-trials, at Salem, 62, 68.
+
+ Witnesses, compurgation by, 158.
+
+ Writ of right, procedure in battle under, 116.
+
+ Writ of right, procedure under, in full, 120, 122.
+
+
+
+*** END OF THE PROJECT GUTENBERG EBOOK 75835 ***
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+<!DOCTYPE html>
+<html lang="en">
+<head>
+ <meta charset="UTF-8">
+ <title>
+ Legal Antiquities | Project Gutenberg
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+.dedication {
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+
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+
+ </style>
+ </head>
+<body>
+<div style='text-align:center'>*** START OF THE PROJECT GUTENBERG EBOOK 75835 ***</div>
+
+<h1>LEGAL ANTIQUITIES</h1>
+
+<p class="center larger">A COLLECTION OF ESSAYS UPON<br>
+ANCIENT LAWS AND<br>
+CUSTOMS</p>
+
+<p class="titlepage">BY<br>
+<span class="larger">EDW. J. WHITE</span><br>
+<span class="smaller">Editor Third Edition “Tiedeman, on Real Property,” Author<br>
+of “Mines and Mining Remedies,” “Personal Injuries On<br>
+Railroads,” “The Law in Shakespeare,” Etc.</span></p>
+
+<p class="titlepage"><span class="smaller">PUBLISHED BY</span><br>
+THE F. H. THOMAS LAW BOOK CO.<br>
+<span class="smaller"><span class="smcap">St. Louis, Mo.</span><br>
+1913</span></p>
+
+<p class="titlepage smaller">Copyright, 1913<br>
+by<br>
+EDWARD J. WHITE</p>
+
+<p class="titlepage smaller"><span class="smcap">Nixon-Jones Printing Co.<br>
+St. Louis, Mo.</span></p>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p class="dedication">TO THE MEMORY OF MY<br>
+<span class="larger">MOTHER,</span><br>
+WHOSE FAITH IN HUMANITY MADE HER ALWAYS CHARITABLE<br>
+FOR THE FRAILTIES OF THE PAST AND HOPEFUL<br>
+FOR THE FUTURE; WHOSE TENDER DEVOTION,<br>
+SACRIFICES AND ENCOURAGEMENT ARE<br>
+THE DEAREST RECOLLECTIONS OF<br>
+MY LIFE, THESE PAGES ARE<br>
+AFFECTIONATELY<br>
+INSCRIBED.</p>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<h2 class="nobreak" id="TABLE_OF_CONTENTS">TABLE OF CONTENTS.</h2>
+
+</div>
+
+<table>
+ <tr>
+ <td><a href="#CHAPTER_I"><span class="smcap">Chapter I.</span></a></td>
+ </tr>
+ <tr>
+ <td>Marriage Laws and Customs.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_II"><span class="smcap">Chapter II.</span></a></td>
+ </tr>
+ <tr>
+ <td>Witchcraft and Sorcery.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_III"><span class="smcap">Chapter III.</span></a></td>
+ </tr>
+ <tr>
+ <td>Recall of Judges.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_IV"><span class="smcap">Chapter IV.</span></a></td>
+ </tr>
+ <tr>
+ <td>Trial by Battle.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_V"><span class="smcap">Chapter V.</span></a></td>
+ </tr>
+ <tr>
+ <td>Trial by Ordeal.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_VI"><span class="smcap">Chapter VI.</span></a></td>
+ </tr>
+ <tr>
+ <td><i>Peine Forte et Dure.</i></td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_VII"><span class="smcap">Chapter VII.</span></a></td>
+ </tr>
+ <tr>
+ <td>Wager of Law.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_VIII"><span class="smcap">Chapter VIII.</span></a></td>
+ </tr>
+ <tr>
+ <td>Benefit of Clergy.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_IX"><span class="smcap">Chapter IX.</span></a></td>
+ </tr>
+ <tr>
+ <td>Privilege of Sanctuary.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_X"><span class="smcap">Chapter X.</span></a></td>
+ </tr>
+ <tr>
+ <td>Ancient Punishments.</td>
+ </tr>
+ <tr>
+ <td><a href="#CHAPTER_XI"><span class="smcap">Chapter XI.</span></a></td>
+ </tr>
+ <tr>
+ <td>Wills, Quaint and Curious.</td>
+ </tr>
+</table>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_1"></a>[1]</span></p>
+
+<h2 class="nobreak" id="INTRODUCTION">INTRODUCTION.</h2>
+
+</div>
+
+<p>In this age of ours, distinguished principally for the
+variety of the inventions and the fast and furious pace
+at which we move; when the motto of the Captains of
+Industry, being paraphrased, is simply, that “Motion
+means Money”; when the politicians vie with each
+other in their attempts to cater to every passing popular
+fantasy and the great mass of the citizenship is too
+much engrossed in the commercial life of the day, to
+study or analyze the history of our institutions, but the
+demand of the times is for continuous change, in keeping
+with the moving spirit of the age, it is advisable that
+we should occasionally stop and consider the lessons of
+the past, lest we forget some of the valuable information
+of antiquity.</p>
+
+<p>There was perhaps never a time, in the history of
+our country, when the general feeling of individual unrest
+has brought about such disrespect for our existing
+institutions.</p>
+
+<p>The development of the great body of our law, from
+the brutalities of a barbarous period, with the ever
+changing ideas of civilization, to meet the needs of the
+people, and the higher standards obtaining, has been
+gradual but certain. In so far as we have actually progressed,
+therefore, we should be satisfied with the progress
+made and should be slow to return to the customs
+or remedies which a past civilization found unavailing,
+lest all our progress should prove but a dim phantom
+of the imagination.</p>
+
+<p><span class="pagenum"><a id="Page_2"></a>[2]</span></p>
+
+<p>A profitable lesson can oftimes be gleaned from a
+study of the past and when an innovation demanded is
+one that experience has proven fallacious, it is puerile
+to refuse to profit by this lesson, for even “a burnt
+child” will avoid the fire.</p>
+
+<p>Undoubtedly much of the remedial and substantive
+law of our period needs revision, to the end that simplicity
+may be attained and the interminable delays, resulting
+from the present practice, incidental to too
+many new trials and other objectionable methods, obviated.
+But this revision should be cautiously made, so
+as not to impair the efficiency of the great body of the
+law that the wisdom of the past has demonstrated to be
+thoroughly consistent with the individual and national
+welfare.</p>
+
+<p>The first attempt to simplify procedure in the United
+States, by the adoption of the New York Code, was only
+sixty-five years ago and a majority of the States
+adopted such legislation since the Civil War. The common
+law practice was greatly improved and simplified
+by this concerted action of the States and unquestionably
+there are many things that can yet be improved
+in the remedial procedure of the present day.</p>
+
+<p>But the prevalent idea that an increased volume of
+statute law will furnish a panacea for all existing evils,
+is radically wrong. The beneficent rules of conduct,
+crystallized into law, by custom, because consistent
+with the needs of the people, in the evolution of civilization,
+should be jealously preserved against the unscientific
+fragmentary legislation, too often reflecting the unjust
+and unequal demands of an aroused public sentiment,
+shaped by designing politicians, rather than by<span class="pagenum"><a id="Page_3"></a>[3]</span>
+the “cool examiner of the public pulse,” prompted by
+beneficent objects.</p>
+
+<p>Legislation, of course, is the simplest way of modifying
+or repealing law, but legislators, in our country, frequently
+act without adequate information or legal
+training and the most salutary rule of conduct, in such
+hands, might be supplanted by the most unequal and unjust
+law.</p>
+
+<p>All that is old is not necessarily good, but just because
+it is old, is not a sufficient reason for discarding
+it. Legislation may become as limitless as the imagination
+of the legislator and unless properly advised, it
+would be inimical to the interests of the State or Nation.</p>
+
+<p>When legislation is advised by any considerable
+number of the leaders of any political party, which
+history has shown in other countries to have been productive
+of the most deplorable consequences, then it is
+time to leave the issues of the present long enough to
+study the lessons of the past.</p>
+
+<p>In conning the “Marriage Laws and Customs” of
+past ages, we can, in some measure, congratulate ourselves
+that our Marriage Laws are better than those of
+the past centuries, yet when we consider the large class
+of “Predestined Lost” ones, born as a result of diseased
+and mismated marriages, and when we give but
+a cursory examination to the divorce statistics, we can
+see that we have grave need for better laws on this
+most important of all subjects, the regulation of the
+relation, through which the standards of citizenship are
+controled.</p>
+
+<p>The Witch-Craze, in Europe and America, which resulted
+in the wholesale slaughter of innocents, through<span class="pagenum"><a id="Page_4"></a>[4]</span>
+a blind faith by the Courts, in the popular standards of
+the people, whereby unprovable offenses, were permitted
+to be established in utter disregard of the rules of
+evidence, and a vacillating, dependent judiciary helped
+for centuries, to perpetrate the most intolerable outrages
+against civilization, illustrates the necessity of an
+absolutely independent judiciary, free from the dominating
+influence of the frenzy of the public and a constant
+adherence to the rules of evidence and the proper
+legal ideals, in the administration of the law.</p>
+
+<p>The Judicial Recall, as we see it in ancient history,
+is another of the present popular fantasies to be
+avoided. Hammurabi tried this system 2,500 years before
+Christ’s time, when witches were convicted according
+to their ability to swim a torrent and surgeons were
+mutilated, by the loss of a hand, for an unsuccessful
+operation. It was also tried in ancient Athens and because
+of some unpopular decision, the “most just
+Judge” of that city, Aristides, was recalled, and some
+votes were cast against him, because the voters were
+simply tired of hearing him called “The Just.” Aristotle’s
+evidence is to the effect that this law brought
+about the most deplorable consequences, in Greece,
+Persia and other antique nations, where it was in vogue.
+The old Anglo-Saxon practice of preferring the charge
+of “False Judgment” against the judge whose decision
+was challenged, who was recalled, if this charge was
+sustained, was found inimical to the interest of the
+Government and since the English Judges were emancipated
+from the narrow groove of an unskilled public
+sentiment and were appointed for life, the majesty of
+the law has been revered in no other country on the face<span class="pagenum"><a id="Page_5"></a>[5]</span>
+of the earth, as it has been in England. This is testimony
+worth considering, for, judging the future by the
+past, if this practice undermined the judicial institutions
+of other countries, it would also undermine our
+own judicial system and ought to be avoided. The demand,
+by the ill-formed, for the destruction of the independence
+of the Judiciary, in utter disregard of the
+lessons of the past and the wisdom of our fathers,
+should be considered, therefore, along with this object
+lesson furnished by ancient history and by penetrating
+into the records of the past centuries, it will be seen that
+to adopt such a law would mean to return to the “Leges
+Barbarorum” of the past.</p>
+
+<p>In the discharge of their impartial functions, the
+judges of the people’s courts, have nothing to do with
+popular standards; it is with right and wrong, according
+to the just and equal standards of the law that they
+have to deal and it is as true to-day, as when the patriarch
+Moses, admonished the judges of ancient Israel,
+that, in the prerogative of the judgment-seat, “Thou
+shalt not follow a multitude to do evil; neither shalt
+thou speak in a cause to decline after many, to wrest
+judgment.”<a id="FNanchor_1" href="#Footnote_1" class="fnanchor">[1]</a></p>
+
+<p>The work of the judges is in private places; they have
+no favors to bestow, no rewards of office to distribute.
+It is frequently the business of the charlatan to misconstrue
+and misinterpret their ablest judgments and as
+the courts are the final repositories of the people’s
+rights, when the public clamor is the loudest for the sacrifice
+of individual right, then the true judicial character
+performs its highest office, in withstanding all assaults<span class="pagenum"><a id="Page_6"></a>[6]</span>
+by the ill-informed, upon the ramparts of the
+Temple of Justice.</p>
+
+<p>With the wide-spread demand for the “judicial recall”
+we find the true modern standard, in this regard,
+reflected in the recent strong language of an upright
+Texas Judge, who, in the course of his opinion, observed:</p>
+
+<div class="blockquote">
+
+<p>“I have made it the rule of my judicial life, and shall
+continue to do so, while invested with the authority pertaining
+to the office I hold, to decide questions as I understand
+them, after as careful an investigation as my
+capacity affords, without reference to what public opinion
+may be. I do and shall continue to regard the law as
+superior to the ebullition of outraged feeling, when communities
+are shocked by crime. When cases arising
+under such circumstances, have reached this court, my
+voice and my vote shall, in the future, as in the past,
+be given for the upholding of the law, not bending it
+to public sentiment. The stability of the institutions of
+this government depends upon adherence to the law, as
+it is written, and not on the fluctuating strenuousity of
+eruptive ebullitions of popular sentiment.”<a id="FNanchor_2" href="#Footnote_2" class="fnanchor">[2]</a></p>
+
+</div>
+
+<p>This course alone is consistent with the attainment of
+the just idea of government, by the judicial department,
+and peculiarly of this department, because the ideals of
+the unskilled are not always consistent with the standards
+of scientific jurisprudence. A subservient judiciary,
+dependent upon the vacillating ebullitions of an
+unstable public sentiment would bring about a subversion
+of the important functions of this department of
+government, just as it did when popular sentiment controlled
+the incumbents of the judgment seat, in ancient<span class="pagenum"><a id="Page_7"></a>[7]</span>
+Babylon, in Greece and in the England of old Anglo-Saxon days.</p>
+
+<p>“Trial by Ordeal,” “Trial by Battle,” the dreadful
+“<i>Peine forte et dure</i>,” and “Wager of Law,” are all
+instructive procedures of a past civilization, from which
+important lessons can be drawn.</p>
+
+<p>“Trial by Ordeal,” “Trial by Battle” and “Wager of
+Law,” as institutions of a primitive people, struggling
+for right, are but expressions of a misguided and abortive
+effort to attain correct judicial ideals, by false and
+inaccurate standards. Before the evolution of the race
+had attained to the ideals, when tribunals for the trial of
+questions of right and wrong, according to the actual
+facts in each concrete case, had been established, such
+issues were determined by the ability of the accused, in
+criminal cases, or the appellee, in civil suits, of a certain
+character to accomplish certain ordeals, requiring almost
+superhuman strength or fortitude, or to withstand,
+by individual combat, the strength of the opposite party
+to the issue waged. Of course, with such ideals, might
+alone controled the right and by the “Wager of Law,”
+the other alternative used in the quest for right, the
+popularity of the principal or his ability to secure oath-helpers,
+to assist him in swearing away the given crime
+or debt, resolved the conclusion upon a given issue, into
+a simple question of the elasticity of the consciences of
+the principal and his friends, who were always able to
+win their cause, after issue waged, by a sufficiently
+strong and an adequate number of oaths.</p>
+
+<p>On the abolition of the “Ordeal,” in the thirteenth
+century, when the accused, in a criminal charge, refused
+to submit to a “Trial by Battle,” the courts were unable<span class="pagenum"><a id="Page_8"></a>[8]</span>
+to force a plea, without some amendment of the
+procedure and adroit criminal lawyers, for some years,
+availed themselves of this subterfuge, of having their
+clients stand mute and refuse to plead, when their conviction
+of felony would be certain to result and the
+courts found themselves helpless to avoid a condition,
+which resulted in the crowding of the jails and prisons,
+with prisoners, afraid to submit to the “Trial by
+Battle” and refusing to plead to the indictments filed
+against them. This, in time, brought about the greatest
+judicial severity in the case of prisoners standing mute
+and finally the practice, in all such cases, came to be to
+apply a heavy weight upon the chest of the accused and
+to literally “press him to death,” if he persisted in his
+obstinacy. For centuries, in England, this custom continued,
+and thousands were “pressed to death,” for
+standing mute, when arraigned upon a criminal charge.
+The same practice was followed in the witch persecutions
+in this country, in the seventeenth century and
+when we consider that these abominable customs obtained,
+until the past century, we are, indeed, to be congratulated
+that our present procedure, with all of its
+imperfections, has risen to the standard where it is able
+to reject such inhuman and barbarous practices.</p>
+
+<p>The “Benefit of Clergy” and “Privilege of Sanctuary,”
+illustrate the attempt of the Church to mollify, as
+it were, the cruelties resulting from the harsh administration
+of the criminal laws of mediaeval times, in England,
+by the secular courts and had it not been for these
+beneficent institutions—which were frequently utilized
+to protect criminals of the worst sort—there would
+have been no alleviation for the sufferings of the accused,<span class="pagenum"><a id="Page_9"></a>[9]</span>
+and the large number of innocents who embraced
+the plea of Clergy, or sought the sacred precincts of the
+protected Sanctuary, would, along with the guilty, have
+paid the penalty for living in a dark and benighted age,
+unable to protect the innocent from the power of the
+mighty, when accused of wrong-doing.</p>
+
+<p>When we read of the “Ancient Punishments” of the
+past centuries, we can but feel a satisfaction that the
+struggle of our English forefathers of mediaeval times,
+by herculean efforts against those in authority, adopted
+such fixed principles of constitutional law, as we find
+reflected in <i>Magna Charta</i>, and the various constitutions
+of our own country, preventing “cruel and unusual
+punishment.”</p>
+
+<p>Those so fortunate as to avoid the punishments of the
+past centuries, when death lurked in every charge filed
+against the poor and oppressed, must have felt a sort
+of consolation in being able to run the gauntlet of such
+barbarities and delusions, and to die a natural death,
+and this is no doubt why we find such evidence of jocularity,
+mixed with a strain of pathos running through
+the “Quaint and Curious Wills” and testaments of antiquity.</p>
+
+<p>Some of the great painters of modern times, such as
+the late Sir Lawrence Alma-Tadema, have depicted
+scenes upon the canvas, in such manner as to make antiquity
+to live again before modern eyes—to resurrect,
+as it were, the men and women of the past centuries and
+to infuse new life into their bodies—so that they seem
+to again assume real form and being.</p>
+
+<p>This comes from a close study of the subjects and a
+genius, almost akin to a divine gift. No such gift can<span class="pagenum"><a id="Page_10"></a>[10]</span>
+aid the lawyer, or did in this instance, who seeks to reproduce
+pen pictures of the antique proceedings of the
+past, but study of the subject is of course essential to
+give any tolerable idea of the obsolete laws and customs
+of other days.</p>
+
+<p>A keen interest in these old proceedings prompted a
+somewhat painstaking study of many antique volumes,
+as a basis for the presentation of the following pages,
+but the duties of a quite busy professional life have prevented
+the exhaustive investigation that would otherwise
+have been given the subjects treated.</p>
+
+<p>The sources of the information used in the different
+essays appear in notes and references throughout the
+work and it is to be hoped, if the usual modicum of instruction
+may be lacking, that some of the interest felt
+by the author, in tracing the old laws and customs of
+previous ages, may, in a measure, be shared, by the
+reader, who is kind enough to peruse the work.</p>
+
+<p>Not nearly all the learning or the law upon any one
+of the subjects presented, will be found set forth in the
+different paragraphs pertaining to the various subjects
+introduced, but a general outline of each topic, with frequent
+illustrations from concrete cases, will appear.</p>
+
+<p>None of the many legal antiquities of the Grecian
+States or the Roman Empire, which could be so profitably
+discussed, have been attempted, but only a few of
+the antique English laws and customs that have particularly
+attracted the attention of the author. These several
+subjects were all given cursory examinations in the
+preparation of the data for “Law in Shakespeare” and
+the superficial investigation in connection with that
+work, led to the more minute treatment herein. This is<span class="pagenum"><a id="Page_11"></a>[11]</span>
+the apology for the undertaking and the engrossment
+of professional duties is the excuse for the limited
+scope of the treatment accorded each subject.</p>
+
+<p>With the era now existing, these old issues and customs
+are dead and buried out of sight and we would not
+be mad enough to revive them, if we could. They
+played no unimportant part, however, in the pathetic
+drama of the evolution of the race and we ought to
+erect monuments to their memory, as it were, and occasionally
+wander back to scatter flowers upon the monumental
+shaft, without deserting the live issues and
+duties at present confronting us.</p>
+
+<p>When we contemplate the lessons of the past, as presented
+in these “Legal Antiquities,” we can but realize
+the plain truth, expressed by William Knox, that “We
+are the same our fathers have been,” for if we had
+lived and moved and had our being in the dark days
+when these customs obtained, we would have considered
+them in the same light that our fore-fathers viewed
+them and this should make us charitable toward these
+frailties and mistakes of the past; we should be comforted
+with the reflection that such institutions are but
+mile-stones of the centuries, marking the rapid progress
+of the race, but when we read of these customs
+of the men and women of antiquity, we can but realize
+the truth of the words of Longfellow, that</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“... the world is very old,</div>
+ <div class="verse indent0">And generations pass as they have passed,</div>
+ <div class="verse indent0">A troop of shadows, moving with the sun.”</div>
+ </div>
+</div>
+</div>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_1" href="#FNanchor_1" class="label">[1]</a> Exodus, XXIII., 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_2" href="#FNanchor_2" class="label">[2]</a> Judge Davidson, of Texas, in Ex parte Martinez, 145 S. W. Rep.
+959, 1023.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_12"></a>[12]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_I">CHAPTER I.<br>
+<span class="smcap">Marriage Laws and Customs.</span></h2>
+
+</div>
+
+<p>The term marriage was defined, in the Institutes of
+Justinian, as the lawful union of a man and a woman,
+including an inseparable association of their lives.<a id="FNanchor_3" href="#Footnote_3" class="fnanchor">[1]</a></p>
+
+<p>Written almost fourteen centuries ago, few, if any,
+of the many definitions of marriage, improve upon that
+given in the Institutes of this old philosopher-lawyer-Emperor
+of the Romans.<a id="FNanchor_4" href="#Footnote_4" class="fnanchor">[2]</a></p>
+
+<p>As the basis of the marriage contract is the necessity
+of society for some rule for the appropriation of the
+opposite sexes to one another and the protection of that
+relation, when once established, it is in one form or another,
+the oldest institution of man and the source of
+our most antique laws and customs.<a id="FNanchor_5" href="#Footnote_5" class="fnanchor">[3]</a></p>
+
+<p>The Chinese inform us that in the beginning, human
+beings, like other animals, without morality or community
+laws, wandered through the plains and forests, using
+their women in common; that the offspring of such
+unions knew their mothers, but rarely knew who their
+fathers were and that this custom continued among
+men, until the Emperor Fou-hi established the marriage
+custom.<a id="FNanchor_6" href="#Footnote_6" class="fnanchor">[4]</a></p>
+
+<p>While the ancient “Heathen Chinese” were thus<span class="pagenum"><a id="Page_13"></a>[13]</span>
+holding their women in common, there is evidence that
+among the old Teutons and Hindus, the “marriage by
+capture” and “rape marriages” were still recognized
+by law, long before the “bride-sale” or “sale marriages,”
+so generally obtaining in ancient Assyria and
+Babylon, were established in Germany.<a id="FNanchor_7" href="#Footnote_7" class="fnanchor">[5]</a></p>
+
+<p>Some historians claim that, in the early days of
+heathenry, capture was the only method used by young
+men for securing their brides and the supply of consorts
+depended upon the strength of the male, rather
+than the existence of “the tender passion.”<a id="FNanchor_8" href="#Footnote_8" class="fnanchor">[6]</a></p>
+
+<p><span class="pagenum"><a id="Page_14"></a>[14]</span></p>
+
+<p>But the pictures of violence obtaining in these ancient
+days of heathenry are so obscured by the mists
+of the past and such a large field is left for the construction
+of ingenious theories, surrounded by romances
+of connubial bliss, resulting from this early custom
+of primitive society, that notwithstanding the general
+popularity of the theory of “marriage by capture,”
+some of the most eminent authorities are inclined to
+deny that such a custom ever existed at all.<a id="FNanchor_9" href="#Footnote_9" class="fnanchor">[7]</a></p>
+
+<p>Some writers maintain that the rights of the individual
+were never more clearly defined in marriage, than
+by primitive man, and that this is in accord with the
+common tendency of the male, to attribute a religious
+meaning to the ordinary intercourse with woman.<a id="FNanchor_10" href="#Footnote_10" class="fnanchor">[8]</a></p>
+
+<p>The Biblical theory of the custom, dates from the
+command to our first parents, in Genesis: “Be fruitful,
+and multiply and replenish the earth.”<a id="FNanchor_11" href="#Footnote_11" class="fnanchor">[9]</a></p>
+
+<p>In the beginning, we find that from the rib, which
+the Lord had taken from Adam, he made a woman
+“<i>and he brought her unto the man</i>.”<a id="FNanchor_12" href="#Footnote_12" class="fnanchor">[10]</a></p>
+
+<p>From Christian testimony, we have the evidence of
+the first book of Moses, upon the antiquity of this institution,
+for when Shechem, the son of Hamor, after defiling
+Dinah, the daughter of Leah, longed for her, in
+marriage, his father went to Jacob and his sons and
+communed with them, saying: “The soul of my son
+Shechem longeth for your daughter; I pray you give
+her him to wife. And make ye marriages with us, and<span class="pagenum"><a id="Page_15"></a>[15]</span>
+give your daughters unto us and take our daughters
+unto you.”<a id="FNanchor_13" href="#Footnote_13" class="fnanchor">[11]</a></p>
+
+<p>So according to the Bible story, we find that the institution
+of marriage obtained seventeen centuries before
+Christ and these old patriarchs were plighting the
+troth of their son and daughter and talking of dowries
+and marriage portions, much as the parents of the
+twentieth century youth now arrange such matters.</p>
+
+<p>There has always been three principal forms of marriage,
+from the earliest historical times, monogamy, or
+the marriage of one man to one woman at a time, polygamy,
+or the marriage of one man to several women at
+the same time, and polyandry, or the marriage of one
+woman to two or more husbands at the same time.<a id="FNanchor_14" href="#Footnote_14" class="fnanchor">[12]</a></p>
+
+<p>Since the days of our first parents, according to the
+Bible story, monogamy has been the institution best
+suited to the progress of society and the proper evolution
+of the human race, for the most progressive nations
+of the world’s history have embraced monogamy as a
+rule of social conduct.</p>
+
+<p>The old Hebrews, however, made wonderful strides
+while practicing polygamy, an institution established by
+Lamech, in the sixth generation after Adam, which grew
+apace with the progress of the race, until in Solomon’s
+time, the king had acquired a round thousand women,
+from the different nationalities of the world, seven
+hundred princesses as wives and three hundred concubines.<a id="FNanchor_15" href="#Footnote_15" class="fnanchor">[13]</a></p>
+
+<p>Polygamy was also practiced in Persia and is to-day,
+in Turkey and other Oriental countries, but under Roman<span class="pagenum"><a id="Page_16"></a>[16]</span>
+rule it slowly died out in the east. It was prohibited
+by Diocletian and other preceding Emperors
+and except in the single instance of the Mormons, in
+Utah, it has never reappeared in any countries subject
+to either the Roman or Teutonic laws.<a id="FNanchor_16" href="#Footnote_16" class="fnanchor">[14]</a></p>
+
+<p>Polyandry no doubt had its origin in unfertile regions,
+in the endeavor to limit the population to the resources
+of the district; it is almost an obsolete custom,
+but is still practiced in parts of India, Thibet and Ceylon.<a id="FNanchor_17" href="#Footnote_17" class="fnanchor">[15]</a></p>
+
+<p>The marriage customs of the Romans furnish the
+basis for the marriage laws of the civilized world, and
+even the Hebrew and Teutonic influence is small compared
+to that exerted upon this institution, by the Roman
+law. The general conception of the marriage relation,
+by the Romans, was an exalted one, as it was
+regarded as an equal partnership in the whole of life,
+effecting an equal distribution in both the secular and
+sacred rights of the individuals.<a id="FNanchor_18" href="#Footnote_18" class="fnanchor">[16]</a></p>
+
+<p>The three forms of marriage, by the early Roman
+law, were (1) <i>Confarreatio</i>, consisting of a religious<span class="pagenum"><a id="Page_17"></a>[17]</span>
+ceremony, ending in the sacrifice of an ox, and the distribution
+of a broken wheaten cake, by a priest; (2)
+<i>Coemptio in manum</i>, a conveyance or formal sale of the
+woman, to the man, and (3) <i>Usus</i>, or the right of a wife,
+by prescription, arising from the cohabitation of the
+wife with the husband, for one year, without an absence
+for over three consecutive nights.<a id="FNanchor_19" href="#Footnote_19" class="fnanchor">[17]</a></p>
+
+<p>If the woman lived with the man without either the
+religious ceremony or the formal sale, she did not become
+his wife, unless she had lived with him for a year,
+without absenting herself for three consecutive nights.<a id="FNanchor_20" href="#Footnote_20" class="fnanchor">[18]</a></p>
+
+<p>This latter form was called “passing into the hand”
+of her husband and until this Hand power had been created,
+the property rights of the wife remained unaffected
+by the marriage. Marriages with Hand in an
+early day were almost universal, however, for the
+women did not prefer the free marriage, which would
+place them, in law, outside the legal family of the husband.<a id="FNanchor_21" href="#Footnote_21" class="fnanchor">[19]</a>
+Marriages within the Levitical degrees were
+prohibited by the early Roman Emperors, and while
+first cousins might lawfully marry, until the end of the
+Republic,<a id="FNanchor_22" href="#Footnote_22" class="fnanchor">[20]</a> the Emperor Theodosius prohibited their
+marriage under pain of death by burning.<a id="FNanchor_23" href="#Footnote_23" class="fnanchor">[21]</a></p>
+
+<p><span class="pagenum"><a id="Page_18"></a>[18]</span></p>
+
+<p>Uncles and nieces and aunts and nephews were prohibited
+from marrying, until the period of the Emperor
+Claudius, who desired to marry his brother’s daughter,
+Agrippina, and so passed a decree of the Senate allowing
+such a marriage.<a id="FNanchor_24" href="#Footnote_24" class="fnanchor">[22]</a></p>
+
+<p>Concubinage was a “permitted connection,” under
+the Roman law, from the earliest times, down to the period
+of the philosopher Emperor, Leo, A. D. 887 when
+it was prohibited by law.<a id="FNanchor_25" href="#Footnote_25" class="fnanchor">[23]</a> The Justinian Code recognized
+the legality of the relation and fixed the legal and
+property status of the concubine and her progeny and
+various Christian Emperors, in the early days of the
+Empire passed laws regulating the relation known as
+<i>Concubinatus</i>.<a id="FNanchor_26" href="#Footnote_26" class="fnanchor">[24]</a></p>
+
+<p>The woman was left in the same relation as the law
+found her; she was not raised to the level of the husband
+and while her children were entitled to support
+from the father, they were not legitimate, but could inherit
+from the mother.<a id="FNanchor_27" href="#Footnote_27" class="fnanchor">[25]</a> Under the Roman law, however,
+children born in concubinage, could be legitimated
+by the subsequent marriage of their parents,<a id="FNanchor_28" href="#Footnote_28" class="fnanchor">[26]</a> and this
+early Roman law was the foundation for the custom
+obtaining in England, France, Germany, Normandy and<span class="pagenum"><a id="Page_19"></a>[19]</span>
+Scotland, prior to the Norman Conquest, of legitimating
+the children born out of lawful wedlock, by the subsequent
+marriage of their parents. At the wedding of
+a couple having children prior to their marriage, it was
+the general custom, in the countries named, to place the
+children under a cloak, or mantle, which was also
+spread over the parents, and the children of such a
+union were thereafter known in the law, as “mantle
+children,” to distinguish them from children regularly
+born in lawful wedlock.<a id="FNanchor_29" href="#Footnote_29" class="fnanchor">[27]</a></p>
+
+<p>According to Selden, this ceremony was observed, in
+England, when the children of John of Gaunt and Catherine
+Swinford were legitimated by Parliament,<a id="FNanchor_30" href="#Footnote_30" class="fnanchor">[28]</a> and
+in Normandy, Duke Richard espoused Gunnora, “in
+Christian fashion,” and “the children were covered
+with the mantle.”<a id="FNanchor_31" href="#Footnote_31" class="fnanchor">[29]</a></p>
+
+<p><span class="pagenum"><a id="Page_20"></a>[20]</span></p>
+
+<p>Neither the ancient Hebrews, Greeks, Mohammedans
+or Romans, regarded marriage as a religious ordinance,
+but the relation could be established, according to the
+laws and customs of all these ancient people, by the
+interchange of consent.<a id="FNanchor_32" href="#Footnote_32" class="fnanchor">[30]</a></p>
+
+<p>In Cnut’s time, in England, we find that he made laws
+to prevent the sale of a woman to a man whom she disliked,<a id="FNanchor_33" href="#Footnote_33" class="fnanchor">[31]</a>
+but even at this stage of English society, the
+church approved these sale marriages and condoned the
+old betrothals of the Anglo-Saxons, and preserved the
+forms of ceremonies which still constitute the curious
+cabinet of antiquities of the English church.<a id="FNanchor_34" href="#Footnote_34" class="fnanchor">[32]</a></p>
+
+<p>The early Christian church, however, did not treat
+marriage as a sacrament; the doctrine that marriage
+was a sacrament was evolved from the Fifth Chapter
+of the Epistle of St. Paul, to the Ephesians and it was
+not until the Council of Trent, in the year 1563 that the
+Roman Catholic Church required the celebration of
+marriage to be accompanied by a religious ceremony.<a id="FNanchor_35" href="#Footnote_35" class="fnanchor">[33]</a></p>
+
+<p><span class="pagenum"><a id="Page_21"></a>[21]</span></p>
+
+<p>In England, as early as the seventh century, the concern
+of the church about all sins pertaining to the
+flesh, caused it to raise its voice upon questions concerning
+marriage and divorce.<a id="FNanchor_36" href="#Footnote_36" class="fnanchor">[34]</a></p>
+
+<p>By the middle of the twelfth century according to the
+laws of England, marriage was held to appertain to
+the spiritual forum.<a id="FNanchor_37" href="#Footnote_37" class="fnanchor">[35]</a></p>
+
+<p>In the memorable law suit of Richard de Anesty, in
+1143, a marriage solemnly celebrated by the church, and
+from which a child had been born, was declared to be
+void in favor of a prior marriage, constituted by a mere
+exchange of consenting words, without the formality of
+a religious ceremony at all.<a id="FNanchor_38" href="#Footnote_38" class="fnanchor">[36]</a></p>
+
+<p>Soon after this decision, Glanville acknowledged the
+jurisdiction of the ecclesiastical courts upon all issues
+touching the validity of marriage and because of the
+acknowledged inability of the king’s court to solve the
+issue, where the legitimacy of a litigant had been
+raised, the canon law was subsequently looked to in all
+such cases.<a id="FNanchor_39" href="#Footnote_39" class="fnanchor">[37]</a></p>
+
+<p>In 1215, at the Council of Lateran, Pope Innocent III.
+extended to the whole western portion of Christendom
+the custom of publishing “banns of marriage,” calling
+upon all men to declare any just cause of impediment, if
+any could be urged to the union and from this time on,<span class="pagenum"><a id="Page_22"></a>[22]</span>
+marriages with banns, had certain legal advantages
+over a marriage without banns, but still the unblessed,
+formless marriage was a marriage, before the law.<a id="FNanchor_40" href="#Footnote_40" class="fnanchor">[38]</a></p>
+
+<p>During the reign of Henry II., Alexander III. decreed
+that a marriage by mere consent, in terms of a present,
+existing contract, would be given precedence over a
+later marriage by another man with the same woman,
+duly solemnized in religious form, and followed by
+physical union.<a id="FNanchor_41" href="#Footnote_41" class="fnanchor">[39]</a> It seems a strong case, to give effect
+to the bare consent, in present form, “unhallowed and
+unconsummated” as against a solemn formal contract,
+followed by a consummated union, yet this decree was
+consistent with the ecclesiastical law, as interpreted
+from the middle of the twelfth century until the Council
+of Trent, and no religious ceremony or the presence
+of a priest was essential to constitute a valid marriage,
+before the catholic church.<a id="FNanchor_42" href="#Footnote_42" class="fnanchor">[40]</a></p>
+
+<p>In 1254 the interesting case of William de Cardunville,
+a tenant in chief of the Crown, came before the
+court, upon an <i>inquisitio post-mortem</i>, to determine
+which of two conflicting claimants was his rightful heir.
+He had solemnly espoused one Alice, with whom he had
+lived for sixteen years and had several children, the
+youngest being a son, four years old, named Richard.
+Long before his espousel of Alice, he had lived with and
+had a son by one Joan, and this son was also named
+Richard and was twenty-four years old at the death of
+his father. Joan established a common-law marriage,
+without the religious ceremony, and she was adjudged<span class="pagenum"><a id="Page_23"></a>[23]</span>
+the rightful wife of the deceased and her son, the first
+begotten Richard, was awarded the livery.<a id="FNanchor_43" href="#Footnote_43" class="fnanchor">[41]</a></p>
+
+<p>From an early date, the interpretation of the English
+Courts, as to the validity of a marriage based upon
+a present mutual consent of the parties, was followed
+in the United States, with the exception of Massachusetts,
+Maryland, West Virginia and Kentucky.</p>
+
+<p>In the year 1810, Chief Justice Parsons, then on the
+bench of the Supreme Court of Massachusetts, rendered
+a decision, in which he denied that according to the
+common law a valid marriage could be made, by the
+mutual agreement of the parties alone.<a id="FNanchor_44" href="#Footnote_44" class="fnanchor">[42]</a></p>
+
+<p>Chancellor Kent, however, in 1809, as Chief Justice
+of the Supreme Court of New York, held that:</p>
+
+<div class="blockquote">
+
+<p>“No formal solemnization of marriage was requisite.
+A contract of marriage, made <i>per verba de praesenti</i>,
+amounts to an actual marriage and is as valid as if
+made <i>in facie ecclesiae</i>.”<a id="FNanchor_45" href="#Footnote_45" class="fnanchor">[43]</a></p>
+
+</div>
+
+<p>This latter exposition of the common law of England
+has been generally followed in the United States, and
+may be said to obtain, generally, in all the states, other
+than those mentioned above, except where the local
+statutes provide otherwise.<a id="FNanchor_46" href="#Footnote_46" class="fnanchor">[44]</a></p>
+
+<p>Clearly, by the law of nature, marriage may be constituted
+by the mutual present consent of two competent
+persons, of the opposite sex, without other formality
+than the performed inclination of the individuals
+concerned and so the common, or unwritten law, recognized<span class="pagenum"><a id="Page_24"></a>[24]</span>
+the legality of such a contract. The law of nature
+was adopted as the surest guide to the law of man, in
+this relation.</p>
+
+<p>Considerable uncertainty and some confusion resulted
+in England as to the essentials of a valid marriage
+and the acts necessary to constitute a marriage,
+prior to the eighteenth century, but during the reign of
+George II., in 1753, a statute was passed,<a id="FNanchor_47" href="#Footnote_47" class="fnanchor">[45]</a> requiring all
+marriages to be celebrated by a clergyman and in a
+church, unless by special dispensation by the Archbishop
+of Canterbury. This statute was repealed in
+1836 when a purely civil marriage before only a Registrar,
+was permitted by the law of England, in lieu of
+the ecclesiastical ceremony.<a id="FNanchor_48" href="#Footnote_48" class="fnanchor">[46]</a></p>
+
+<p>Touching the issue as to the validity of a marriage
+not solemnized by religious ceremony, is the interesting
+and famous case of The Queen vs. Millis,<a id="FNanchor_49" href="#Footnote_49" class="fnanchor">[47]</a> wherein the
+House of Lords, erroneously decided that such a marriage
+was void, according to the English law, in the
+year 1843.</p>
+
+<p>The Irish Court of King’s Bench was equally divided<span class="pagenum"><a id="Page_25"></a>[25]</span>
+upon the issue and in the House of Lords, after
+the decision of the English judges had been given
+against the validity of the marriage at which no clergyman
+had been present, Lords Lyndhurst, Cottenham
+and Abinger were for holding the marriage void, while
+Lords Brougham, Denman and Campbell, were in favor
+of its validity, but on account of the precise form in
+which the question was put to the House, the effect of
+the division was to hold the marriage void, and thus a
+mere accident gave the decision in favor of the erroneous
+view that from the earliest time in English law, the
+presence of an ordained clergyman was essential to the
+celebration of a valid marriage, when, as we have seen,
+from the decisions and history of the law, this was not
+the case, either in England or according to the Roman
+law, until the Council of Trent.<a id="FNanchor_50" href="#Footnote_50" class="fnanchor">[48]</a></p>
+
+<p>But while both the temporal and spiritual courts
+recognized the validity of marriages based alone upon
+mutual consent, followed by a physical union, the religious
+ceremony in an early day, was held essential to
+endow the wife with the right to the husband’s land.
+Bracton tells us that the endowment can only be made at
+the church door, for while the marriage may be contracted
+elsewhere, the bride can only be endowed at the
+door of the church.<a id="FNanchor_51" href="#Footnote_51" class="fnanchor">[49]</a></p>
+
+<p>This rule, however, was of course inconsistent with<span class="pagenum"><a id="Page_26"></a>[26]</span>
+the recognition of the validity of the marriage and both
+the ecclesiastic and temporal courts went to the extreme
+limit to legitimize the offspring of marriages, not
+the result of a wilful criminal relation. Retroactive and
+putative marriages were recognized, both in the temporal
+and ecclesiastical courts, when the legitimacy of
+children depended upon such a construction and in
+cases where the parents had married within the prohibited
+degrees of consanguinity, or if a woman, in good
+faith, married a man already married and believed that
+he was single and had children by him, the children
+would be held legitimate and capable of inheriting, under
+the law.<a id="FNanchor_52" href="#Footnote_52" class="fnanchor">[50]</a></p>
+
+<p>The courts, in order to legitimize the offspring of
+doubtful marriages, went the full limit, in upholding
+the marriage relation from a very early day, but the
+consort who abandoned her husband to dwell with her
+adulterer, was written beyond the pale of the law. By
+an old statute, of the reign of Edward I., a woman who
+eloped and abode with her adulterer was punished by a
+loss of dower<a id="FNanchor_53" href="#Footnote_53" class="fnanchor">[51]</a> and this statute was enforced, in the
+case of William and Margaret Paynel, which originated
+in 1302.<a id="FNanchor_54" href="#Footnote_54" class="fnanchor">[52]</a></p>
+
+<p>These parties petitioned the king for dower that was
+due the woman, as the widow of her first husband, John
+de Camoys. It was charged that Margaret had eloped
+with William and committed adultery with him. In
+answer, William and Margaret produced a solemn charter,
+whereby her first husband had “given, granted, released<span class="pagenum"><a id="Page_27"></a>[27]</span>
+and quit-claimed” the said Margaret to William.
+They also introduced evidence to the effect that after
+they went to live together they had been charged with
+adultery in the court Christian, and that by the oath of
+compurgators, among whom were married and unmarried
+ladies and a prioress, they had successfully met
+this charge and they offered to leave to the decision of
+a jury the issue whether or not they were guilty of
+adultery in living together. The court, however, in
+a lengthy decree, held that the facts on their face constituted
+adultery and since no reconciliation of the first
+husband was shown, the woman was not entitled to
+dower, under this statute.<a id="FNanchor_55" href="#Footnote_55" class="fnanchor">[53]</a></p>
+
+<p>This illustrates the easy morality of the olden times,
+so contrary to our present standards, touching the marital
+relation, yet this case is not a parallel to many
+which could be cited in the golden days of Greece and
+Rome. So little sanctity was attached to the marital
+relation in Greece, even in the days of Pericles, that
+men were accustomed to loan their wives to their
+friends and the literature of the period made poetry of
+marital infidelity and fornication and adultery seemed
+about the commonest employment of both individuals
+and gods and goddesses. The Romans had more of
+the religious tendencies than the Greeks, but it is said
+that the Younger Cato loaned his wife, Marcia, to the
+orator Hortensius and took her back again, after his
+death.<a id="FNanchor_56" href="#Footnote_56" class="fnanchor">[54]</a></p>
+
+<p><span class="pagenum"><a id="Page_28"></a>[28]</span></p>
+
+<p>Such conduct seems almost unbelievable, because so
+contrary to the natural moral instincts, yet the natural
+selection between two adults of the opposite sexes, although
+in derogation of the rights of the life-partner of
+either, seems hardly so depraved as the consent by the
+natural parents, to the marriage of infants of tender
+years, which custom was so prevalent in England and
+France in the past centuries.</p>
+
+<p>During the middle ages, in England, the marriages
+of little children were frequently arranged by their parents,
+for the purpose of avoiding wardship and to prevent
+the children from forming improper attachments,
+or to effect advantageous family connections for the
+parents.</p>
+
+<p>History records that Thomas, Lord Berkeley, was
+contracted to Margaret, daughter of Gerald Warren,
+Lord Lisle, in the forty-first year of Edward III., when
+the girl was only seven years old, and because of her
+tender years, it was stipulated that she should remain
+with her father for four years, but on account of sickness
+in the family, they were married when she was
+eight years old.<a id="FNanchor_57" href="#Footnote_57" class="fnanchor">[55]</a></p>
+
+<p>Maurice, fourth Lord Berkeley, was knighted at
+seven years of age, to prevent his wardship, and he was<span class="pagenum"><a id="Page_29"></a>[29]</span>
+married at the age of eight, to Elizabeth, daughter of
+Lord Spencer, when the bride was also but eight years
+old.<a id="FNanchor_58" href="#Footnote_58" class="fnanchor">[56]</a></p>
+
+<p>Hundreds of similar cases could be mentioned in
+France and England, and in tropical countries, where
+the women develop at an earlier age, the marriages
+occur at a corresponding earlier age. In Brazil, in the
+past century parents married their children when still
+in years of infancy and the case of a Brazilian traveler,
+enroute to England, who demanded a half-fare ticket
+for his wife, who was under twelve years of age, occurred
+in the year 1853.<a id="FNanchor_59" href="#Footnote_59" class="fnanchor">[57]</a></p>
+
+<p>We are also told that the Hungarians of the seventeenth
+century often betrothed their children while still
+in their cradles, and the marriages were celebrated at
+the earliest possible age.<a id="FNanchor_60" href="#Footnote_60" class="fnanchor">[58]</a></p>
+
+<p>The law, which can never rise superior to the prevalent
+sense of right in a given community, recognized the
+validity of these child marriages, in these several countries,
+just as it validated the “sale marriages” of the
+old Saxon days<a id="FNanchor_61" href="#Footnote_61" class="fnanchor">[59]</a> and in early feudal times recognized<span class="pagenum"><a id="Page_30"></a>[30]</span>
+the validity of exactions known as “Maiden-rent,” a
+sum paid to the Lord of the Manor, in the nature of a
+fine, in consideration of his relinquishment of his accustomed
+right of spending the first night with the bride
+of his tenant.<a id="FNanchor_62" href="#Footnote_62" class="fnanchor">[60]</a></p>
+
+<p>As the relics of a barbarous age, such licentious customs,
+like the evidences of genius and depravity frequently
+found co-existent in the same individual, are interesting<span class="pagenum"><a id="Page_31"></a>[31]</span>
+from a historical standpoint, as existing facts
+connected with the given institutions of a past age and
+also because many of the ancient customs, in altered
+form, furnish the basis for the later customs and practices,
+gradually changed, with the passing years, to
+meet the different conditions and institutions of later
+periods.</p>
+
+<p>The custom of giving a dowry, or marriage portion,
+which has obtained from an ancient period, is no doubt
+the result of the old practice of paying for the wife in
+money, the presents, land, or sums paid by way of settlement
+being a mere modification of the old sale and
+purchase of the bride by the husband.<a id="FNanchor_63" href="#Footnote_63" class="fnanchor">[61]</a></p>
+
+<p>In patriarchial days, we find Shechem, the son of
+Hamer, negotiating with old Jacob and his sons, for
+the marriage of Dinah and he said unto them: “Ask
+me never so much dowry and gift and I will give according
+as ye shall say unto me; but give me the damsel to
+wife.”<a id="FNanchor_64" href="#Footnote_64" class="fnanchor">[62]</a></p>
+
+<p>The <i>donatio propter nuptias</i>,<a id="FNanchor_65" href="#Footnote_65" class="fnanchor">[63]</a> of the Romans, and
+the old marriage dowry, the source of so much legislation
+and litigation in ancient England, France and other
+continental countries, is traceable, directly or indirectly
+to this old practice. Indeed, the oldest known laws
+treat of the marriage dowry, as we find that the code
+of Hammurabi, written 2250 years before Christ provided
+for the return of the dowry, in case of the divorcement
+of a barren wife.<a id="FNanchor_66" href="#Footnote_66" class="fnanchor">[64]</a></p>
+
+<p><span class="pagenum"><a id="Page_32"></a>[32]</span></p>
+
+<p>Money was given the bride, from an early day in
+France, and we find that when Clovis married the Princess
+Clotilde, he sent, by proxy, a sou and a denier,
+which became by law, the usual marriage offering, in
+that country.<a id="FNanchor_67" href="#Footnote_67" class="fnanchor">[65]</a> Caesar speaks of the marriage settlement,
+as a custom he found to exist amount the ancient
+Gauls;<a id="FNanchor_68" href="#Footnote_68" class="fnanchor">[66]</a> it obtained among the Hebrews, at an early
+date<a id="FNanchor_69" href="#Footnote_69" class="fnanchor">[67]</a> and has come to be a part of the marriage laws
+of most of the civilized countries.<a id="FNanchor_70" href="#Footnote_70" class="fnanchor">[68]</a></p>
+
+<p>Under the old Angle-Saxon law, dower could be assigned
+only at the church door.<a id="FNanchor_71" href="#Footnote_71" class="fnanchor">[69]</a> Speaking on this subject,
+Littleton says:</p>
+
+<div class="blockquote">
+
+<p>“When he cometh to the church door to be married
+there, after affiance and troth plighted, he endoweth the
+woman of his whole land, or of the half, of other lesser
+part thereof, and there openly doth declare the quantity
+and the certainty of the land she shall have for her
+dower.”<a id="FNanchor_72" href="#Footnote_72" class="fnanchor">[70]</a></p>
+
+</div>
+
+<p>Accordingly, we find, when Edward I. married Marguerite
+of France, in 1299, he endowed her at the door
+of Canterbury Cathedral, in order that the gift could be<span class="pagenum"><a id="Page_33"></a>[33]</span>
+witnessed by all the persons who had assembled to see
+the marriage ceremony.<a id="FNanchor_73" href="#Footnote_73" class="fnanchor">[71]</a></p>
+
+<p>Selden says that the use of marriage rings, grew out
+of the old custom of giving the bride a dowry, the ring
+being given as a symbol of the husband’s good will, in
+lieu of the dowry money, of previous days.<a id="FNanchor_74" href="#Footnote_74" class="fnanchor">[72]</a></p>
+
+<p>However this may be, the custom of giving wedding
+rings to the bride dates from an early period. We find
+that Isaac propitiated the favor of Rebekah by presenting
+her with a massive ear-ring and two bracelets.<a id="FNanchor_75" href="#Footnote_75" class="fnanchor">[73]</a>
+The betrothal ring was used in ancient Rome, and the
+Christian church no doubt adopted the wedding ring,
+from the pagan custom of the Italians, as a convenient
+sign of marriage.<a id="FNanchor_76" href="#Footnote_76" class="fnanchor">[74]</a></p>
+
+<p>In the ninth century the ring was used by the Romans
+for betrothal purposes and not as an insignia of<span class="pagenum"><a id="Page_34"></a>[34]</span>
+marriage;<a id="FNanchor_77" href="#Footnote_77" class="fnanchor">[75]</a> it was used by the Anglo-Saxons, on the betrothal
+of their infant children, the ring being placed
+on the right hand, until the marriage, when it was transferred
+to the left,<a id="FNanchor_78" href="#Footnote_78" class="fnanchor">[76]</a> and thus grew the custom, until
+finally, it became a part of the English law, that a wedding
+ring should be used at all church marriages.<a id="FNanchor_79" href="#Footnote_79" class="fnanchor">[77]</a>
+This custom is still retained by the Catholics, among
+whom the ring is consecrated by the priest, sprinkled
+with holy water, in the form of a cross and then returned
+to the bridegroom.<a id="FNanchor_80" href="#Footnote_80" class="fnanchor">[78]</a></p>
+
+<p>The superstitions of olden times, which attached to
+the marriage ceremony, as celebrated in the early days
+of “little knowledge,” as some writers refer to the antique
+periods of the human race, are also responsible
+for the present custom of throwing rice, old shoes,
+stockings, bouquets, and such like practices, at marriages.</p>
+
+<p>The custom of throwing rice was no doubt borrowed
+from the ancient Persians, as rice was no inconsiderable
+portion of the marriage ceremony in Persia.<a id="FNanchor_81" href="#Footnote_81" class="fnanchor">[79]</a> Rice was<span class="pagenum"><a id="Page_35"></a>[35]</span>
+considered an emblem of fruitfulness and the contracting
+parties, after their betrothal, met at midnight, on a
+bed, in the presence of two sponsors. The sponsor for
+the man, touched the woman’s forehead and asked her
+if she would have the man; the same ceremony was gone
+through with by the sponsor for the woman and the
+hands of the contracting parties were then joined and
+rice was scattered over them and prayers for their
+fruitfulness were offered.<a id="FNanchor_82" href="#Footnote_82" class="fnanchor">[80]</a></p>
+
+<p>Rice also constitutes an important part in the marriages
+of the Hindus, the Brahmins, Javanese, the inhabitants
+of Elba and is quite generally used, in other
+European countries.<a id="FNanchor_83" href="#Footnote_83" class="fnanchor">[81]</a></p>
+
+<p>The custom of throwing a shoe after the bridal couple,
+so generally followed, in England, Scotland and the
+United States, as a token of good luck, is directly traceable
+to the old Jewish law, making the shoe a sign of
+renunciation of dominion or authority, as well as a symbol
+of exchange.</p>
+
+<p>Thus, under the Mosaic law, the brother of a childless
+man was bound to marry his widow and until he renounced<span class="pagenum"><a id="Page_36"></a>[36]</span>
+his right, she could not marry another. If refused,
+the woman was obliged to “loose his shoe from
+off his foot” and “spit before his face,” as an assertion
+of her complete independence.<a id="FNanchor_84" href="#Footnote_84" class="fnanchor">[82]</a> The custom was followed,
+according to Bible evidence, in the espousal between
+Ruth and Boaz, for “as it was the custom in
+Israel concerning changing, that a man plucked off his
+shoe and delivered it to his neighbor,” so the kinsman
+of this famous woman plucked off his shoe and gave it
+to Boaz, as a token of his renunciation of Ruth and of
+Boaz’s right to marry her.<a id="FNanchor_85" href="#Footnote_85" class="fnanchor">[83]</a></p>
+
+<p>That this custom was later used by the early Christians,
+would seem to be confirmed by the story connected
+with the proposal of the Emperor Vladimir to the
+daughter of Raguald, for when asked if she would not
+marry the Emperor, she replied: “I will not take off
+my shoe to the son of a slave.”<a id="FNanchor_86" href="#Footnote_86" class="fnanchor">[84]</a> And as a part of the
+betrothal, in the early Anglo-Saxon days, we read that
+when the marriage was completed, the father of the
+bride took off her shoe and handed it to the bridegroom,
+who touched her on the head with it, as a token of the
+exchange and of his power over her.<a id="FNanchor_87" href="#Footnote_87" class="fnanchor">[85]</a></p>
+
+<p>Stocking throwing, at weddings, in England, has existed
+from a very early day and is said to be purely a
+British custom.<a id="FNanchor_88" href="#Footnote_88" class="fnanchor">[86]</a></p>
+
+<p><span class="pagenum"><a id="Page_37"></a>[37]</span></p>
+
+<p>A letter describing the marriage, at court, of Sir
+Philip Herbert, in 1604, says that “at night there was
+sewing into the sheet, casting off the bride’s left hose,
+with many other pretty sorceries.”<a id="FNanchor_89" href="#Footnote_89" class="fnanchor">[87]</a></p>
+
+<p>In Fletcher’s Poems, written in 1656, is a verse descriptive
+of Clarinda’s wedding, referring to this old
+custom:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“This clutter o’er, Clarinda lay,</div>
+ <div class="verse indent0">Half-bedded, like the peeping day</div>
+ <div class="verse indent2">Behind Olympus’ cap;</div>
+ <div class="verse indent0">Whiles at her head each twitt’ring girle</div>
+ <div class="verse indent0">The fatal stocking quick did whirle</div>
+ <div class="verse indent2">To know the lucky hap.”</div>
+ </div>
+</div>
+</div>
+
+<p>It is reported that this custom, as well as that of putting
+the bride to bed, was followed at the wedding of
+Mary, Queen of Scots, to Lord Darnley; that the same
+ceremony was gone through with, at the wedding of
+Mary II. and the sedate Prince of Orange and that this
+custom was followed at nearly all the marriages of the
+crowned heads during the middle ages, in England, until
+George III. set aside the joyful custom of “posset-drinking
+and stocking throwing,” on his wedding night.<a id="FNanchor_90" href="#Footnote_90" class="fnanchor">[88]</a></p>
+
+<p>The common law liability of the community property
+of the wife and her husband for the ante-nuptial debts
+of his wife, gave rise to a peculiar custom, in England,<span class="pagenum"><a id="Page_38"></a>[38]</span>
+known as “Smock-marriages,” or “Marriage in a
+Shift.” This custom obtained from early Saxon days
+into the eighteenth century and the debtor bride often
+came to the wedding arrayed only in a plain white
+“smock” or “shift,” as a public declaration or warning
+to her creditors that she took no property to her
+husband, as a basis for charging him with responsibility
+for her debts.<a id="FNanchor_91" href="#Footnote_91" class="fnanchor">[89]</a></p>
+
+<p>This eccentric custom, known as “marriage in a
+smock,” in England, under which a widow was married
+with nothing on but a “shift,” or “smock,” upon the
+theory that her second husband would thereby escape
+liability for the debts contracted by her former husband,
+was also followed in the Colonies.</p>
+
+<p>This notion that a bride who lacked modesty, as well
+as money could throw off her debts with her dress, by
+going to church in her smock or under garment and
+thus let her creditors “shift” for themselves, finds
+many examples in the English cases during the seventeenth
+and eighteenth centuries.</p>
+
+<p>On October 17, 1714, Anne Sellwood, of Chilters, All
+Saints, Wiltshire and John Bridmore, were united in
+the holy bonds of matrimony and against the record in
+the parish register occurs the memorandum: “The
+aforesaid Anne Sellwood was married in her shift,
+without any clothes or head-gear on.”<a id="FNanchor_92" href="#Footnote_92" class="fnanchor">[90]</a></p>
+
+<p>In 1766 a Whitehaven bride also sought to attain the
+same end, by going to church, as became any decent<span class="pagenum"><a id="Page_39"></a>[39]</span>
+woman, undressing herself to her sole under-garment
+for the ceremony and donning her clothes again as
+soon as the knot was tied.<a id="FNanchor_93" href="#Footnote_93" class="fnanchor">[91]</a> And it is recorded that
+somewhere between the years 1838 and 1844, a Lincolnshire
+curate officiated at a wedding where the bride
+stood before him, enveloped only in a sheet.<a id="FNanchor_94" href="#Footnote_94" class="fnanchor">[92]</a></p>
+
+<p>While such attempts evidence a perhaps dishonest
+effort to evade the law of debtor and creditor, these
+“smock-marriages” nevertheless evince a most laudable
+inclination on the part of such bold brides to save
+the purse of their intended husbands, so while modern
+husbands would not appreciate the entire return to this
+now obsolete custom, they would not object to the effort
+of brides, while decently clad, in emulation of the
+spirit evinced by these ancient dames of the “shift marriage”
+period, of using their best efforts to spare the
+pocket-books of the men of their choice.</p>
+
+<p>Alice Morse Earle, in her interesting volume, “Customs
+in old New England,” refers to a “smock-marriage”
+at Westerly, Rhode Island.<a id="FNanchor_95" href="#Footnote_95" class="fnanchor">[93]</a></p>
+
+<p>The traveler Kalm also describes such a marriage in
+Pennsylvania, in 1748, where the bridegroom, with the
+proper spirit of chivalry, in order to save the appearance
+of his bride and also his credit, met the bride in
+her scant drapery, half way between her house and his
+own, well provided with warm garments which he
+dressed her in, after formally announcing, in the presence
+of the assembled guests, that the wedding clothes
+which he placed upon her belonged to him and were only
+loaned to the bride, especially for the occasion.</p>
+
+<p><span class="pagenum"><a id="Page_40"></a>[40]</span></p>
+
+<p>John Gatchell married Sarah Cloutman, while she
+was clad only in her “shift,” or “smock,” in Lincoln
+County, Maine, in 1767,<a id="FNanchor_96" href="#Footnote_96" class="fnanchor">[94]</a> and in accordance with the
+popular opinion that the creditors of the bride’s first
+husband could not follow her farther than the king’s
+highway, if she was married only in her “shift,” many
+“smock-marriages” occurred at York, Maine, as recorded
+in the early history of Wells and Kennebunkport.
+The wedding of the Widow Mary Bradley occurred
+while she was clad only in her “shift,” or under-garment,
+during the cold weather in the month of
+February, 1774; she went to meet the bridegroom, thus
+thinly clad and the minister found her with chattering
+teeth and shivering from the cold. Her groom had not
+been as thoughtful as the Pennsylvania bridegroom, in
+loaning her clothing for the occasion, so the gallant
+gentleman of the cloth kindly threw his cloak around
+the freezing bride, to protect her from the wintry
+blasts.<a id="FNanchor_97" href="#Footnote_97" class="fnanchor">[95]</a></p>
+
+<p>In Hall’s “History of Eastern Vermont,” there is
+a graphic account of the marriage of the Widow Lovejoy
+to Asa Averill. The widow was not even clad in
+her “shift,” or under-garment, but appeared at the
+ceremony, in a nude condition, hidden behind a curtain,
+in a recess of the chimney.</p>
+
+<p>Mr. William C. Prime, in his interesting book,
+“Along New England Roads,” gives an account of two
+such marriages that came under his observation. He describes
+how the widow Hannah Ward, of Newfane, Vermont,
+was married to Major Moses Joy, in 1789, while<span class="pagenum"><a id="Page_41"></a>[41]</span>
+the bride, perfectly nude, stood in a closet. She held
+her hand out of a diamond shaped hole in the closet
+door to Joy, and the ceremony was thus performed, in
+the absence even of “smock or shift.”<a id="FNanchor_98" href="#Footnote_98" class="fnanchor">[96]</a> Immediately
+after the ceremony, however, she appeared resplendent
+in her wedding garments, which the gallant Major had
+provided for her, in the closet.</p>
+
+<p>In the other marriage, according to this old custom,
+as described by Mr. Prime, the nude bride left her room
+by a window, at night and standing on the top rung of a
+high ladder, she donned her wedding garments and thus
+abandoned the old obligations of her widowhood.<a id="FNanchor_99" href="#Footnote_99" class="fnanchor">[97]</a></p>
+
+<p>One of the most curious variations of this custom,
+however, is the account given, by Gustavus Vassa, of a
+“smock-marriage” which occurred on the gallows, in
+New York, in 1784. A felon who had been sentenced to
+death was about to be hanged, when he was liberated to
+wed a woman clad only in her “shift.”<a id="FNanchor_100" href="#Footnote_100" class="fnanchor">[98]</a></p>
+
+<p>This strange belief in gallows matches, that a condemned
+felon could be thus rescued, by marriage to
+any woman who would take him from the gallows, is
+placed by Barrington in the list of legal vulgar errors.
+But, as suggested by a writer in Chambers Journal,
+under the subject “Matrimonial Curiosities,” it seems
+doubtful if such a queer idea could have taken possession
+of the popular mind, unless there was some foundation
+for it, in the law.<a id="FNanchor_101" href="#Footnote_101" class="fnanchor">[99]</a> It is perhaps but one of many<span class="pagenum"><a id="Page_42"></a>[42]</span>
+such customs, arising from some isolated case, wherein
+the Court recognized it, which gave it currency and
+caused it to be followed in other instances.</p>
+
+<p>We are told that in 1725 a woman petitioned King
+George I., for the pardon of a convicted felon, in order
+that she might wed him, under Tyburn Tree.<a id="FNanchor_102" href="#Footnote_102" class="fnanchor">[100]</a></p>
+
+<p>Manningham states that this was the custom, not the
+law, in olden times, in France, and Italy, and that if any
+notorious strumpet would beg a convicted felon, about
+to be hanged for her husband, her plea would be
+granted, in order that their joint lives might be bettered
+by so holy an action.<a id="FNanchor_103" href="#Footnote_103" class="fnanchor">[101]</a></p>
+
+<p>Sterill reports a case that he had seen wherein a
+woman, clad only in her smock, or under-garment,
+begged a condemned person for her husband, with a
+white wand in her hand.<a id="FNanchor_104" href="#Footnote_104" class="fnanchor">[102]</a></p>
+
+<p>Whatever recognition the law gave this custom, that
+it actually existed in England, and France is evidenced
+by the many references to the practice, in story and
+rhyme, published during the seventeenth and eighteenth
+centuries.</p>
+
+<p>Montaigne tells a story of a Picardian, who, seeing a
+lame dame advancing toward him, cried out: “She
+limps, she limps, despatch me quickly.”<a id="FNanchor_105" href="#Footnote_105" class="fnanchor">[103]</a> The ballads
+of Roxburghe also tell, in rhyme, how a merchant of<span class="pagenum"><a id="Page_43"></a>[43]</span>
+Chichester, who had killed a German, after his sentence
+and last speech upon the gallows, was wooed by no less
+than ten goodly maidens, who thus addressed him:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“This is our law,” quoth they;</div>
+ <div class="verse indent0">“We may your death remove,</div>
+ <div class="verse indent0">If you, in lieu of our good-will,</div>
+ <div class="verse indent0">Will grant to us your love.”<a id="FNanchor_106" href="#Footnote_106" class="fnanchor">[104]</a></div>
+ </div>
+</div>
+</div>
+
+<p>But having left the fixed doctrines of the law governing
+the relation between the opposite sexes, known as
+marriage, to enter into a study and analysis of the vulgar
+errors in connection with this subject-matter, it is
+high time to bring the chapter to a close.</p>
+
+<p>Of course it was only attempted in this chapter to
+take a most cursory view of the great subject selected
+and to present but a few of the many laws and customs
+that have sprung up among the various peoples of the
+earth, governing the relation whereby the opposite
+sexes, in accordance with the law of natural selection,
+appropriate themselves to one another.</p>
+
+<p>In the ultimate days, when human multiplication has
+done its work—when man has become so populous that
+every square foot of ground upon the known earth shall
+be covered by a man—the law of evolution will no doubt
+have eradicated many of the present marriage laws and
+customs, based upon a false public opinion, and the
+generation of the species will no doubt be conducted
+along more advanced and scientific lines.</p>
+
+<p>For the next few centuries, however, judging the
+future by the past, the marriage relation will continue
+in the same crude and unscientific condition that has
+controled it for the past five thousand years, so we need<span class="pagenum"><a id="Page_44"></a>[44]</span>
+not now concern ourselves about any “devastating torrent”
+of children, but leave this vexed problem for
+succeeding centuries.</p>
+
+<p>In the meantime, like visionary things, mere motes,
+the atoms known as human beings, will continue to be
+brought into the world, as a result of the unnatural
+laws and customs governing this natural relation,</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Still wondering how the marvel came, because two coupling mammals chose,</div>
+ <div class="verse indent0">To slake the thirst of fleshy love.”</div>
+ </div>
+</div>
+</div>
+
+<p>Tossed into the “giant grasp of Life, like gale-borne
+dust, or wind-wrung spray,” the son of man will continue
+to be “the toy, the sport, the waif and stray of
+passions, error, wrath and fear.”</p>
+
+<p>Empires have perished and nations have risen during
+the period covered by the foregoing pages. Countless
+millions of human beings have lived their little
+lives, with their tincture of lust; tasted, for a brief
+space, the “joy in an armful of beautiful dust,” as a
+result of the relation established by the laws and customs
+treated of in these pages, and then “step by step,
+perforce, returned” to “couthless youth, wan, white
+and cold, Lisping again the broken words, till all the
+tale be fully told.” And thus, for successive ages to
+come, will the “moving row of magic shadow shapes,”
+continue to come and go “Round with the sun-illumined-lantern
+held, in Midnight, by the Master of the
+Show.”</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_3" href="#FNanchor_3" class="label">[1]</a> Institutiones Justinianus, written 527-529, A. D.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_4" href="#FNanchor_4" class="label">[2]</a> Ringrose “Marriage Laws of the World,” p. 10.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_5" href="#FNanchor_5" class="label">[3]</a> Tylor, “Early History of Mankind;” McLennan’s “Primitive
+Marriage.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_6" href="#FNanchor_6" class="label">[4]</a> McLennan’s “Primitive Marriage;” Ringrose, “Marriage Laws
+of the World,” p. 7.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_7" href="#FNanchor_7" class="label">[5]</a> Tacitus, Germania, c. 18; II. Pollock and Maitland’s History
+English Law, 364; Johns’ “Babylonian and Assyrian Laws,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_8" href="#FNanchor_8" class="label">[6]</a> We are told that this rude custom obtains today in “Far Cathay,”
+Blackwood’s Magazine, July-Dec., 1887, vol. 42, p. 671.</p>
+
+<p>E. J. Woods in his book, “The Wedding Day in All Ages and
+Countries,” claims that the old Hebrew expression of “taking a
+wife,” arose from the custom of capture, not common to the Israelites,
+but common to other primitive peoples. (Vol. I., p. 9.) He
+quotes Plutarch, as authority for the custom of the Spartans to
+carry off their brides by capture. (Vol. I., pp. 40, 41.) Refers to
+the Rape of the Sabines (vol. I., p. 52), the “Institutes” of Menu,
+as providing one of the forms of marriage by capture, known to
+the four classes of India (vol. I., p. 124). He claims that “the
+capture of women prevailed among the aborigines of the Dekkan
+and in Afghanistan.” (Vol. I., p. 137) He maintains that “In New
+Zealand and the Fejee and other islands of the Pacific, the custom
+of capture of women for wives has prevailed from the earliest times
+of the known history of those places.” (Vol. I., p. 191.) “The form
+of capture is observed in the marriages of the Kalmucks, the Nogay
+Tartars, the Mongols, of the Ortous, in Tartary, the Circassians
+and the people generally of the Caucasus.” (Vol. I., p. 210.) He
+claims that marriage by capture obtained in Poland, in the sixteenth
+and seventeenth centuries (vol. I., p. 220), that the seizure
+of wives by force obtained in Ireland (vol. II., p. 50), so if this
+record is true, since this custom is found to obtain in these countries
+so late as recent historical dates, it is not unbelievable that capture
+was the order of the early barbarous days in our own and other
+countries.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_9" href="#FNanchor_9" class="label">[7]</a> Fison and Howitt, <i>op. cit.</i> 259; Curr, <i>op. cit.</i> I., 108; Prof. Tylor;
+McLennan.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_10" href="#FNanchor_10" class="label">[8]</a> Crawley’s “Mystic Rose,” pp. 6, 147.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_11" href="#FNanchor_11" class="label">[9]</a> Genesis, I., 28.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_12" href="#FNanchor_12" class="label">[10]</a> Genesis, II., 22.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_13" href="#FNanchor_13" class="label">[11]</a> XXXIV. Genesis, 8, 9.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_14" href="#FNanchor_14" class="label">[12]</a> Ringrose, “Marriage and Divorce Laws,” p. 10.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_15" href="#FNanchor_15" class="label">[13]</a> First Book of Kings.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_16" href="#FNanchor_16" class="label">[14]</a> Bryce, “Marriage and Divorce,” III. Essays in Anglo-American
+Legal History, 784, 785; Euripides, Androm., vv. 173, 180; Tacitus,
+Germania, c. xvi. I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_17" href="#FNanchor_17" class="label">[15]</a> Ringrose “Marriage and Divorce Laws,” p. 11.</p>
+
+<p>Monogamy was practiced by the Greeks and Romans as far back
+as our records reach. Wood’s “Wedding Day in All Ages and
+Countries,” vol. I., p. 33.</p>
+
+<p>Morganatic, or “left-handed” marriages, are peculiar to Germany.
+They occur between men of superior and women of inferior rank
+and are prohibited by the Royal Marriage Law of England.</p>
+
+<p>Ringrose, “Marriage and Divorce Laws of the World;” Wood’s
+“Wedding Day in All Ages,” vol. II., p. 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_18" href="#FNanchor_18" class="label">[16]</a> Bryce, “Marriage and Divorce,” III. Essays in Anglo-American
+Legal History, 797; Modestinus in Dig. xxiii, 1, 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_19" href="#FNanchor_19" class="label">[17]</a> Ringrose, “Marriage and Divorce Laws,” p. 8. The Twelve
+Tables fixed the period of three nights, to fix a previous custom,
+no doubt more uncertain. Bryce, “Marriage and Divorce,” III.
+Essays in Anglo-American Legal History, 788.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_20" href="#FNanchor_20" class="label">[18]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_21" href="#FNanchor_21" class="label">[19]</a> III. Essays in Anglo-American Legal History, p. 788.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_22" href="#FNanchor_22" class="label">[20]</a> Tacitus, Ann. xii, 6.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_23" href="#FNanchor_23" class="label">[21]</a> III. Essays in Anglo-American Legal History, 805.</p>
+
+<p>Before the end of the Republic, the <i>confarreatio</i> had practically
+become obsolete and was regarded as an old world curiosity, although
+formerly obtaining generally, in all patrician families. (III.
+Essays in Anglo-American Legal History, p. 789.) The religious
+ceremony, used at the marriage <i>confarreatio</i>, is described in Wood’s
+“Wedding Day in All Ages and Countries,” where it is shown that
+the custom of the “bride-cake” is directly traceable to the cake of
+wheat or barley, used at this old religious ceremony. (“Wedding
+Day in All Ages and Countries,” vol. 1, pp. 51, 52, 60, 61, vol. II., p.
+224.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_24" href="#FNanchor_24" class="label">[22]</a> Tacitus, Ann. xii, 5, 7.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_25" href="#FNanchor_25" class="label">[23]</a> III. Essays in Anglo-American Legal History, 807.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_26" href="#FNanchor_26" class="label">[24]</a> Code Justinian, v. 27, 5, 6; <i>Nov.</i> xii, 4; <i>Nov.</i> lxxxix, 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_27" href="#FNanchor_27" class="label">[25]</a> <i>Novella</i>, lxxxix.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_28" href="#FNanchor_28" class="label">[26]</a> <i>Novella</i>, xii, 4; lxxxix, 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_29" href="#FNanchor_29" class="label">[27]</a> II. Pollock and Maitland’s History English Law, p. 397; III.
+Essays in Anglo-American Legal History, p. 808x.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_30" href="#FNanchor_30" class="label">[28]</a> Selden, Diss. ad. Fletam, p. 538.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_31" href="#FNanchor_31" class="label">[29]</a> Beaumanoir, c. 18, Sec. 24; II. Pollock and Maitland’s History
+English Law, p. 398.</p>
+
+<p>The law did not give the marriage any retroactive effect, by
+reason of this custom of throwing a mantle over the children born
+prior to wedlock, but the custom was recognized by the law, to the
+effect of legitimating the children, in the sense that the act of
+adopting the custom was equivalent to a legal adoption of the
+children, and in spreading the cloak over the children, the law was
+willing to also spread its protecting “mantle” over them and thus
+they became “mantle children,” by force of both the law and this
+old custom of adoption. Although followed in Germany, France
+and Normandy, this custom was refused judicial recognition in the
+reign of Henry II. and Henry III. See Pollock and Maitland’s History
+English Law, p. 398. But for illustrations of the application of the
+custom in the countries above named, see Schroder’s “Mantel-Kinder”
+of Germany, D. R. G. 712.</p>
+
+<p>Discussing the subject of “mantle-children,” in his work “Wedding
+Day in All Ages,” Wood says: “According to the Scotch law,
+the marriage of the father and mother legitimatizes all children
+previously born, however old they may be. An old saying is that
+‘all children under the mother’s girdle or apron-string’ at the time
+of the marriage, are legitimate. In very early days children born
+before wedlock used to perform a part in the marriage ceremony,
+by being placed under the veil or mantle of the bride or the pallium
+of the altar, in which position, they received the nuptial benediction.
+And instances have occurred in more modern times, where premature
+offspring have been put under their mother’s apron, and had the
+string tied over them during her marriage.” (Vol. II., pp. 74, 75.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_32" href="#FNanchor_32" class="label">[30]</a> Ringrose, “Marriage and Divorce Laws,” p. 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_33" href="#FNanchor_33" class="label">[31]</a> Cnut, 74; II. Pollock and Maitland’s History English Law, 365.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_34" href="#FNanchor_34" class="label">[32]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_35" href="#FNanchor_35" class="label">[33]</a> Ringrose, “Marriage and Divorce Laws,” p. 9. We find from the
+second chapter of the Gospel of St. John that Jesus, himself, attended
+a marriage in Cana of Galilee, but performed no religious
+ceremony.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_36" href="#FNanchor_36" class="label">[34]</a> II. Pollock and Maitland’s History English Law, 366.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_37" href="#FNanchor_37" class="label">[35]</a> <i>Ante idem.</i> vol. I., p. 158; Letters of John of Salisbury, i, 124.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_38" href="#FNanchor_38" class="label">[36]</a> <i>Ante idem.</i></p>
+
+<p>Under the Twelve Tables, enacted B. C. 449, a marriage, in Rome,
+could be contracted without any formality, by the consent of the
+parties alone. Bryce, “Marriage and Divorce,” III. Essays in Anglo-American
+Legal History, p. 786.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_39" href="#FNanchor_39" class="label">[37]</a> Glanville, vii, 13, 14; Select Civil Pleas, pl. 15, 92, 109.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_40" href="#FNanchor_40" class="label">[38]</a> II. Pollock and Maitland’s History English Law, p. 371.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_41" href="#FNanchor_41" class="label">[39]</a> Compiliato Prima, lib. 4, tit. c. 6.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_42" href="#FNanchor_42" class="label">[40]</a> II. Pollock and Maitland’s History English Law, 372.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_43" href="#FNanchor_43" class="label">[41]</a> Calendarium Genealogicum, i, 57.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_44" href="#FNanchor_44" class="label">[42]</a> Atlantic Monthly, for 1888, vol. 61, pp. 521, 527.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_45" href="#FNanchor_45" class="label">[43]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_46" href="#FNanchor_46" class="label">[44]</a> Atlantic Monthly, for 1888, vol. 61, p. 521.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_47" href="#FNanchor_47" class="label">[45]</a> 26 George II., c. 33.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_48" href="#FNanchor_48" class="label">[46]</a> Bryce, “Marriage and Divorce,” III. Essays in Anglo-American
+Legal History, p. 815.</p>
+
+<p>The statute of the 26’ year of George II., enacted that wedding
+banns should be regularly published three successive Sundays in the
+church of the parish where the parties were for the time residing.
+This statute was passed to prevent the evils of the “Fleet marriages,”
+during the year 1616, when the Rector of St. James was suspended
+and clerical men living within the Rules of the Fleet, solicited
+passers-by for patronage and celebrated marriage ceremonies in
+ale-houses and garrets, without the publication of banns, or the existence
+of marriage licenses. Wood’s “Wedding Day in All Ages,” vol.
+II., page 235.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_49" href="#FNanchor_49" class="label">[47]</a> 10 Clark and Finley, 534.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_50" href="#FNanchor_50" class="label">[48]</a> Pollock and Maitland, in their History of English Law, say that
+this erroneous decision may have pleased the Lords, but the opposite
+holding will be followed by historians of the middles ages.
+(Vol. II., p. 372.) And James Bryce, in his “Marriage and Divorce,”
+III. Essays in Anglo-American Legal History, says that this “seems
+to have been an erroneous” decision. (Vol. III., p. 815.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_51" href="#FNanchor_51" class="label">[49]</a> Bracton, f. 92, 304, 305; Note Book, pl. 891, 1669.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_52" href="#FNanchor_52" class="label">[50]</a> Bracton, f. 63; Bliss, Calendar of Papal Registers, i, 254; Year
+Book, 11-12 Edward III., p. 481.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_53" href="#FNanchor_53" class="label">[51]</a> Statute West, II., c. 34; Second Inst. 433.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_54" href="#FNanchor_54" class="label">[52]</a> II. Pollock and Maitland’s History English Law, p. 395.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_55" href="#FNanchor_55" class="label">[53]</a> Rot. Parl. i, 140, A. D. 1302.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_56" href="#FNanchor_56" class="label">[54]</a> Ringrose, “Marriage and Divorce Laws,” p. 9.</p>
+
+<p>If the investigation of Edward J. Wood, in his book, “Wedding
+Day in All Ages and Countries,” is accurate, the Eimauk, of Caubul,
+“lend their wives to their guests”; “the Candyans, of the lower and
+middle classes universally practice polygamy and also lend their
+wives to their guests”; “the Keiaz, of the Paropamisan mountains
+of India, lend their wives, as do also the people of Kamul”; the
+“Mpongmes, an African tribe, lend their wives,” and “the Koryaks,
+who are polyandrous, and the Chukchi, in the north-east of Siberia,
+lend out their wives, as do also the Aimaks.”</p>
+
+<p>II. “The Wedding Day in All Ages and Countries,” pp. 97, 146, 151,
+167, 237.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_57" href="#FNanchor_57" class="label">[55]</a> Wood’s “Wedding Day in All Ages and Countries,” vol. II., p. 116.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_58" href="#FNanchor_58" class="label">[56]</a> <i>Ante idem.</i>, p. 116.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_59" href="#FNanchor_59" class="label">[57]</a> Wood’s “Wedding Day in All Ages and Countries,” vol. I., p. 179.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_60" href="#FNanchor_60" class="label">[58]</a> Wood’s “Wedding Day in All Ages and Countries,” vol. I., p. 221.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_61" href="#FNanchor_61" class="label">[59]</a> II. Pollock and Maitland’s History English Law, p. 364; Tacitus
+Germania c. 18. The old Babylonians and Assyrians held a regular
+market day at a public place, for the sale of their daughters.
+(Wood’s “Wedding Day in All Ages and Countries,” vol. I., p. 70.)</p>
+
+<p>The custom of purchasing wives was known to the ancient Greeks
+and was strongly opposed by Aristotle. The payment of money was
+frequently the only form of marriage, in ancient Greece. (Wood’s
+“Wedding Day in All Ages and Countries,” vol. I., pp. 33, 47, 51.)</p>
+
+<p>In Syria every man paid a sum for his wife, proportionate to
+the rank of her father. (<i>Ante. idem.</i>, p. 72.)</p>
+
+<p>The Arabians bought their wives as they did their slaves. (<i>Ante
+idem.</i>, p. 82.)</p>
+
+<p>Burckhardt says that among the Bedouins, of Mount Sinai, marriage
+is a mere matter of purchase and sale. (<i>Ante idem.</i>, p. 85.)</p>
+
+<p>And the same custom obtained among the Mohammedans, Javanese,
+Ethiopians, Circassians, Ostiacs, a Tarter tribe, Laplanders, the
+ancient Germans, Romans and French, as well as our early Saxon
+ancestors. (Wood’s “Wedding Day in All Ages and Countries,” vol.
+I., pp. 90, 155, 174, 210, 214, and vol. II., pp. 3, 173, 247.)</p>
+
+<p>The custom of purchasing wives is perhaps derived from the old
+Salic law. It was known to the ancient Jews, as well as the other
+nations above mentioned and the custom of marriage portions and
+doweries is no doubt the outgrowth of this old practice. (Wood’s
+“Wedding Day in All Ages and Countries,” vol. II., p. 173.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_62" href="#FNanchor_62" class="label">[60]</a> Bouvier; Cowel; I. Reeves History English Law, pp. 369, 371.
+In legal contemplation, a female was in the custody of the Lord
+paramount, until she reached her majority, and then he was bound
+to find her a proper marriage. His custody continued until her
+marriage, even after she became of age and she could only marry
+with his consent. She was bound to obtain the consent of the Lord,
+or lose her dower, but it was sufficient, if she had the consent of
+the chief lord, to marry. The custom was based upon the fealty
+which the husband owed the lord and since the woman lost her
+inheritance, if she gave cause of forfeiture, the lord had it in his
+power to exact anything of her, and hence the custom referred to
+in the text, an exaction allowed by way of a punishment for the
+offense of belonging to the frail sex, in an early day. Reeve’s History
+English Law, vol. I., pp. 370, 371.</p>
+
+<p>Shakespeare makes Cade refer to this old barbarous custom, in
+2’ Henry VI., when he says: “... There shall not a maid be
+married, but she shall pay to me her maidenhead, ere they have it.”
+(Act IV., Scene VII.; White’s “Law in Shakespeare,” Sec. 299, p.
+326).</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_63" href="#FNanchor_63" class="label">[61]</a> Wood’s “Wedding Day in All Ages and Countries,” vol. II., p. 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_64" href="#FNanchor_64" class="label">[62]</a> Genesis, XXXIV., 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_65" href="#FNanchor_65" class="label">[63]</a> Smith’s Dict. Greek and Roman Antiquities.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_66" href="#FNanchor_66" class="label">[64]</a> In the first known code of laws ever written, so far as our
+history goes, in the old code of Hammurabi, King of Babylon, who
+reigned from 2285 to 2242, B. C., we find that doweries and marriage
+portions were spoken of, just as in modern statutes, and it was provided
+that if a childless woman should be returned to her father,
+he should return the dowry, and if he did not the husband could
+deduct all the dowry from the marriage portion and then return
+the marriage portion, the house of her father.</p>
+
+<p>Code Hammurabi, Secs. 163, 164; Johns’ “Oldest Code of Laws,”
+pp. 32, 33; Johns’ “Babylonian and Assyrian Laws,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_67" href="#FNanchor_67" class="label">[65]</a> Wood’s “Wedding Day in All Ages and Countries,” vol. II., p. 17.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_68" href="#FNanchor_68" class="label">[66]</a> <i>Ante idem.</i>, p. 18.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_69" href="#FNanchor_69" class="label">[67]</a> Genesis, XXXIV., 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_70" href="#FNanchor_70" class="label">[68]</a> Ringrose “Marriage and Divorce Laws of the World.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_71" href="#FNanchor_71" class="label">[69]</a> Selden.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_72" href="#FNanchor_72" class="label">[70]</a> Coke, Littleton, 31.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_73" href="#FNanchor_73" class="label">[71]</a> Wood’s “Wedding Day in All Ages,” vol. II., p. 16.</p>
+
+<p>Shakespeare makes frequent reference to the marriage custom of
+giving a dowry to the bride, in his various plays. Thus, in “Love’s
+Labour’s Lost,” (Act II., Scene I), Boyet, in speaking to the Princess,
+refers to Aquitaine as “a dowry for a queen;” King John tells Phillip
+of France, that if his son shall love his daughter, “Her dowry shall
+weigh equal with a queen.” (King John, Act II., Scene I.) Petruchio
+tells Katherine, in “Taming of the Shrew”: “<i>Pet.</i> Your father
+hath consented that you shall be my wife; your dowry ’greed on;
+and will you, nil you, I will marry you.” (Act II., Scene I.) Gloster, in
+1’ Henry VI., speaking of the proffer of his daughter to the King,
+by the Earl of Armagnac, refers to the “large and sumptuous dowry.”
+(Act V., Scene I.) And the poor Lear, is made to ask the duke
+of Burgundy, in discarding his daughter, Cordelia: “What, in the
+least, will you require in present dower with her?” (Act I., Scene
+I.)</p>
+
+<p>White’s “Law in Shakespeare,” Sec. 66, pp. 95, 97.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_74" href="#FNanchor_74" class="label">[72]</a> Wood’s “Wedding Day in All Ages,” vol. I., p. 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_75" href="#FNanchor_75" class="label">[73]</a> Genesis, XXIV., 22, 53.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_76" href="#FNanchor_76" class="label">[74]</a> Wood’s “Wedding Day in All Ages,” vol. II., p. 131.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_77" href="#FNanchor_77" class="label">[75]</a> <i>Ante idem.</i> 130.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_78" href="#FNanchor_78" class="label">[76]</a> <i>Ante idem.</i> 133.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_79" href="#FNanchor_79" class="label">[77]</a> During the reign of George I. and George II., the wedding ring
+was placed on the usual finger at marriage and then transferred to
+the thumb. Wood’s “Wedding Day in All Ages,” vol. II., p. 134.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_80" href="#FNanchor_80" class="label">[78]</a> <i>Ante idem.</i> p. 135.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_81" href="#FNanchor_81" class="label">[79]</a> Wood’s “Wedding Day in All Ages,” vol. I., p. 94.</p>
+
+<p>The Quakers and Mormons reject the wedding ring, because of
+its heathenish origin. Wood’s “Wedding Day in All Ages,” vol. II.,
+p. 135.</p>
+
+<p>The wedding rings of St. Louis, of France; of Margaret, daughter
+of the Earl of Warwick; of the wife of Duke John, of Sweden; of
+Martin Luther and Catherine Von Bora, his wife; the ring given by
+Henry VIII. to Anne of Cleves; that given by Phillip, to Queen
+Mary, and by Lord Darnley, to Mary, Queen of Scots, are described
+in Wood’s “Wedding Day in All Ages,” vol. II., pp. 145, 149.</p>
+
+<p>Chaucer’s reference to the wedding ring, in his “Troilus and
+Cressida”; Shakespeare’s mention of the gemmal ring, in “Midsummer’s
+Night’s Dream”; and his use of the ring in “Two Gentlemen
+of Verona,” “Twelfth Night” and “Merchant of Venice,” with
+many traditions of the wedding ring, will be found interestingly presented
+in Wood’s “Wedding Day in All Ages,” vol. II., pp. 129, 149.</p>
+
+<p>The custom of placing the ring upon the fourth finger of the left
+hand, according to the opinion of a writer in the British Apollo, in
+1708, dates from the discovery of the convenience of the left hand
+for such ornament because less employed than the right and the
+fourth finger, less than others, was needed in ordinary use. See
+Knowlton’s “Origin of Wedding Superstitions;” Finck’s “Primitive
+Love and Love Stories.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_82" href="#FNanchor_82" class="label">[80]</a> Wood’s “Wedding Day in All Ages,” vol. I., pp. 94, 95.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_83" href="#FNanchor_83" class="label">[81]</a> <i>Ante idem.</i>, vol. I., pp. 128, 133, 156; vol. II., pp. 44, 224.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_84" href="#FNanchor_84" class="label">[82]</a> Deuteronomy, XXV., 5, 10.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_85" href="#FNanchor_85" class="label">[83]</a> Ruth, IV., 7, 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_86" href="#FNanchor_86" class="label">[84]</a> Boston Trans. Aug. 13, 1910; Wood’s “Wedding Day in All Ages,”
+vol. I., p. 16; Hutchinson’s “Marriage Customs in Many Lands.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_87" href="#FNanchor_87" class="label">[85]</a> <i>Ante idem.</i></p>
+
+<p>Wood quotes Michelet, in his “Life of Luther,” to show that the
+great Reformer used the shoe at a marriage ceremony. Wood’s
+“Wedding Day in All Ages,” vol. I., p. 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_88" href="#FNanchor_88" class="label">[86]</a> Wood’s “Wedding Day in All Ages,” vol. II., p. 218.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_89" href="#FNanchor_89" class="label">[87]</a> <i>Ante idem.</i>, p. 216.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_90" href="#FNanchor_90" class="label">[88]</a> <i>Ante. idem.</i>, pp. 215, 221.</p>
+
+<p>Referring to the custom of stocking-throwing, Rowe, in his “Happy
+Village,” in 1796 says:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“The wedding-cake now through the ring was led,</div>
+ <div class="verse indent0">The stocking thrown across the nuptial bed.”</div>
+ </div>
+</div>
+</div>
+
+<p>And in the “Collier’s Wedding,” we read:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“The stocking’s thrown, the company gone,</div>
+ <div class="verse indent0">And Tom and Jenny both alone.”</div>
+ </div>
+</div>
+</div>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_91" href="#FNanchor_91" class="label">[89]</a> See Article on “Ancient Marriage Customs,” in Uncle Remus’
+Home Magazine, June, 1912.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_92" href="#FNanchor_92" class="label">[90]</a> “Matrimonial Curiosities,” Chambers Journal, vol. 48, pt. 2,
+p. 813.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_93" href="#FNanchor_93" class="label">[91]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_94" href="#FNanchor_94" class="label">[92]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_95" href="#FNanchor_95" class="label">[93]</a> “Courtship and Marriage Customs,” p. 79.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_96" href="#FNanchor_96" class="label">[94]</a> Earle’s “Customs in Old New England,” p. 79.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_97" href="#FNanchor_97" class="label">[95]</a> History, Wells and Kennebunkport.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_98" href="#FNanchor_98" class="label">[96]</a> “Along New England Roads,” p. 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_99" href="#FNanchor_99" class="label">[97]</a> “Customs in Old New England,” p. 78.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_100" href="#FNanchor_100" class="label">[98]</a> Earle’s “Customs in Old New England,” p. 79.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_101" href="#FNanchor_101" class="label">[99]</a> Chambers Journal, vol. 48, pt. 2, July-Dec., 1871, p. 812.</p>
+
+<p>Discussing the subject of “gallows-matches,” Wood, in his “Wedding
+Day in All Ages,” says: “Formerly was current a vulgar notion
+that if a woman married a condemned man under the gallows, she
+would thereby save him from execution. Certainly this exemption
+had a quasi-legal existence in France in the fifteenth century, as
+there are instances of it in the annals of that country.” (Vol. 2,
+p. 25.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_102" href="#FNanchor_102" class="label">[100]</a> Chambers Journal, vol. 48, pt. 2, 812.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_103" href="#FNanchor_103" class="label">[101]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_104" href="#FNanchor_104" class="label">[102]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_105" href="#FNanchor_105" class="label">[103]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_106" href="#FNanchor_106" class="label">[104]</a> Roxburghe Ballads.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_45"></a>[45]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_II">CHAPTER II.<br>
+<span class="smcap">Witchcraft and Sorcery.</span></h2>
+
+</div>
+
+<p><i>Witch</i>, is taken from the Hebrew word, rendered
+<i>venefica</i>, meaning a poisoner and divineress; one who
+dabbles in spells and fortune-telling.<a id="FNanchor_107" href="#Footnote_107" class="fnanchor">[1]</a> In course of
+time, the term was used to indicate those who held communion
+with evil spirits and derived a super-human
+power from them, whereby they could not only foretell
+the coming of future events, but bring about evil results
+upon the life, bodies, or possessions of individuals.
+This unnatural power was supposed to be acquired by
+a compact with the devil himself, by which the wizard
+or witch bargained his or her soul to the devil as a consideration
+for the power of enchantment.<a id="FNanchor_108" href="#Footnote_108" class="fnanchor">[2]</a></p>
+
+<p>From the earliest times, men and women have tried to
+hold communion with superior beings and to pierce the
+secrets of the future.</p>
+
+<p>In the oldest code of laws in the known world, promulgated
+by Hammurabi, King of Babylon, 2285 years
+before Christ, the first two sections of the code are
+levelled at the crime of witchcraft, and we find that it is
+there written, that:</p>
+
+<div class="blockquote">
+
+<p>“If a man weave a spell and put a ban upon a man,
+and has not justified himself, he that wove the spell
+upon him shall be put to death.”<a id="FNanchor_109" href="#Footnote_109" class="fnanchor">[3]</a></p>
+
+</div>
+
+<p><span class="pagenum"><a id="Page_46"></a>[46]</span></p>
+
+<p>And the same code provided that the man against
+whom the spell was woven, should plunge into the “holy
+river” and if the river overcame him, his house should
+go to the weaver of the spell, but if the river made the
+man innocent, he should take the house of the sorcerer
+and he was to be put to death.<a id="FNanchor_110" href="#Footnote_110" class="fnanchor">[4]</a></p>
+
+<p>According to the photogravure of the blocks of diorite,
+upon which these most antique laws were written,
+therefore, when King Hammurabi, received his law
+direct from the seated sun-god, Samas,—the judge of
+heaven and earth—the old delusion of witchcraft and
+sorcery obtained. So prevalent was the offense, according
+to the delusion then obtaining, that the very first
+sections of the code were directed at this crime, established
+to the satisfaction of the judges of that period, by
+the test of a plunge into the “holy river,” in the absence
+of more direct proof of the existence of the offense
+which existed only in the imaginations of the superstitious
+inhabitants of that misty age.</p>
+
+<p>During the time of Moses, we find that many imposters
+insulted the intelligence of the Supreme Being,
+by claiming to have received delegated powers from on
+high and hence Moses provided in his law that “Thou
+shalt not suffer a witch to live.” The long persecution
+of persons convicted of witchcraft, by a misinterpretation
+of this text, was thus justified by this Biblical injunction
+and many conscientious men and women, in
+their inability to understand the science of common
+things, attributed appearances which they could not
+explain, to supernatural agencies and blindly believing
+in this Mosaic law, proceeded to violate the highest laws<span class="pagenum"><a id="Page_47"></a>[47]</span>
+of God and man, in the fanaticism that a Divine injunction
+was being obeyed, in the punishment of those convicted
+of witchcraft and sorcery.<a id="FNanchor_111" href="#Footnote_111" class="fnanchor">[5]</a></p>
+
+<p>The Twelve Tables of the early Romans contained
+penal provisions against one who should bewitch the
+fruits of the earth or conjure away his neighbors’ corn,
+into his own field,<a id="FNanchor_112" href="#Footnote_112" class="fnanchor">[6]</a> and a century and a half after the
+adoption of the Twelve Tables, one hundred and seventy
+Roman women were tried and convicted of poisoning,
+under the pretense of charms and incantations, which
+led to new laws against such supposed practices.</p>
+
+<p>As the Mosaic law against witchcraft was formerly
+interpreted, to mean the punishment by death of witches
+who did positive injury to another in his person or
+property, so the Roman laws were directed against
+those supposed to have done positive injury to a person,
+in his property or to have hurt him, physically.</p>
+
+<p>In other words, the mere possession of magic art, in
+the old heathen world, was not, in itself a crime, for
+while it was dreaded, as being liable to be turned to
+malicious or wrongful purposes, it was also recognized
+as a most beneficial art, through which the religion of
+domestic life and the remedy of healing the sick, was
+supposed to come.</p>
+
+<p><span class="pagenum"><a id="Page_48"></a>[48]</span></p>
+
+<p>That this view of witchcraft continued to prevail for
+many centuries after the reception of Christianity, is
+evidenced by the laws of Constantine, in the fourth
+century, which ordained capital punishment for all
+those who practiced noxious charms against the life or
+health of others, by supernatural power, but exempted
+from the punishment of the law, all those who practiced
+magical arts for beneficial purposes, such as warding
+off hailstorms, and excessive rains or windstorms, or
+curing cattle or persons afflicted with disease.<a id="FNanchor_113" href="#Footnote_113" class="fnanchor">[7]</a></p>
+
+<p>The savage laws by the Christian Emperors in the<span class="pagenum"><a id="Page_49"></a>[49]</span>
+early centuries did considerable harm in after ages.
+The Anglo-Saxons patterned their laws against sorcery
+and witchcraft after the folk-laws of the continent and
+Cnut, even, legislated against the witchcraft which was
+heathenish.<a id="FNanchor_114" href="#Footnote_114" class="fnanchor">[8]</a></p>
+
+<p>During the reign of Henry I., criminals who encompassed
+the maiming or sickening of a person by maltreating
+a waxen image of him—a belief that generally
+obtained from this time until the seventeenth century—were
+either hanged or burnt.<a id="FNanchor_115" href="#Footnote_115" class="fnanchor">[9]</a> And during the reign of
+this monarch, in England, Archbishop Gerard, of York,
+was accused of necromancy and sorcery and when it
+was discovered that he had died suddenly, and a book
+on the subject of astrology was found under his pillow,
+his body was refused burial in the Cathedral.<a id="FNanchor_116" href="#Footnote_116" class="fnanchor">[10]</a></p>
+
+<p>After the influence of the Catholic religion had safely
+extended its power over the western world, however,
+and the fear of a return to paganism was looked upon as
+most improbable, the church was not inclined to look
+with such aversion upon the class of criminals accused
+of dabbling in the black arts. Astrology and necromancy
+were looked upon with considerable admiration
+by the most powerful of the church and laity and even
+Bishops and Popes tempted the powers of evil, by little
+harmless excursions into the great realm of the supernatural.</p>
+
+<p>This temporizing by the church continued until about
+the beginning of the thirteenth century, when heresy<span class="pagenum"><a id="Page_50"></a>[50]</span>
+had become so common that the interests of the church
+were threatened and when the church began, in various
+parts of the world, a most stringent prosecution of
+witches and sorcerers and the crowned-heads of Europe,
+in humble submission to the demands of the Pope, used
+the power of the kingdom in an attempt to rid the
+church of this threatened evil.<a id="FNanchor_117" href="#Footnote_117" class="fnanchor">[11]</a></p>
+
+<p>From an early day, in France, people were punished
+for supposed crimes resulting from witchcraft and sorcery.
+Charlemagne frequently ordered all necromancers,
+sorcerers and witches to be driven from the realm
+and with the gradual increase of the crimes attributed
+to them, he published different edicts, preserved at
+length in the “Capitulaire de Baluse.”<a id="FNanchor_118" href="#Footnote_118" class="fnanchor">[12]</a></p>
+
+<p>By these edicts, death was decreed against all those
+who practiced feats of sorcery and witchcraft, and those
+who conspired with the devil to afflict either man or
+woman, with barrenness; who excited tempests, or
+windstorms; destroyed the fruits of the earth, hurt
+cows, or other animals, and afflicted human beings
+with sores or disease, were to be immediately executed,
+upon their conviction.<a id="FNanchor_119" href="#Footnote_119" class="fnanchor">[13]</a></p>
+
+<p>From the time of Charlemagne until the eighteenth
+century, in France, England, Scotland and other European
+countries, the trials for witchcraft and sorcery continuously
+multiplied and it became the common means
+to enable a wolfish monarch to rid himself of a disliked
+rival or subject, upon some trumped-up charge, based
+upon some trivial circumstance connected with an unexplained
+phenomenon.</p>
+
+<p><span class="pagenum"><a id="Page_51"></a>[51]</span></p>
+
+<p>The destruction of the Stedinger, in 1234; the persecutions
+of the Templars, from 1307 to the year 1313;
+the trial and execution of poor Joan of Arc, in 1429, the
+tragedy of Arras, in 1459, and many other horrible casualties,
+during the middle ages illustrate the prevalency
+with which this delusion was used to bring about the
+death and destruction of a large portion of the human
+race, who were guilty only of living in an age of ignorance
+and cruelty.<a id="FNanchor_120" href="#Footnote_120" class="fnanchor">[14]</a></p>
+
+<p>At the instance of Pope Gregory IX., the Emperor of
+Germany, Frederic II., pronounced his banns against
+the valiant Stedinger, in 1233 and a crusade was inaugurated
+against them in all Germany. Eight thousand of
+them were slain upon the field of battle and the whole
+race extinguished and their houses and woods were
+burned, because they would not embrace the Catholic
+religion, but continued to adhere to their own ideals
+and ideas in religion and government. The Pope
+charged that they “insulted the holy sacrament, consulted
+witches to raise evil spirits, shed blood like
+water, took the lives of priests and concocted an infernal
+scheme to propagate the worship of the devil.”<a id="FNanchor_121" href="#Footnote_121" class="fnanchor">[15]</a></p>
+
+<p><span class="pagenum"><a id="Page_52"></a>[52]</span></p>
+
+<p>The Templars had also offended the Church and in
+1307 the charge was brought against them that they
+were in communion with evil spirits and had sold their
+souls to the devil. This charge effected its object and
+they were extirpated, even as the poor Stedinger had
+been, in the previous century.</p>
+
+<p>Philip IV., of France, acting under authority of the
+Pope, ordered the arrest and trial of the Templars and
+the confiscation of their goods and property. Hundreds
+were put to the rack and when tortured by pain, confessed
+the most unreasonable charges which were
+lodged against them and this only heightened the popular
+clamor and the persecution against them, as a body.
+Fifty-nine Templars were burned alive, by a slow
+fire, in a field adjoining the city of Paris, after they
+had been convicted of witchcraft and sorcery, and other
+instances of their persecutions, upon this charge, occurred
+in the different provinces, until the year 1313,
+when the Grand Master of the Order Jacques de Molay
+was burned to death, a fitting climax to this reign of
+terror, inaugurated by the Pope and Monarch, to rid
+themselves of an odious order—a lasting stigma to the
+memory of the Pope and Monarch responsible for such
+conditions and an ever increasing source of pity to the
+millions possessing the divine gift of a tender fellow-feeling
+for their own kind.</p>
+
+<p>In 1429 the poor Joan of Arc fell a victim to the
+charge of witchcraft and sorcery and like dual criminals,
+proceeding hand in hand to accomplish the crime,
+religion and law, not only failed to raise a hand to prevent
+the conflagration that consumed and tortured the
+sainted body of this patriotic victim, but actually consummated<span class="pagenum"><a id="Page_53"></a>[53]</span>
+the crime, in the name of holy order and
+legal procedure, which will remain eternally as one of
+the saddest and most pitiable spectacles of the weakness
+and criminal blunderings of the Church and State.</p>
+
+<p>In 1459 a devoted congregation of the Waldenses, at
+Arras, fell victims to a charge of witchcraft and sorcery.
+Many of them, when placed upon the rack, admitted
+their guilt, to escape the torture; prominent
+rulers and people of wealth were involved and many
+were burned, while others were thrown in prison, or
+paid large fines to escape a worse fate, at the hands of
+the ignorant and intolerant courts, that reflected the
+hatred and persecution of the enraged populace.<a id="FNanchor_122" href="#Footnote_122" class="fnanchor">[16]</a></p>
+
+<p>In 1487 two old women were arrested for witchcraft,
+in Switzerland, for having caused a tempest.
+They were placed upon the rack, where people, enforc’d
+do speak anything, and after severe torture they admitted
+that they were in collusion with the devil and
+were condemned to die, and if the criminal register at
+Constance is to be believed, they were burned at the
+stake, for after the name of each, appears the significant
+epitaph: “<i>convicta et combusta</i>.”<a id="FNanchor_123" href="#Footnote_123" class="fnanchor">[17]</a></p>
+
+<p>Speaking of the great prevalency of this accusation,
+about this period, Florimond, in his work concerning
+the Anti-Christ, observes:</p>
+
+<div class="blockquote">
+
+<p>“The seats destined for criminals in our courts of
+justice are blackened with persons accused of this guilt.
+There are not judges enough to try them. Our dungeons
+are gorged with them. No day passes that we do not
+render our tribunals bloody by the dooms which we
+pronounce, or in which we do not return to our homes,<span class="pagenum"><a id="Page_54"></a>[54]</span>
+discountenanced and terrified at the horrible confessions
+we have heard.”</p>
+
+</div>
+
+<p>But the <i>Witch Mania</i> in Europe, may be said to properly
+date from about the year 1488, when Pope Innocent
+VIII., in a determined effort to rid the Church of Rome
+of the stigma and opposition of those supposed to be
+prompted by the devil, appointed inquisitors in every
+country, armed with the apostolic power to accuse and
+punish this class of criminals.<a id="FNanchor_124" href="#Footnote_124" class="fnanchor">[18]</a></p>
+
+<p>Following the appointment of this commission and
+those of successive Popes, a wholesale slaughter of innocent
+men and women, followed this crusade of bigotry
+and ignorance.</p>
+
+<p>Cumanus burned forty-one women in one province
+alone, in Italy; Sprenger burned more than five hundred
+in a year, in Germany; five hundred were burned in
+Geneva, in 1515 and 1516; in the district of Como, in
+the year 1524 about a thousand people suffered death
+for witchcraft and for several years thereafter the
+general average in this district was a hundred a year
+and one inquisitor alone, Remigius, took whatever credit
+he was entitled to, for having during a period of fifteen
+years convicted and burned nine hundred poor souls
+for this imaginary offense.<a id="FNanchor_125" href="#Footnote_125" class="fnanchor">[19]</a></p>
+
+<p>In 1520 witches were burned in fires that were ever
+kept burning to receive their tortured bodies, in France.
+In 1561 five poor women of Verneuil were convicted of
+turning themselves into cats and prowling around and
+performing satanic feats, as a result of which they were
+all burned alive.<a id="FNanchor_126" href="#Footnote_126" class="fnanchor">[20]</a></p>
+
+<p><span class="pagenum"><a id="Page_55"></a>[55]</span></p>
+
+<p>In 1571 the celebrated sorcerer, Trais Echelles, after
+his confession, was burned at the Place de Greve, in
+Paris.</p>
+
+<p>In 1573 Giles Garnier, of Lyons, was indicted for
+being a loup-garou, or man wolf,<a id="FNanchor_127" href="#Footnote_127" class="fnanchor">[21]</a> and prowling around
+at night and destroying children. Fifty witnesses testified
+against him and after being placed upon the rack,
+he confessed the crime he was charged with and was
+condemned by Dr. Camus to be:</p>
+
+<div class="blockquote">
+
+<p class="noindent">“tied to a stake and burned alive and that his ashes
+be then scattered to the winds.”<a id="FNanchor_128" href="#Footnote_128" class="fnanchor">[22]</a></p>
+
+</div>
+
+<p>The conditions in England, during the sixteenth
+century, were about the same as in France, Germany
+and Italy, so far as the persecutions for witchcraft were
+concerned. While rooting out many errors of ignorance
+and superstition, the Reformation made no head-way
+at all against witchcraft and sorcery, the greatest evil
+of the period and strange to narrate, while their followers
+were persecuted for this crime, Luther and Calvin
+were as firm believers in witchcraft as were the
+Popes whom they opposed and their followers were
+even as zealous persecutors of the innocents accused
+of this crime as were the churchmen of the old religion.<a id="FNanchor_129" href="#Footnote_129" class="fnanchor">[23]</a></p>
+
+<p>A few of the English cases will not be found uninstructive
+as illustrative of the prejudice and persecution<span class="pagenum"><a id="Page_56"></a>[56]</span>
+levelled at those accused of witchcraft in that
+country, during the sixteenth and seventeenth centuries.</p>
+
+<p>The celebrated case of the Witches of Warbois, in
+1594, is especially worthy of mention. The good old
+Mother Samuel lived in the neighborhood of Sir Samuel
+Cromwell and a Mr. Throgmorton and the latter had
+several daughters and among them a Miss Joan, who
+was a melancholy girl, whose head was filled with
+stories of ghosts and witches and she conceived the idea
+that poor old Mother Samuel had bewitched her, as
+she felt sudden pains in her limbs and strange sensations,
+when she went near her. Her parents believed her
+and after a few family casualties the poor old woman
+was arrested upon a charge of witchcraft filed against
+her by the family of Sir Samuel Cromwell, after the
+death of his wife, as she had confessed, upon different
+persecutions that she had afflicted them with pains and
+fits and turned their milk sour in the pans, prevented
+their ewes and cows from bearing and that she had
+caused Lady Cromwell’s death. She also confessed
+that her husband and daughter were leagued with her
+in witchcraft and all three were found guilty and
+hanged on April 7’, 1593.</p>
+
+<p>In Scotland, during the ninth Parliament of Queen
+Mary, witchcraft was made a crime punishable by
+death, and after this statute, the superstition and fear
+of the people brought frequent accusations against different
+people, many of whom were prominent in Government
+and social circles.</p>
+
+<p><span class="pagenum"><a id="Page_57"></a>[57]</span></p>
+
+<p>The case against Dr. Fian and his accomplices will
+illustrate the feeling obtaining in Scotland about this
+period. Gellie Duncan implicated Agnes Sampson and
+when she was put to the torture, she also implicated
+Dr. Fian, Marion Lincup and Euphemia Macalzean,
+the daughter of Lord Cliftonhall. They were charged
+with having attempted the king’s life, through witchcraft
+and sorcery. It was charged that they had raised
+a fearful storm at sea, to attempt to wreck a ship on
+which the king, James VI., and his bride had sailed.
+Several of the accused were subjected to the torture
+and finally confessed to the crime and implicated the
+rest, and on June 25’, 1591, Barbara Napier, Gellie
+Duncan, Agnes Sampson, Dr. Fian and twenty-five
+others were hanged for witchcraft and Euphemia Macalzean
+was “bound to a stake, and burned in ashes,
+<i>quick</i> to the death.”<a id="FNanchor_130" href="#Footnote_130" class="fnanchor">[24]</a></p>
+
+<p>After this conviction in Scotland, the renown of King
+James as an enemy to witchcraft and sorcery, preceded
+him to England and when he ascended the English
+throne in 1603, he was ready for a new crusade against
+this obnoxious class of criminals.</p>
+
+<p>The first statute upon witchcraft, in England, was
+that of 1541, which defined the offense and affixed the
+punishment.</p>
+
+<p>Two statutes were passed in 1551, one relating to
+false prophesies, due no doubt to the machinations of
+Elizabeth Barton, the “Holy Maid of Kent,” and the
+other was levelled at conjurgations, witchcraft and
+sorcery.</p>
+
+<p>The statute of Elizabeth, in 1562, recognized witchcraft<span class="pagenum"><a id="Page_58"></a>[58]</span>
+as a crime of first magnitude, punishable by death,
+regardless of whether it was exerted against the lives,
+limbs, or property of the subjects.<a id="FNanchor_131" href="#Footnote_131" class="fnanchor">[25]</a></p>
+
+<p>On his accession to the throne in 1604 King James
+passed the statute whereby it was enacted that:</p>
+
+<div class="blockquote">
+
+<p>“If any person shall use, practice, or exercise, any
+conjurgation of any wicked or evil spirit, or shall consult,
+covenant with, or feed any such spirit, the first
+offense to be imprisoned for a year and stand in the
+pillory once a quarter; the second offense to be death.”</p>
+
+</div>
+
+<p>The milder punishment was not inflicted, but all convicted
+under this statute were hanged and burned, or
+burned, without previous strangling, “alive and quick.”</p>
+
+<p>This statute continued on the statute books until the
+year 1736, when it was repealed and suffered no longer
+to disgrace the intelligence of the country, after which
+date witches, conjurers and fortune-tellers were only
+subjected to the jail sentences common to other misdemeanors,
+confinement for short intervals, or the pillory.</p>
+
+<p>We are reliably informed that during the Long Parliament,
+in England, three thousand witches were executed<a id="FNanchor_132" href="#Footnote_132" class="fnanchor">[26]</a>
+and during the first eighty years of the seventeenth<span class="pagenum"><a id="Page_59"></a>[59]</span>
+century, it has been estimated that five hundred
+people were annually executed for witchcraft, in England,
+making a total of forty thousand who thus met
+their deaths, during the whole period referred to.<a id="FNanchor_133" href="#Footnote_133" class="fnanchor">[27]</a></p>
+
+<p>One of the rankest weeds in the garden of wild delusions
+that flourished in England, in the seventeenth
+century was Matthew Hopkins, who prided himself
+upon the title of “Witch-finder General.” About 1644
+he made the discovery of some moles or other marks on
+the accused persons, which he advertised as “devil’s
+marks” and he immediately became in great demand
+in helping to hunt down and convict persons accused
+of this crime.</p>
+
+<p>He had several tests to subject them to, and one of
+the cruelest was to tie the hands and feet of the prisoner
+together cross-wise, the right thumb to the toe of the
+left foot and <i>vice versa</i>. Being thus tied, so they could
+not swim, they were wrapped in a cloth or blanket and
+placed in a pool of water or a river, on their backs. If
+they sank, they were innocent, but drowned for their
+innocence, and if they floated, they were adjudged guilty
+of witchcraft and hanged or burned.<a id="FNanchor_134" href="#Footnote_134" class="fnanchor">[28]</a></p>
+
+<p>Another kind of punishment, to extort a confession,
+was what was called “Waking” the witch. An iron
+bridle or hoop was placed cross-wise of her face with
+four prongs, penetrating the mouth. The hoop was
+fastened to the wall at the back of the head, so that
+the prisoner could not lie down. She was kept in this
+position sometimes for several days, attendants constantly
+prodding her, to keep her awake.<a id="FNanchor_135" href="#Footnote_135" class="fnanchor">[29]</a></p>
+
+<p><span class="pagenum"><a id="Page_60"></a>[60]</span></p>
+
+<p>In 1664 the venerable Sir Mathew Hale, condemned
+Amy Duny and Rose Cullender, to be burned at the
+stake in St. Edmondsbury, upon the most flimsy kind
+of proof, offered to establish this imaginary crime.<a id="FNanchor_136" href="#Footnote_136" class="fnanchor">[30]</a></p>
+
+<p>When these two old women went to a shop to purchase
+herring, their ugliness caused them to be insulted,
+and they resented it. The daughter of the owner of the
+store was afflicted with epilepsy and the women were
+charged with having bewitched her. She was blind-folded
+and when they touched her, her imagination and
+nervousness was such that she was thrown into a fit
+and this was received as proof positive of her bewitchment
+and the fact that she also was thrown into a fit,
+when similarly blind-folded, when others than the accused
+persons touched her, was held incompetent as
+evidence in their favor.</p>
+
+<p>Upon the evidence of Samuel Pacey, the girl’s father,
+Margaret Arnold, her aunt, and Thomas Brown, as an
+expert witness upon Witchcraft, the learned Sir
+Mathew Hale charged the jury to ascertain from the
+evidence, first, whether or not the persons charged were
+actually bewitched and if so, whether or not the prisoners
+had actually bewitched her. He personally told
+the jury that he had no doubt of the fact that witches
+existed, first because the Scriptures affirmed it and,
+secondly, because the laws of the country recognized
+it. The jury promptly returned a verdict of guilty and
+the girl and her father called the next morning to see
+Sir Mathew Hale and advised him that the complete
+recovery of the girl followed within a half hour after
+the verdict of conviction against the prisoners.<a id="FNanchor_137" href="#Footnote_137" class="fnanchor">[31]</a></p>
+
+<p><span class="pagenum"><a id="Page_61"></a>[61]</span></p>
+
+<p>Eleven cases of witchcraft were tried before Chief-Justice
+Holt, between 1694 and 1701, but sentiment
+was changing toward this offense, by this time and this
+rugged and astute lawyer made such an appeal to the
+jury, in each case, that all the defendants were acquitted.<a id="FNanchor_138" href="#Footnote_138" class="fnanchor">[32]</a></p>
+
+<p>Jane Wenham, known as the “Witch of Walkerne,”
+was tried and convicted before Lord Chief-Justice
+Powell, in 1711, upon the most fanciful and ridiculous
+kind of evidence, but she was pardoned, before her execution.<a id="FNanchor_139" href="#Footnote_139" class="fnanchor">[33]</a></p>
+
+<p>In 1716, however, a woman and her daughter only
+nine years old, were tried and convicted of sorcery, at
+Huntingdon, because they had washed their stockings
+and made a lather of soap and raised a storm and for
+this terrible offense they were both hanged.<a id="FNanchor_140" href="#Footnote_140" class="fnanchor">[34]</a></p>
+
+<p><span class="pagenum"><a id="Page_62"></a>[62]</span></p>
+
+<p>But this was the last judicial execution for witchcraft
+in England, although many prisoners were
+charged with the crime, between this date and the year
+1736, when the statute of James I. was repealed.<a id="FNanchor_141" href="#Footnote_141" class="fnanchor">[35]</a></p>
+
+<p>While the delirium of witchcraft was raging in Europe,—until
+its victims numbered tens of thousands
+and its votaries millions,—the fever spread across
+the ocean and the New England colonists also fell a
+prey to the superstition. The fear of witchcraft and
+sorcery seized the multitudes in the United States, in
+the middle of the seventeenth century and supposed
+criminals were arrested in such numbers that the
+prisons were not large enough to hold them.</p>
+
+<p>The persecutions at Salem, Massachusetts, lasted
+from February until September, 1692, during which
+time, nineteen supposed witches were hung, fourteen
+of them being women.<a id="FNanchor_142" href="#Footnote_142" class="fnanchor">[36]</a></p>
+
+<p>Under the early statutes of New York and Pennsylvania,
+witchcraft was a capital offense.<a id="FNanchor_143" href="#Footnote_143" class="fnanchor">[37]</a></p>
+
+<p>The good William Penn, who fled from similar persecution
+in England, presided in the “City of Brotherly
+Love,” at the trial of two Swedish women, who were
+arraigned for witchcraft. The funeral pile had been
+prepared and the flint and tinder were all ready to burn
+them, but fortunately they were acquitted of the
+charge.<a id="FNanchor_144" href="#Footnote_144" class="fnanchor">[38]</a></p>
+
+<p><span class="pagenum"><a id="Page_63"></a>[63]</span></p>
+
+<p>In Connecticut and Massachusetts, the penalty for
+witchcraft was death and the laws of these states were
+based not only upon the Mosaic code, but upon the
+Common Law of England, as well.</p>
+
+<p>A few trials occurred in Virginia and Maryland and
+six persons were hung, in Connecticut, for witchcraft,
+during the last half of the seventeenth century.</p>
+
+<p>Margaret Jones was executed for witchcraft, in Boston,
+in June, 1648; Mary Parsons, of Springfield, Massachusetts,
+was tried and convicted, in 1651; Mrs. Ann
+Hibbins was executed in Boston, in 1656, and Goody
+Glover was executed at the same place, in 1688.<a id="FNanchor_145" href="#Footnote_145" class="fnanchor">[39]</a></p>
+
+<p>The history of the persecutions at Salem, Massachusetts,
+has furnished the basis for several books, presenting
+the harrowing details of the trial of the several
+victims of the crusade against the delusion of witchcraft,
+at that place.<a id="FNanchor_146" href="#Footnote_146" class="fnanchor">[40]</a></p>
+
+<p>The Salem persecutions began with the delusions of
+a party of young girls, who imagined they were bewitched.
+Elizabeth Parris, aged nine, the daughter of
+Rev. Samuel Parris, her cousin, Abigail Williams, aged
+eleven, Ann Putnam, aged twelve, the daughter of the
+parish clerk, Mary Walcott, Mercy Lewis, Elizabeth
+Hubbard and several other girls furnished the evidence
+upon which these persecutions were begun.</p>
+
+<p>After reading of witchcraft and magic, these children,
+who had worked themselves into a state of nervous excitement,
+began to cut queer antics, such as hiding in
+holes; crawling under chairs; assuming odd postures<span class="pagenum"><a id="Page_64"></a>[64]</span>
+and uttering loud and incoherent expressions, all of
+which they attributed to the supernatural power exerted
+over them by three women of the neighborhood, Sarah
+Good, Sarah Osburn and an Indian woman named Tituba.
+Acting under the license of witchcraft, these girls
+disturbed religious worship, at will and performed other
+little misdemeanors, which their doting parents laid
+to the door of the witches, instead of correcting them,
+as they should have done.</p>
+
+<p>Finally the three women were arrested and arraigned
+for the crime of witchcraft. They were unpopular and
+uncomely women, as Mrs. Upham shows, Mrs. Good
+having been abandoned by her husband and Mrs. Osburn
+being a poor unhappy woman, bed-ridden and suffering
+from nervousness and melancholia.<a id="FNanchor_147" href="#Footnote_147" class="fnanchor">[41]</a> Tituba, the
+Indian woman, believed in witchcraft herself and had
+told the children stories of evil spirits until they firmly
+believed in her unnatural power.</p>
+
+<p>On March 1’, 1692, the trial was begun at the meeting
+house in Salem, before Esquires John Hathorn and
+Jonathan Corwin. Sarah Good was first examined and
+denied any communion with evil spirits and affirmed
+her service of God. No counsel was allowed the prisoners,
+as this was the custom according to the common
+law, in capital cases, unless the Court was in doubt, as
+the Judge was supposed to be the counsel for the
+prisoner.</p>
+
+<p>After having been tormented for some time, and believing
+her escape to lie only in the conviction of someone
+else, Mrs. Good accused her co-prisoner, Mrs. Osburn,
+and she was remanded to jail and Mrs. Osburn<span class="pagenum"><a id="Page_65"></a>[65]</span>
+was brought before the court. Frail in body and feeble
+in her intellect, this poor woman, when interrogated by
+the pompous oracles of the law, could only protest her
+innocence and deny any communion with evil spirits,
+or any knowledge of the offense charged against her
+by her alleged accomplice.</p>
+
+<p>After this travesty of a trial, she was again committed
+to prison, where she was kept heavily chained,
+from March 7, until May 10’, when she died, her innocent
+soul being thus forever released from the unnatural
+and inhuman affliction heaped upon her body
+by her fellow-beings. The Indian woman, when she
+was examined, did not deny that the children had been
+bewitched, but she laid it all to the door of her co-defendants,
+Mrs. Good and Mrs. Osburn.</p>
+
+<p>The girls, when brought before the supposed witches,
+fell down and shrieked, in their excitement; if the prisoners
+clasped their hands, they screamed that they
+were pinched; when they bit their lips, they in turn,
+asserted that they were being bitten; they produced
+pins, which they said the witches had pricked them
+with and worked upon the morbid imagination of the
+assembly so that the trials of the witches were little
+less than a burlesque.<a id="FNanchor_148" href="#Footnote_148" class="fnanchor">[42]</a></p>
+
+<p>Martha Corey was arrested on the 19’ of March, 1692,
+and the evidence of her husband was used against her,
+to the effect that she had taken his saddle to keep him
+from attending church; that she sat up late at night
+and frequently kneeled on the hearth, as if in prayer,<span class="pagenum"><a id="Page_66"></a>[66]</span>
+but uttered no word; that certain of his cattle had been
+afflicted and that one of their cats had had a fit. On
+such evidence as this, this good woman, was adjudged
+guilty and was one of the eight persons executed on
+the 22’ of September.<a id="FNanchor_149" href="#Footnote_149" class="fnanchor">[43]</a></p>
+
+<p>On April 19’, 1692, when he was over four score
+years of age, poor old Giles Corey was arrested for
+witchcraft, at Salem, and his case furnishes the only
+instance in the United States, where to avoid the attainder
+of his blood and the forfeiture of his estate, a
+prisoner obstinately stood mute and was “pressed to
+death.”</p>
+
+<p>His unfriendly course toward his wife and the attitude
+of two of his four sons-in-law in testifying
+against his wife, no doubt so worked upon his mind as
+to cause him to make a terrible expiation. He deeded
+all his property to his two favorite sons-in-law, William
+Cleeves and John Moulton, and decided to then stand
+mute and refuse to plead and let the law take its course.</p>
+
+<p>Of course he knew that the gates of justice were
+closed to him and that he would be convicted, although
+he was innocent, but he determined to defy the multitude
+and to withhold his plea, in order to save his
+property for his sons-in-law and to show his courage,
+in the supreme test.</p>
+
+<p>Longfellow, in his “New England Tragedies,” has
+described this feeble old man, withstanding the exhortations
+of his friends, in his determination to die the
+death of a martyr in an unjust cause, and one cannot
+read the graphic and realistic account of this tragedy,<span class="pagenum"><a id="Page_67"></a>[67]</span>
+without feelings of the greatest compassion and admiration
+for this grand old stoic, of our own soil, who
+bravely suffered his body to be pressed until all life
+was extinct and whose soul took its flight from the open
+field, near the Howard street burial ground, in the village
+of Salem, on September 19’, 1692.<a id="FNanchor_150" href="#Footnote_150" class="fnanchor">[44]</a></p>
+
+<p>In the case of the gentle Rebecca Nurse, even after
+her acquittal, by a jury, regularly empaneled and
+charged to try her for witchcraft, the frenzied populace
+“recalled the decision” and she was sentenced by
+the Court, to meet the demands of the mob; she was
+carted to the summit of Gallows hill, and hanged, on
+July 19’, and her case furnishes one of the most unjust
+instances of the “recall of a judicial decision” and one
+of the grossest travesties upon justice in the history
+of any country.<a id="FNanchor_151" href="#Footnote_151" class="fnanchor">[45]</a></p>
+
+<p>Because John and Elizabeth Proctor had absented
+themselves from the meetings, during the trials for
+witchcraft, they were finally accused and thrown in
+prison. He made a manly appeal for a trial at Boston,
+in a letter dated July 23’, 1692, addressed to Mr. Mather,
+Mr. Allen, Mr. Moody, Mr. Willard and Mr. Bailey,
+but all to no avail. His friends petitioned the Court;
+one of the girls who testified against them made a statement
+that she “must have been out of her head,” when<span class="pagenum"><a id="Page_68"></a>[68]</span>
+she gave her evidence, as it was not true, but nothing
+could stem the tide of the current of rapidly rising
+prejudice and resentment prevailing, so after a farcical
+trial, he was convicted and executed on August 19’,
+1692.</p>
+
+<p>His fearless defense of his good wife saved her life
+and two weeks after his death, she bore a baby in prison
+and it was no doubt due to her pregnant condition that
+she too, escaped the fury of the mob.<a id="FNanchor_152" href="#Footnote_152" class="fnanchor">[46]</a></p>
+
+<p>The trials of Bridget Bishop, Mary Easty, a sister
+of Rebecca Nurse, the Jacobs family, Martha Carrier
+and Philip and Mary English, Elizabeth How, Rev.
+George Burroughs, Sarah Wildes, Susanna Martin,
+John Williard, Alice Parker, Ann Pudeater, Margaret
+Scott, William Reed, Samuel Wardell and Mary
+Parker,<a id="FNanchor_153" href="#Footnote_153" class="fnanchor">[47]</a> are all interesting and present the details of
+the most stirring tragedies the courts of justice in this
+country have ever enacted, but space in this chapter
+will not permit the detailed account of these various
+trials.</p>
+
+<p>From the earliest times, a great deal has been written
+upon the subject of witchcraft and sorcery, in the different
+languages of Europe. The delusion has furnished
+a theme for long and arduous treatises by
+scientist, divine and philosopher and the poet and
+novelist, has found it a fruitful source of inspiration
+for song and story.</p>
+
+<p>The works of Dr. Joseph Glanvil, chaplain-in-ordinary
+to Charles II., and R. Baxter, in his “Certainties<span class="pagenum"><a id="Page_69"></a>[69]</span>
+of the Works of Spirits,” as vindications of the superstitions
+of witchcraft and sorcery, did much to spread
+the delusion, during the popularity of the superstition.</p>
+
+<p>Balthazar Bekker, a reformed Dutch clergyman, was
+the first to strike at the very foundation of the delusion,
+near the end of the seventeenth century; Hutchinson, in
+his historical essay on Witchcraft, in 1718, also took
+a skeptical view of the subject, and these men, with
+Weier and Reginald Scot, along with the sturdy advocates
+who defended the prisoners charged with witchcraft,
+and such judges as Lord Holt, in England, did
+much to discourage and overcome the belief in the
+fallacy.</p>
+
+<p>Burn’s lines to the “De’il” aptly express the popular
+notion of the time when the belief in spooks and
+evil spirits obtained:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Ae dreary, windy, winter night,</div>
+ <div class="verse indent0">The stars shot down wi’ sklentin light,</div>
+ <div class="verse indent0">Wi’ you, mysel, I got a fright</div>
+ <div class="verse indent6">Ayont the lough;</div>
+ <div class="verse indent0">Ye, like a rash-bush, stood in sight</div>
+ <div class="verse indent6">Wi’ waving sough.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">The cudgel in my nieve did shake,</div>
+ <div class="verse indent0">Each bristled hair stood like a stake,</div>
+ <div class="verse indent0">When wi’ an eldritch stour, ‘quaick, quaick’,</div>
+ <div class="verse indent6">Among the springs</div>
+ <div class="verse indent0">Away ye squatter’d, like a drake,</div>
+ <div class="verse indent6">On whistling wiggs.”</div>
+ </div>
+</div>
+</div>
+
+<p>The notion of the devil then was that he was a large,
+ill-shaped, hairy sprite, with long tail, horns, cloven
+feet and wings, as we so often see him pictured in the
+old representations.</p>
+
+<p>Before Milton’s time, he was believed to be a mere
+mischievous, ugly and petty spirit, who played fantastic<span class="pagenum"><a id="Page_70"></a>[70]</span>
+tricks upon humanity, but Milton made of him the paragon
+of evil, not merely grotesque, but a fiend, whose
+power was all used for evil.<a id="FNanchor_154" href="#Footnote_154" class="fnanchor">[48]</a></p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“The other shape,</div>
+ <div class="verse indent0">If shape it might be call’d that shape had none</div>
+ <div class="verse indent0">Distinguishable in member, joint or limb;</div>
+ <div class="verse indent0">Or substance might be call’d that shadow seem’d,</div>
+ <div class="verse indent0">For each seem’d either,—black it stood as night,</div>
+ <div class="verse indent0">Fierce as ten furies, terrible as Hell,</div>
+ <div class="verse indent0">And shook a dreadful dart; what seem’d his head</div>
+ <div class="verse indent0">The likeness of a kingly crown had on.</div>
+ <div class="verse indent0">Satan was now at hand.”<a id="FNanchor_155" href="#Footnote_155" class="fnanchor">[49]</a></div>
+ </div>
+</div>
+</div>
+
+<p>From the history of Demonology and Witchcraft, as
+given in the works of Bodin, Bekker, Leloyer, De
+Lancre, Garinet, Mackay, Lecky, Nevins, Upham, Benson,
+Goodwin and Sir Walter Scott, demons of both
+sexes had existed in the world, ever since the fall of
+Adam. They increased and multiplied with wonderful
+rapidity; inhabited the air and had no fixed residence
+or abode, and when they congregated, windstorms, hurricanes
+and earthquakes resulted. They were supposed
+to delight in destroying the beauties of nature and
+the possessions of man and entered the bodies of individuals
+with their breath and caused pains and sickness
+and bad dreams. All these demons were at the command
+of any person who would barter his soul to them
+and his or her evil purpose was then accomplished, but
+no good action would be undertaken.</p>
+
+<p>In France and England the witches were supposed
+to ride astride broom-sticks, while in Italy and Spain,<span class="pagenum"><a id="Page_71"></a>[71]</span>
+the Devil, himself, in the shape of a goat, carried them
+on his own back.<a id="FNanchor_156" href="#Footnote_156" class="fnanchor">[50]</a></p>
+
+<p>This belief prevailed for many centuries all over Europe
+and in certain sections of the world the belief
+in witchcraft and sorcery is not entirely eradicated
+today.<a id="FNanchor_157" href="#Footnote_157" class="fnanchor">[51]</a></p>
+
+<p>In 1627, a ballad entitled the “Druten Zeitung,” or
+“Witches Gazette” was quite popular in Germany. The
+sufferings of the witches burned at Würzburg, Bamberg,
+Franconia and other cities and provinces of the
+German Empire, were minutely described, by the poet,
+who grew quite witty in his descriptions of the contortions
+produced by pain, when the flames brought
+forth shrieks from the poor wretches who were burned
+alive.<a id="FNanchor_158" href="#Footnote_158" class="fnanchor">[52]</a></p>
+
+<p>The “Amber Witch,” by William Meinhold, being<span class="pagenum"><a id="Page_72"></a>[72]</span>
+the most interesting trial for witchcraft, of Mary
+Schweidler, is one of the most exceptional and interesting
+of the books of fiction, based upon the delusion of
+witchcraft.</p>
+
+<p>But let us draw the curtain upon this continuous
+human tragedy enacted for two and a half centuries, in
+Europe, in the name of the law, cataloguing the long
+list of judicial murders, upon the stage where superstition
+and delusion alone held sway.</p>
+
+<p>It is sad, in the extreme, to contemplate the long list
+of human beings whose lives were forfeited, in the early
+days of “little knowledge,” by those who thus:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Hoped to merit Heaven, by making earth a Hell.”</div>
+ </div>
+</div>
+</div>
+
+<p>And it is doubly sad, to contemplate that the Temples
+of Justice were peopled by these fears of fantasy and
+the imagination—like some of the fetishes that modern
+critics of our present judicial system erect in some
+places—and that the high priests of the temples blindly
+followed the mad cry of the mob and laid aside the
+scales of justice to interpret the unjust ideals of an
+intoxicated public sentiment, following only the red
+flag of murder. These jurists of the past centuries
+who participated in this wholesale slaughter of individual
+right, may have feared their recall, if they withstood
+the frenzy of a wrought-up public clamor, and in
+this a lesson can be learned, of the danger of following
+the demands of public sentiment, in courts of justice,
+instead of the proper ideals of equality and justice.</p>
+
+<p>It is fortunate that only the small percent of the
+densely ignorant now-a-days, account for the misunderstood
+facts and phenomena of nature by the fears and
+delusions of witchcraft and sorcery and that in the<span class="pagenum"><a id="Page_73"></a>[73]</span>
+progress of the race, the delusion of witchcraft has
+been crowded into the dark, remote and rugged sections
+where alone the foot of civilization can find no resting-place.</p>
+
+<p>There are few, if any, more deplorable episodes, in
+human history than that of the persecutions for witchcraft.
+They illustrate to what an extreme degree of
+relentless cruelty human nature will go, when fanned
+to a fever-heat of excitement by some fanatical delusion.
+On the other hand, the history of the persecutions for
+witchcraft show how little reliance can be placed upon
+the credibility of witnesses, influenced by some general
+excitement, or acting under a mistaken belief of duty,
+based upon the attainment of some popular object.
+Thousands of witnesses who appeared against the poor
+victims charged with this hated crime of witchcraft
+and sorcery, honestly believed in the fantastical delusions
+and tricks of fancy that they described as actual
+occurrences, which in fact had no better foundation than
+their own fervid imaginations.</p>
+
+<p>Regarding man’s self, alone, it is difficult to reconcile
+the beneficent laws taught by the church, with the
+sad “scope and scheme” of things, as disclosed by the
+pathetic facts of history, in connection with this subject.
+And yet:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“You cry ‘the cruelty of things’ is mystery to your purblind eye,</div>
+ <div class="verse indent0">Which fixed upon a point in space, the general project passes by.</div>
+ <div class="center">...</div>
+ <div class="verse indent0">The dreadest sound man’s ear can hear, the war and rush of stormy wind</div>
+ <div class="verse indent0">Depures the stuff of human life, breeds health and strength for humankind.</div>
+ <div class="verse indent0">And thus the race of Being runs, till haply, in the time to be,</div>
+ <div class="verse indent0">Earth shifts her pole, and Mushtari men another falling star shall see.”</div>
+ </div>
+</div>
+</div>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_107" href="#FNanchor_107" class="label">[1]</a> II. Mackay’s “Memoirs of Delusions,” pp. 169, 170.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_108" href="#FNanchor_108" class="label">[2]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_109" href="#FNanchor_109" class="label">[3]</a> Johns’ “Oldest Code of Laws,” 1; Scheil’s “Tome IV. Textes
+Elamites-Semitiques,” etc., Johns’ “Babylonian and Assyrian Laws,
+Contracts and Letters.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_110" href="#FNanchor_110" class="label">[4]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_111" href="#FNanchor_111" class="label">[5]</a> II. Mackay’s “Memoirs of Delusions,” p. 169; Exod. XXII. 18.
+As Mackay shows, the sublime hope of immortality, in the early
+days of “little knowledge” became the source of a whole train of
+superstitions, from which fount a deluge of blood and horror poured
+over Europe, for two and a half centuries. “Memoirs of Delusions,”
+vol. II., p. 168.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_112" href="#FNanchor_112" class="label">[6]</a> Niebuhr’s Lecture, Roman History (English Tr.), vol. I., pp.
+295, 319; George Long’s article “Lex,” in Smith’s Dictionary of
+Greek and Roman Antiquities; Mommsen’s History of Rome
+(English translation), vol. I., book I., ch. II. and book II., ch. 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_113" href="#FNanchor_113" class="label">[7]</a> <i>Codex Justin. lib. ix, tit. 18.</i></p>
+
+<p>The “Dialogue on Witches and Witchcraft,” published by the
+Percy Society from the literature of the middle ages, presents the
+reasons and basis for the belief in Witchcraft, “in which is layed
+open how craftily the divell deceiveth not onely the witches, but
+many other, and so leadeth them awrie into manie great errours,
+By George Giffard, Minister of God’s word, in Malden, published in
+1603.”</p>
+
+<p>In this Dialogue, Daniel quotes Christ’s words, as reported by
+Marke, that his name is “Legion, for we are many,” as evidence
+of the existence of “multitudes and armies of divels, as we see in
+the Gospel.” The command of the Mosaic law “Thou shalt not
+suffer a witch to live,” is quoted as a sufficient reason for rooting
+them out; the words of Moses are quoted that the Lord would cast
+out those nations that hearkened unto soothsayers and diviners,
+pronouncing that every one that does those things are an abomination
+to the Lord; that the Lord not only declared that such as
+practiced witchcraft and sorcery were an abomination before the
+Lord, but that they should “also bee rooted out.” (Percy Society Pub.
+vol. VIII., 24, 40, 42, 52, 72.)</p>
+
+<p>The belief that cats were bewitched to do the bidding of the
+devil, which formed such a large part of the delusion of witchcraft,
+as practiced in the middle ages, is also touched on, in the “Dialogue
+on Witches,” in the above interesting publication, from the literature
+of the middle ages which can be read with much amusement
+and entertainment, because it gives in realistic hue, a vivid pen
+picture of the old delusion, just as it existed in the early days of
+the seventeenth century.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_114" href="#FNanchor_114" class="label">[8]</a> Cnut, II., 4; Lea. <i>op. cit.</i> iii. 420; Brunner D. R. G. ii. 678; II.
+Pollock and Maitland’s History English Law, p. 553.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_115" href="#FNanchor_115" class="label">[9]</a> Leg. Hen. 71; II. Pollock and Maitland’s History English Law,
+553.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_116" href="#FNanchor_116" class="label">[10]</a> II. Pollock and Maitland’s History English Law, p. 553.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_117" href="#FNanchor_117" class="label">[11]</a> II. Pollock and Maitland’s History English Law, p. 553.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_118" href="#FNanchor_118" class="label">[12]</a> Garinet’s “Histoire de la Magie en France.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_119" href="#FNanchor_119" class="label">[13]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_120" href="#FNanchor_120" class="label">[14]</a> Dr. Sprenger, in his “Life of Mohammed,” computes the entire
+number of persons who were burned as witches, during the <i>Christian
+epoch</i>, as about <i>nine million</i>.</p>
+
+<p>Tasso attributed the belief in magic and witchcraft to the Crusaders,
+but M. Michaud, in his “History of the Crusades,” denies
+that the Crusaders believed in witches. However, the edicts of
+Charlemagne demonstrate quite conclusively that Tasso was right,
+for the Crusaders, in common with the millions of their contemporaries
+who were votaries of the delusion of witchcraft and sorcery,
+attributed the misunderstood facts in the natural world about them,
+to supernatural powers of magic.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_121" href="#FNanchor_121" class="label">[15]</a> Mackay’s “Memoirs of Delusions,” vol. II., p. 186.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_122" href="#FNanchor_122" class="label">[16]</a> Monstrelet’s Chronicle.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_123" href="#FNanchor_123" class="label">[17]</a> II. Mackay’s “Memoirs of Delusions,” p. 194.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_124" href="#FNanchor_124" class="label">[18]</a> Mackay’s “Memoirs of Delusions,” vol. II., p. 195.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_125" href="#FNanchor_125" class="label">[19]</a> <i>Ante idem.</i>, p. 197; Danaeus, “Dialogues of Witches.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_126" href="#FNanchor_126" class="label">[20]</a> Mackay’s “Memoirs of Delusions,” vol. II., p. 199.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_127" href="#FNanchor_127" class="label">[21]</a> The ignorant Canadian French still believe in the Loup-garou,
+just as the French did in the centuries gone by.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_128" href="#FNanchor_128" class="label">[22]</a> Mackay’s “Memoirs of Delusions,” vol. II., p. 201.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_129" href="#FNanchor_129" class="label">[23]</a> Hutchinson, on Witchcraft.</p>
+
+<p>In the year 1670 a number of women were condemned by the
+Parliament of Normandy, for riding broom-sticks to the Domdaniel.
+Louis XIV., commuted their sentences to banishment for life, when
+the Parliament of Rouen presented to him a memorial, insisting
+that he set aside the order for their commutation, but the wise
+King stood firm and refused to let them be judicially murdered in
+his kingdom. (For this memorial in full, see II. Mackay’s “Memoirs
+of Delusions,” pp. 289, 298.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_130" href="#FNanchor_130" class="label">[24]</a> II. Mackay’s “Memoirs of Delusions,” p. 226.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_131" href="#FNanchor_131" class="label">[25]</a> Very severe statutes were passed during the reign of Elizabeth,
+against the imaginary crime of witchcraft and sorcery. The statute
+33 Henry VIII. c. 8, was repealed by I. Edward VI., c. 12 and as this
+left no law in force to punish this class of offenders, it was enacted
+by 5 Elizabeth, c. 16, that if any person used or practiced witchcraft,
+enchantment, charm or sorcery, whereby any one shall happen to be
+killed or destroyed, it shall be felony, without clergy. And if anyone
+thereby be wasted, consumed, or lamed, in body or member,
+or any of his goods destroyed or impaired, such offender shall be
+imprisoned for a year, and stand in the pillory once a quarter,
+during that time for six hours. (V. Reeve’s History English Law,
+p. 349.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_132" href="#FNanchor_132" class="label">[26]</a> See “Butlers Hudibras,” edition by Dr. Zachary Gray (vol. II).</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_133" href="#FNanchor_133" class="label">[27]</a> Mackay’s “Memoirs of Delusions,” vol. II., p. 237.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_134" href="#FNanchor_134" class="label">[28]</a> Lecky’s “Rationalism in Europe,” vol. I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_135" href="#FNanchor_135" class="label">[29]</a> Lecky’s “Rationalism in Europe,” p. 146, vol. I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_136" href="#FNanchor_136" class="label">[30]</a> II. Mackay’s “Memoirs of Delusions,” p. 248.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_137" href="#FNanchor_137" class="label">[31]</a> II. Mackay’s “Memoirs of Delusions,” pp. 253, 254.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_138" href="#FNanchor_138" class="label">[32]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_139" href="#FNanchor_139" class="label">[33]</a> II. Mackay’s “Memoirs of Delusions,” p. 255.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_140" href="#FNanchor_140" class="label">[34]</a> II. Mackay’s “Memoirs of Delusions,” p. 258.</p>
+
+<p>While this hideous record of blood and murder, in the name of
+the law, was being recorded in England, during the seventeenth
+century, a similar record was being written, in the criminal courts
+of Spain, Italy, Scotland and Germany. Thousands of innocent
+people lost their lives under this charge in these countries, during
+this century.</p>
+
+<p>As an illustration of this mad carnival of death, in Würzburg,
+alone in the two years following 1627, one hundred and fifty-seven
+people were burned, in twenty-nine burnings, averaging from five
+to six people at a burning. The wealthy and the paupers, old and
+young, the ungainly and the comely, all alike suffered in this unholy
+crusade.</p>
+
+<p>Of the list there were three play-actors; four innkeepers; three
+councilmen; fourteen vicars; the burgomaster’s lady; an apothecary’s
+wife and daughter, the wife, sons and daughter of the councillor
+Stolzenberg and Gobel Babelin, “the prettiest girl in the town,”
+thirty-two vagrants and a large number of little innocent children,
+who were guilty of no offense or crime other than that of living in
+a period when their innocence was considered a crime. (Hauber’s
+“<i>Acta et Scripta Magica</i>.”)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_141" href="#FNanchor_141" class="label">[35]</a> II. Mackay’s “Memoirs of Delusions,” p. 258.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_142" href="#FNanchor_142" class="label">[36]</a> Upham’s “Salem Witchcraft, in Outline”; Nevin’s “Witchcraft in
+Salem Village.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_143" href="#FNanchor_143" class="label">[37]</a> Upham’s “Witchcraft in Outline,” p. 6.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_144" href="#FNanchor_144" class="label">[38]</a> Upham’s “Witchcraft in Outline,” 6.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_145" href="#FNanchor_145" class="label">[39]</a> The trial of Mary Dyer, Quaker, is presented in “Two Letters
+of William Dyer,” 1659-1660.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_146" href="#FNanchor_146" class="label">[40]</a> Upham’s “Salem Witchcraft”; Nevin’s “Witchcraft in Salem”;
+Moore’s “History of Witchcraft in Massachusetts.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_147" href="#FNanchor_147" class="label">[41]</a> Upham’s “Salem Witchcraft,” pp. 25, 26.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_148" href="#FNanchor_148" class="label">[42]</a> Upham’s “Salem Witchcraft,” pp. 44, 45; Nevin’s “Witchcraft
+in Salem,” 46, 69.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_149" href="#FNanchor_149" class="label">[43]</a> Upham’s “Witchcraft in Outline,” 61.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_150" href="#FNanchor_150" class="label">[44]</a> <i>Ante idem.</i>, p. 69.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_151" href="#FNanchor_151" class="label">[45]</a> Rose Terry Cooke, in her, “Death of Goody Nurse,” thus describes
+the death of this good woman:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“They hanged this weary woman there,</div>
+ <div class="verse indent2">Like any felon stout;</div>
+ <div class="verse indent0">Her white hairs on the cruel rope</div>
+ <div class="verse indent2">Were scattered all about.”</div>
+ </div>
+</div>
+</div>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_152" href="#FNanchor_152" class="label">[46]</a> Upham’s “Salem Witchcraft,” p. 87.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_153" href="#FNanchor_153" class="label">[47]</a> Upham’s “Salem Witchcraft,” pp. 142, 143; Nevin’s “Witchcraft
+in Salem,” pp. 70, 253.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_154" href="#FNanchor_154" class="label">[48]</a> See article on “Demonology,” in Foreign Quarterly Review,
+London, 1840.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_155" href="#FNanchor_155" class="label">[49]</a> Paradise Lost, book ii, Line 666.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_156" href="#FNanchor_156" class="label">[50]</a> II. Mackay’s “Memoirs of Delusions,” p. 178.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_157" href="#FNanchor_157" class="label">[51]</a> Many of the ignorant Canadian-French still believe in the
+delusions of the loup-garou, or man wolf, and in the southern portion
+of Nigeria, as recently shown by P. Amaury Talbot, superstition
+and witchcraft lurk in all the forests and lakes of the country.
+Describing these superstitions, in a recent article in the London
+Telegraph, Mr. Talbot says:</p>
+
+<p>“The bush with its soft green twilight, dark shadows, and quivering
+lights, is peopled by many terrors, but among these ‘Ojje’, or
+witchcraft, reigns supreme. The bird which flies in at your open
+door in the sunlight, the bat which circles round you at night, the
+small bushbeasts which cross your path while hunting, all may be
+familiars of witch or wizard or even the latter themselves, disguised
+to do you hurt. Sometimes the terror of witchcraft will
+scatter a whole town.”</p>
+
+<p>And for belief in witchcraft, among the southern darkies, see
+Journal of American Folk Lore, vol. III., p. 205; Bruce’s “Plantation
+Negro as a Freeman”; and Jones’ “Negro Myths from the
+Georgia Coast.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_158" href="#FNanchor_158" class="label">[52]</a> II. Mackay’s “Memoirs of Delusions,” p. 277.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_74"></a>[74]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_III">CHAPTER III.<br>
+<span class="smcap">Recall of Judges.</span></h2>
+
+</div>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Of all the virtues, Justice is the best,</div>
+ <div class="verse indent0">Valour without it is a common pest.</div>
+ <div class="center">...</div>
+ <div class="verse indent0">All other virtues dwell but in the blood,</div>
+ <div class="verse indent0">That in the soul, and gives the name of good;</div>
+ <div class="verse indent0">Justice, the queen of virtues.”—Waller.</div>
+ </div>
+</div>
+</div>
+
+<p>Judge is the generic descriptive name given to one
+who is invested with the power of judging and deciding
+causes in the courts of law. The recall, as applied to
+the judiciary, is the withdrawal of the power given a
+judge to decide causes.</p>
+
+<p>As justice has always been the great interest of man,
+on earth, we find that the virtue has ever been extolled,
+as one of the greatest blessings of the human race and
+among the earliest institutions of which we have any
+knowledge, we find that courts were constituted, for
+the distribution or enforcement of justice, through the
+medium of judges.<a id="FNanchor_159" href="#Footnote_159" class="fnanchor">[1]</a></p>
+
+<p><span class="pagenum"><a id="Page_75"></a>[75]</span></p>
+
+<p>The great law-giver, Moses, having learned the hard
+lesson from the book of human life, early grasped the
+truth that man’s nature needed protection from its own
+impulses and passions, and that an exalted rule of
+conduct, commanding what was right, to be effective,
+must be enforced and interpreted, by a wholly disinterested
+guiding influence. He accordingly established
+the administration of justice, among the ancient Israelites,
+by choosing “able men, out of Israel, such as
+feared God, men of truth, hating covetousness; and
+made them heads over the people, rulers of thousands,
+rulers of hundreds, rulers of fifties, and rulers of tens;
+and they judged the people at all seasons; the hard
+causes they brought unto Moses, but every small matter
+they judged themselves.”<a id="FNanchor_160" href="#Footnote_160" class="fnanchor">[2]</a></p>
+
+<p>Grasping, even at this early day at the exalted standard,
+later realized, in the Horatian ideal, “of the just
+man, who, firm in the consciousness of right, disdains,
+with equanimity, the frowns of a tyrant and the clamors
+of a mob,” we find this old patriarch, fifteen centuries
+before Christ, admonishing the judges of the Israelites:</p>
+
+<div class="blockquote">
+
+<p>“Thou shalt not follow a multitude to do evil; neither
+shalt thou speak in a cause, to decline, after many, to
+wrest judgment.”<a id="FNanchor_161" href="#Footnote_161" class="fnanchor">[3]</a></p>
+
+</div>
+
+<p>Admonishing the judges, further, in regard to
+being swayed in their decisions, by the fickle winds of
+public sentiment, Moses said:</p>
+
+<div class="blockquote">
+
+<p>“Ye shall not respect persons in judgment, but ye
+shall hear the small as well as the great; <i>ye shall not
+be afraid of the face of man</i>; for the judgment is God’s;<span class="pagenum"><a id="Page_76"></a>[76]</span>
+and the cause that is too hard for you, bring it unto me
+and I will hear it.”<a id="FNanchor_162" href="#Footnote_162" class="fnanchor">[4]</a></p>
+
+</div>
+
+<p>And not content with warning the judges of the
+danger of fearing the people, in the act of pronouncing
+judgment, he also warned the people of the duty of
+respecting the judgments of the courts, in the following
+wise commands:</p>
+
+<div class="blockquote">
+
+<p>“And thou shalt come unto the Priests and Levites,
+and unto the Judge that shall be in those days and inquire;
+and they shall shew thee the sentence of judgment.
+And thou shalt do according to the sentence,
+which they of that place which the Lord shall choose,
+shall shew thee; and thou shalt observe to do according
+to all that they inform thee. According to the sentence
+of the law which they shall teach thee, and according
+to the judgment which they shall tell thee, thou shalt
+do; thou shalt not decline from the sentence which they
+shall shew thee to the right hand, nor to the left. And
+the man that will do presumptuously, and will not
+hearken unto the priest that standeth to minister there,
+before the Lord thy God, <i>or unto the Judge</i>, even that
+man shall die and thou shalt put away the evil from
+Israel. And all the people shall hear and fear, and do
+no more presumptuously.”<a id="FNanchor_163" href="#Footnote_163" class="fnanchor">[5]</a></p>
+
+</div>
+
+<p>It thus appears that the ancient Israelites appreciated
+the virtue known as Justice and more nearly approximated
+the cultivated ideal existing in more recent
+times, for they understood, or Moses did, that it was
+indispensable, in the act of dispensing justice, for the
+incumbent of the judgment seat, to rise superior to the
+popular standards of justice and equality and that the
+due and orderly realization of the virtue could only be<span class="pagenum"><a id="Page_77"></a>[77]</span>
+realized by a proper regard and respect for the judgments
+of the courts when they were pronounced.</p>
+
+<p>In this respect, the old patriarchs were in advance of
+the ancient Babylonians and Athenians, for while attempting
+the distribution of justice, through the medium
+of disinterested judges, they did not seem to
+grasp the necessity for an independent judiciary, but
+upon unjust grounds they permitted the recall and
+debasement of their wisest judges.</p>
+
+<p>In the oldest Code of Laws in the known world, the
+code of Hammurabi, King of Babylon, 2285 B. C.,<a id="FNanchor_164" href="#Footnote_164" class="fnanchor">[6]</a> who
+claimed to have received his laws from the seated sun-god,
+Samas, the “judge of heaven and earth;”—an
+old, Mosaic bearded king, as represented to us, from
+the dark ages, upon the black block of diorite, presenting
+also his Code of Laws; known to history as the
+Babylonian king, who conquered the four quarters
+of the earth; who enriched Ur (Father Abraham’s
+birthplace), the humble, the reverent, who clothed the
+gravestones of Malkat with green; the warrior who
+guarded Larsa and renewed Ebabbar; the Shield of the
+land who united the scattered inhabitants of Isin; who
+firmly founded the farm of Kish; the White Potent one
+who penetrated the secret cave of the bandits; one who
+recognizes the Right and who Rules by Law; who
+humbles himself before the great gods<a id="FNanchor_165" href="#Footnote_165" class="fnanchor">[7]</a>—this valiant
+one of the misty ages of long ago, in his Code, after
+providing for the death of the man who should weave
+a spell or put a ban upon another man, in the fifth section<span class="pagenum"><a id="Page_78"></a>[78]</span>
+of his Code of Laws, provided for the recall or removal
+of the judges of his courts, by the following
+provision:</p>
+
+<div class="blockquote">
+
+<p>“If a judge has judged a judgment, decided a decision,
+granted a sealed sentence, and afterwards has
+altered his judgment, that judge, for the alteration of
+the judgment that he judged, one shall put him to account
+and he shall pay twelve-fold the penalty, which
+was in the said judgment, and in the assembly one
+shall expel him from his judgment seat, and he shall
+not return, and with the judges at a judgment he shall
+not take his seat.”<a id="FNanchor_166" href="#Footnote_166" class="fnanchor">[8]</a></p>
+
+</div>
+
+<p>Petitions and motions for a rehearing were thus
+interdicted by Hammurabi, regardless of the mistakes
+entering into the judgment, which could only be righted
+by a rehearing, or a new trial, and if a new trial were
+granted, the judge was publicly disgraced and recalled
+and was never allowed to sit in judgment again.</p>
+
+<p>So unalterably opposed were the ancient Babylonians
+to the granting of a new trial, that if a decision for the
+infliction of a penalty were set aside, the judge had to<span class="pagenum"><a id="Page_79"></a>[79]</span>
+pay it twelve-fold to him from whom it was exacted and
+for any new trial granted by him, the judge was publicly
+deposed from his office and expelled from his seat of
+judgment and no longer permitted to sit with the
+judges. According to the strict letter of the Code, it
+was no justification for the judge to be able to show
+that the new trial was granted to prevent a miscarriage
+of justice, for as the law reads, a judgment once pronounced
+was irrevocable, for that judge, at least.<a id="FNanchor_167" href="#Footnote_167" class="fnanchor">[9]</a></p>
+
+<p>But let us look more minutely into the procedure,
+governing the right of litigants in the days of Hammurabi.
+It was the prerogative of the King, during the
+First Dynasty, to send to the local judges his own decision
+of a cause, or to simply send the case to them
+for trial.</p>
+
+<p>Trials were held in the great temple of Ebabbarim,
+at Sippara, where copies of his code had been set up
+by Hammurabi, at the temple of Merodach in Babylon,
+at the temple of Sin, at Larsa, or the temple of Ishhara.
+Witnesses, it seems, were sworn, before God and
+the King, to swear to the truth, touching the controversy,
+and documentary evidence was used, much as
+it is today, to establish a right or title by written evidence,
+or the agreement of the parties.<a id="FNanchor_168" href="#Footnote_168" class="fnanchor">[10]</a> Having ascertained
+where the right resided, it was the peculiar
+province of the judge to “cause them to receive judgment”;
+the strife was accordingly quieted and the judgment
+passed into an irrevocable decree, which the judge<span class="pagenum"><a id="Page_80"></a>[80]</span>
+himself could not set aside, without thereby working
+his own disgrace and recall.<a id="FNanchor_169" href="#Footnote_169" class="fnanchor">[11]</a> The decision was drawn
+up by the scribe and placed upon a tablet, sealed by
+the judge and some of these irrevocable tablets, as
+imperishable conclusions of these ancient law-suits
+have come to us, after thousands of years, to tell their
+tale.<a id="FNanchor_170" href="#Footnote_170" class="fnanchor">[12]</a></p>
+
+<p><span class="pagenum"><a id="Page_81"></a>[81]</span></p>
+
+<p>This recipient of the wisdom of the sun-god, Hammurabi,
+did not stop with humiliating and degrading
+the upright judge, who, to right a wrong judgment
+was willing to admit his error to the advantage of a
+wronged litigant, by granting a new trial, but in keeping
+with such a mistaken standard, the Code of this ancient
+ruler of the Babylonians also punished the unsuccessful
+surgeon, by removing the hand that performed an
+unsuccessful operation;<a id="FNanchor_171" href="#Footnote_171" class="fnanchor">[13]</a> by penalizing the unsuccessful
+veterinarian, who lost his neighbor’s cattle or
+horse;<a id="FNanchor_172" href="#Footnote_172" class="fnanchor">[14]</a> the builder was made liable for all damages
+resulting from the fall of a building he had erected<a id="FNanchor_173" href="#Footnote_173" class="fnanchor">[15]</a>
+and, in general, it was the policy of this strict king, to
+raise the standards of public duty, by punishing the
+incumbents of public office and penalizing the members
+of the learned professions and vocations, rather than
+cultivating the higher standards of the professions, by
+the elimination of the unskilled therefrom.</p>
+
+<p>The ancient Greeks also practiced the recall and
+ostracism of their most eminent judges and other powerful
+public officials, who incurred the ill-will of the populace,
+because of some unpopular decision, or the envy of
+any considerable number of citizens, because of some
+alleged undemocratic performance.</p>
+
+<p>This ostracism, or recall, in Greece, is said to have
+been established by Cleisthenes after the expulsion of
+the Peisistratidae<a id="FNanchor_174" href="#Footnote_174" class="fnanchor">[16]</a> and the nature and object of the<span class="pagenum"><a id="Page_82"></a>[82]</span>
+recall, as then obtaining, is thus explained by the philosopher
+Aristotle:</p>
+
+<div class="blockquote">
+
+<p>“Democratical states <i>used to</i> ostracise and remove
+from the city for a definite time, those who appeared
+to be preeminent above their fellow citizens, by reason
+of their wealth, the number of their friends, or any
+other means of influence.”<a id="FNanchor_175" href="#Footnote_175" class="fnanchor">[17]</a></p>
+
+</div>
+
+<p>The removal and ostracism of public officers, in
+Greece, does not seem to have been used as a punishment
+for any crime or particular unfitness developed
+by the official removed, but rather as a precautionary
+measure, to dispense with the services of those who
+became so powerful as to excite the fear or attract the
+envy of their contemporaries.<a id="FNanchor_176" href="#Footnote_176" class="fnanchor">[18]</a></p>
+
+<p>The procedure whereby the recall or ostracism of a
+judge or other public official was accomplished, in
+ancient Greece, was as follows: A space was enclosed
+by barricades, with ten entrances, for the ten tribes.
+The tribesmen entered the enclosed space, by these ten
+entrances, each with a shell, or piece of earthenware,
+on which he wrote the name of the official he wished
+recalled or degraded. The casting and enumeration of
+the vote was regulated and supervised by the presidents
+dents of the Senate and by the nine archons, and if as
+many as 6000 votes against any one official was polled,
+this <i>ipso facto</i> removed him from office and he was
+obliged to leave the city of his residence within ten
+days from that date; but if the total number of votes
+cast against him did not equal 6000 he was not removed<span class="pagenum"><a id="Page_83"></a>[83]</span>
+from office.<a id="FNanchor_177" href="#Footnote_177" class="fnanchor">[19]</a> Because of the shell, or piece of earthenware,
+upon which the vote was cast against the official
+removed from office, the proceeding came to be known
+as the “earthenware scourge.”<a id="FNanchor_178" href="#Footnote_178" class="fnanchor">[20]</a></p>
+
+<p>By this proceeding, in ancient Greece, some of the
+most distinguished men of the nation were removed,
+or ostracised, but when it was found that their services
+were indispensable to the public welfare, they were
+recalled to office. Cimon, Alcibiades, Themistocles,
+Aristeides and many other prominent citizens suffered
+this degradation in Athens and other democratical
+states, in Greece, for the recall was considered as a
+necessary precaution to ensure absolute equality among
+the citizens of the various commonwealths.</p>
+
+<p>As a concrete illustration of the application of the
+recall to the judiciary, in Greece, we will take the case
+of Aristeides, known as “Aristeides the Just.” There
+is authority for the statement that the judicial integrity
+and ability of this old Greek patriot was so generally
+recognized, in Athens, that during the presentation of
+one of the tragedies of Eschylus, when one of the characters
+was referred to as a man who “cared more <i>to be
+just</i>, than to appear so,” all eyes were instantly turned
+toward Aristeides, as the one man, who, of all other
+Greeks, most merited the title of “The Just,” and
+from this time on this truly royal, or divine appellation,
+according to Plutarch, was, by universal consent, attributed
+to this virtuous man.<a id="FNanchor_179" href="#Footnote_179" class="fnanchor">[21]</a></p>
+
+<p><span class="pagenum"><a id="Page_84"></a>[84]</span></p>
+
+<p>This remarkable distinction aroused envy against
+Aristeides and it is reported that Themistocles circulated
+a rumor that by determining and judging causes
+in private, he was undermining the courts of judicature
+and was secretly making way for a monarchy in his own
+person, so the jealousies of the populace were so
+aroused against him that it was decided to recall this
+upright judge. Plutarch relates the pathetic circumstance,
+connected with the degradation and ostracism
+of this Just Judge, that while the voting was taking
+place, in the railed market-place, Aristeides was approached
+by an illiterate citizen, who handed him his
+<i>ostracon</i>, or sherd and directed him to write his own
+name upon the shell. Without disclosing his identity,
+Aristeides asked the man if the Judge had ever done
+him any injury, when the voter replied: “None at all,
+neither know I the man; but I am tired of hearing him
+everywhere called <i>The Just</i>.”<a id="FNanchor_180" href="#Footnote_180" class="fnanchor">[22]</a></p>
+
+<p>Aristeides made no reply to the man, but wrote as
+he directed and returned the sherd to him, with his
+name written upon it. The six thousand votes, necessary
+to procure his removal, or recall, having been
+polled, he departed from his beloved Athens, praying,
+with uplifted hands, that the Athenians might never
+have occasion to remember Aristeides.<a id="FNanchor_181" href="#Footnote_181" class="fnanchor">[23]</a></p>
+
+<p><span class="pagenum"><a id="Page_85"></a>[85]</span></p>
+
+<p>The ostracism of Aristeides did not last for the ten
+years, for which his punishment was decreed, under the
+Grecian law, however, for three years later, when the
+Persian king, Xerxes, invaded Greece, Aristeides returned
+and when the Persians were overcome he was
+completely reinstated in the good graces of his countrymen
+and took a leading part in the affairs of the government
+of Athens, without resentment, for he sought
+no other gratification than that of serving his country
+with fidelity and honour.</p>
+
+<p>Themistocles was another of the great citizen jurists
+of Athens to suffer the recall or ostracism, by popular
+vote, while this ancient law obtained in Greece.</p>
+
+<p>As an index to the character and uprightness of
+this distinguished Athenian, it is reported that before
+entering upon the trial of a cause in which the poet
+Simonides, of Ceos, was interested, when requested,
+by his friend, to overlook the underlying principles of
+the law, in the consideration of the cause, this virtuous
+judge replied:</p>
+
+<div class="blockquote">
+
+<p>“Simonides, you would be a bad poet, if your lines
+ran counter to the just measure and rules of your art,
+nor should I be a good magistrate, if, for favor, I made
+false law.”<a id="FNanchor_182" href="#Footnote_182" class="fnanchor">[24]</a></p>
+
+</div>
+
+<p>Notwithstanding the signal and loyal services of this
+patriotic citizen in the war with the Persians and his
+long service as a magistrate, when Themistocles finally
+erected his temple of Diana of Best Counsel, with
+himself represented by a figure in the temple, the
+Athenians also became envious of him and made use<span class="pagenum"><a id="Page_86"></a>[86]</span>
+of the law providing for the recall and ostracism in
+order to humble his eminence and authority, as they
+usually did with all those whom they believed to have
+grown too powerful, for the equality deemed requisite
+in a popular government, for, as said by Plutarch:</p>
+
+<div class="blockquote">
+
+<p>“The ostracism was instituted not so much to punish
+the offender, as to mitigate and pacify the violence
+of the envious, who delighted to humble eminent men,
+and who, by fixing this disgrace upon them, might vent
+some part of their rancor.”<a id="FNanchor_183" href="#Footnote_183" class="fnanchor">[25]</a></p>
+
+</div>
+
+<p>According to Aristotle, the law providing for the
+recall or ostracism of public officials, by popular vote,
+in Athens, soon became mischievous, for:</p>
+
+<div class="blockquote">
+
+<p>“Men did not look to the interests of the community,
+but used ostracism for party purposes.”<a id="FNanchor_184" href="#Footnote_184" class="fnanchor">[26]</a></p>
+
+</div>
+
+<p>The last person against whom this old law was enforced
+at Athens, was Hyperbolus, a demagogue of low
+birth and mean habits; the Athenians considered that
+in applying this law to such a person, their own dignity
+had been compromised, so the law providing for ostracism
+or recall, by popular vote, in Athens, was discontinued.<a id="FNanchor_185" href="#Footnote_185" class="fnanchor">[27]</a></p>
+
+<p>The law providing for the recall or ostracism of public
+officers, by popular vote, known as “Petalism”
+among the Syracusans, was borrowed from the Athenian
+law of ostracism. This species of recall, took its
+name from the petals or leaves of the olive, on which<span class="pagenum"><a id="Page_87"></a>[87]</span>
+was written the name of the person whom the citizens
+voted to recall.<a id="FNanchor_186" href="#Footnote_186" class="fnanchor">[28]</a></p>
+
+<p>Under the law of the Syracusans, known as “petalism,”
+the removed officer or judge was banished for a
+period of five years only, as this was considered a
+sufficient length of time to humble the pride and destroy
+the hope of the degraded one.</p>
+
+<p>Historians tell us, however, that this law of recall
+known as “petalism,” by which the Syracusans voted
+to recall their distinguished men, by writing their
+names upon the corolla, or leaf-part of the olive, did
+not long continue in effect, since the fear of this “degradation
+or humbling,” deterred the best qualified
+among the citizens from taking any part in public
+affairs, and the degeneracy and bad government which
+resulted from the selection of only the lowest types of
+demagogues for public officers, led to the repeal of the
+law, B. C. 452.<a id="FNanchor_187" href="#Footnote_187" class="fnanchor">[29]</a></p>
+
+<p>In the early Roman days the custom also obtained of
+submitting to the people, by popular vote, the determination
+of accusations against judges and other public
+officers, as matters of general public interest and the
+<i>judicia publica</i> of later times owed its existence to this
+antique custom. Preators, or those invested with judicial
+functions were no exception to the general rule,
+but all classes of public servants were directly responsible
+to the Roman people and were liable to be called
+upon, at any time, to answer to a charge which might
+mean banishment or death.</p>
+
+<p><span class="pagenum"><a id="Page_88"></a>[88]</span></p>
+
+<p>In the early days of the Republic, every act of a citizen
+which was deemed injurious to the State, or its
+peace, was called perduellio, and the offender (perduellis)
+was tried before the forum of public sentiment
+(<i>populi judicio</i>) and, if convicted of any violation of the
+obligations he owed to the State, he was put to death.<a id="FNanchor_188" href="#Footnote_188" class="fnanchor">[30]</a>
+The crime known as <i>Majestas</i>, corresponding to the
+English charge of treason, was apt, at any time to be
+preferred against the most upright public servant and
+the opinions of the populace were found frequently at
+variance with the justice of the cause. Justice was not
+always found to be consistent with the expressed will
+of the multitude of Roman citizenship, for their opinions
+were not always shaped or controled by the most
+exalted standards of equality. Unpopular officials were
+frequently condemned, regardless of the reason for the
+unpopularity, while the able orator or popular citizen,
+was usually successful in his cause.<a id="FNanchor_189" href="#Footnote_189" class="fnanchor">[31]</a></p>
+
+<p>Under the empire, judicial magistrates, such as Preators,
+were removed, at the will of the Emperor, and we
+find that while Julius Caesar had appointed sixteen, to
+settle the disputes of the Romans, Augustus peremptorily
+removed four and thus reduced the number to
+twelve.<a id="FNanchor_190" href="#Footnote_190" class="fnanchor">[32]</a></p>
+
+<p>The early Anglo-Saxons, like the Israelites of patriarchial
+days, while recognizing that the power of distributing
+or enforcing justice, was primarily lodged
+with the people, as a whole, constituting the great body
+of society, understood the impossibility of administering<span class="pagenum"><a id="Page_89"></a>[89]</span>
+justice, in the concrete, by delegating the performance
+of such important functions, without investigation
+or the understanding of correct ideals, to the great
+unskilled mass of the people, in their collective capacity,
+so apt to be carried away, in such matters, by variable
+sentiments, or whims or caprices, based upon impulses,
+not always consistent with the proper standards
+of right.</p>
+
+<p>In order to insure the rendition of justice to every
+individual, or to approximate as nearly as might be, to
+this object, this important power was committed, therefore,
+at a very early day, in England, to specially selected
+magistrates, possessing peculiar skill and fitness to
+hear and determine causes in courts of law and qualified,
+by study and training to discharge these difficult
+public functions with certainty and expedition, according
+to correct standards.</p>
+
+<p>Following the beneficent policy, illustrated by the
+old Mosaic code, of bringing justice home to every
+man’s door, as nearly as may he, it was the general
+plan of Anglo-Saxon society, as designed and shaped
+by the great King Alfred and other early kings, to have
+such a system of courts as would speedily dispense justice
+to all the people, under the various conditions of
+society. Anglo-Saxon courts did not have the means
+of compelling obedience to their mandates for the majesty
+of the law was not the rule implicitly followed
+by all classes, in the beginning, but before many centuries,
+following King Alfred’s time, we find that it had
+become the fixed rule of life.<a id="FNanchor_191" href="#Footnote_191" class="fnanchor">[33]</a></p>
+
+<p><span class="pagenum"><a id="Page_90"></a>[90]</span></p>
+
+<p>From the early <i>gemot</i>, of the Anglo-Saxon period,
+we soon find the regular county court and hundred
+court, where poor and rich alike were entitled to receive
+justice, without price and without delay.<a id="FNanchor_192" href="#Footnote_192" class="fnanchor">[34]</a> The
+expeditious court of <i>piepoudre</i>, (the dusty foot court)—which
+dispensed justice as speedily as dust falls from
+the foot<a id="FNanchor_193" href="#Footnote_193" class="fnanchor">[35]</a>—furnished speedy justice for small cases,
+while the <i>curia regis</i>, established by William the Conqueror,
+held in the royal palace, presided over by the
+king himself and his chief justiciar, with court barons,
+presided over by the lords of the realm, furnished, for
+many centuries a complete system of judiciture for the
+hearing of the ordinary causes in the realm.<a id="FNanchor_194" href="#Footnote_194" class="fnanchor">[36]</a> The
+King was the fountain of justice and it was his business
+to see justice done, where the litigant failed to get
+his cause heard in the jurisdiction of his own hundred.
+Of course as a natural result of such a policy, the right
+of dispensing justice and receiving the profits thereof,
+under the Normans, soon became hereditary rights,
+passing to successive lords, whose judgments were supreme,
+unless the King himself ordered the entering of
+a certain judgment.<a id="FNanchor_195" href="#Footnote_195" class="fnanchor">[37]</a> The Court of King’s Bench, the
+Court of Common Pleas and the High Court of Chancery,
+by gradual processes of time, succeeded to the
+principal places among the courts of later centuries,
+with the establishment by Henry II., A. D. 1176, of the<span class="pagenum"><a id="Page_91"></a>[91]</span>
+<i>justices itinerant</i>, who divided the realm into six circuits
+and afterwards followed a fixed judicial system.<a id="FNanchor_196" href="#Footnote_196" class="fnanchor">[38]</a></p>
+
+<p>From the reign of William the Conqueror, until that
+of King John, the administration of Justice was still
+kept in the hands of the king, who was regarded as the
+source of all justice and law; after the conquest, the
+various prerogatives of the crown were increased and
+it was during this precarious state of the law that the
+subjects were obliged to purchase the favor of the
+sovereign, in order to obtain justice in the king’s
+courts.<a id="FNanchor_197" href="#Footnote_197" class="fnanchor">[39]</a></p>
+
+<p>So dependent upon the will of the sovereign was the
+tenure of the judge, during the reign of Richard I., that
+we find William de Longchamp, chief justiciary and
+chancellor, was removed from his office, by the intrigue
+of John, Earl of Morton, the king’s brother.<a id="FNanchor_198" href="#Footnote_198" class="fnanchor">[40]</a></p>
+
+<p>Judges were then but the servants of the king and he
+could move them about as mere pawns upon the chess
+board of his own expediency, or dismiss them, at a
+moment’s notice, if they refused to do his bidding.<a id="FNanchor_199" href="#Footnote_199" class="fnanchor">[41]</a><span class="pagenum"><a id="Page_92"></a>[92]</span>
+Hubert de Burgh succeeded Hubert Walter and Geoffry
+Fitz Peter, as Chief Justiciar, but he seldom sat on the
+bench and was removed in 1232,<a id="FNanchor_200" href="#Footnote_200" class="fnanchor">[42]</a> when the Chief
+Justiciarship was committed to a lawyer, named
+Stephen Segrave. The latter was disgraced and dismissed
+by the King, in 1234, just two years after his
+appointment and from this period until 1258, or until
+the revolution, the justiciarship was in abeyance.<a id="FNanchor_201" href="#Footnote_201" class="fnanchor">[43]</a></p>
+
+<p>In lieu of an appeal, or writ of error, which challenged
+the sufficiency or correctness of a record or
+judgment, instead of the judge himself, we find that
+from the time of Cnut, until the reign of Henry I., if a
+judgment was challenged the proceeding was what was
+known as that of “false judgment,” growing out of the
+practice of early Saxon days, when a litigant who was
+dissatisfied with a decision or “doom,” charged the
+doomsman who uttered it with falsehood.<a id="FNanchor_202" href="#Footnote_202" class="fnanchor">[44]</a></p>
+
+<p>Until the thirteenth century the exception to a given
+judgment or decree of an inferior court was tested by
+the charge of “false judgment.” The record was
+transferred from the inferior tribunal to the superior
+one by certain knights, appointed for the purpose.
+Frequently, these knights would challenge the litigant
+questioning the correctness of the judgment to trial by
+battle, to test the correctness of the decree<a id="FNanchor_203" href="#Footnote_203" class="fnanchor">[45]</a> but if this
+were not done, and the issue upon the legality of the
+finding of the lower court thus determined, the justices
+of the king’s court proceeded to examine the record.</p>
+
+<p><span class="pagenum"><a id="Page_93"></a>[93]</span></p>
+
+<p>If the King’s Justices found, on an examination of
+the record that the judgment of the county, the hundred
+or the manor, were wrong, a fine was assessed
+against the judge rendering the erroneous judgment
+and by a finding of “false judgment” a Lord lost
+forever the right to hold a court.<a id="FNanchor_204" href="#Footnote_204" class="fnanchor">[46]</a></p>
+
+<p>Here was a method of recall, almost as bad as that
+existing under the Babylonian Empire, for instead of
+removing the judge who attempted to right a wrong, he
+was removed before having been given the opportunity
+to get right.</p>
+
+<p>As late as the year 1219 we find that the justices in
+eyre were brought before the justices of the Court of
+King’s Bench, upon a charge of “false judgment,” for
+having unlawfully condemned a man to death and upon
+examination of the record by the Council, their judgment
+was set aside and they were amerced with a fine
+for having entered such a “false judgment.”<a id="FNanchor_205" href="#Footnote_205" class="fnanchor">[47]</a></p>
+
+<p>It is little wonder, with this harsh rule obtaining,
+that by the time of Edward I. history records that his
+justices had become extremely cautious men, unwilling
+to decide nice points of law but referring every close
+question to the Council for instruction.<a id="FNanchor_206" href="#Footnote_206" class="fnanchor">[48]</a> The penalty
+of a mistake or “false judgment” to them meant not
+only a fine, but disgrace and the recall, if the King saw
+fit to so punish them, so this was not only calculated to<span class="pagenum"><a id="Page_94"></a>[94]</span>
+make a man cautions, but to prevent those of skill and
+dignity from risking the expression of their judgment,
+when the penalty for a mistake was such that it might
+forever ruin the future life and hopes of the judge
+pronouncing judgment. The strange thing is that with
+such a system, any self respecting man could be found
+to undertake the performance of functions such as
+those required of a judge, when his behavior was the
+means of ruining his future life, regardless of his pure
+intentions in the performance of his official duty.</p>
+
+<p>The tenure of office of the English judge continued
+for centuries, to be at the pleasure of the Crown, and
+under the Plantagenets and the Tudors, a Chief-Justice
+even, might be removed, like any other officer of the
+King, at the pleasure of the sovereign,<a id="FNanchor_207" href="#Footnote_207" class="fnanchor">[49]</a> and during
+this whole period we find that the standards of the
+judiciary were in keeping with this servile and undignified
+conception of the duties of such an office, for the
+judges, with but few exceptions, during this period of
+servile attachment to the Crown, were men of but
+mediocre ability, willing to prostitute their high offices,
+to hold the esteem and favor of their patron.</p>
+
+<p>It was thus found, by experience, in England, that
+the proper discharge of the impartial duties of the
+courts was consistent only with the maintenance, at all
+times, of their dignity and independence, hence, it was
+enacted, by statute, (13 William III., c. 2) that the
+commissions of judges were to be held, not as formerly,
+during the mere pleasure of the king, but so long as
+they should conduct themselves uprightly. They can
+only be removed from office, upon the address of both<span class="pagenum"><a id="Page_95"></a>[95]</span>
+houses of Parliament and since the reign of George III.,
+the commissions of judges are not terminated with the
+death of the king, but they continue to hold their office,
+notwithstanding the demise of the king, during their
+good behavior, or until removed by the joint action of
+both houses of Parliament.<a id="FNanchor_208" href="#Footnote_208" class="fnanchor">[50]</a></p>
+
+<p>And not only did the English law raise the incumbent
+of the judgment seat to a plane where he could view,
+with disdain the frowns of the tyrant in the performance
+of his official functions, but that he might also be free
+from the clamors of the populace, he was exempt from
+indictment for any judicial act honestly done, or
+omitted, while sitting as a judge. In other words, while
+acting in a judicial capacity, judges were not liable for
+an honest mistake, but only for fraud or corruption.<a id="FNanchor_209" href="#Footnote_209" class="fnanchor">[51]</a></p>
+
+<p>The judge is criminally and civilly liable, by the
+English common law for judicial acts willfully and maliciously
+done; for acts clearly in excess of his proper
+jurisdiction and for the wrongful exercise of a mere
+ministerial act, whether honestly done or not,<a id="FNanchor_210" href="#Footnote_210" class="fnanchor">[52]</a> but this
+was the full limit of his liability and for honest mistakes
+in the performance of his duty, he was responsible
+to no one and could be troubled only by an accusing<span class="pagenum"><a id="Page_96"></a>[96]</span>
+conscience for a mistake in the performance of a proper
+judicial function.</p>
+
+<p>Since the placing of the English judiciary upon this
+high plane where the courts are wholly above and beyond
+the spoils of party or the favoritism or fears of
+sovereignty, the respect paid to the majesty of the law
+in that country, has challenged the admiration of the
+world. English procedure is the pattern for the best
+governed countries on the earth and the decisions of
+her courts have come to be ideals to be followed by
+courts of other nations, seeking the attainment of
+justice.</p>
+
+<p>The patriot fathers, familiar with the mistakes of the
+ancients and the reasons for the establishment of the
+judicature of England, upon an independent foundation,
+in the establishment of the judicial system in the
+United States, adopted the method that history had
+commended to England, of life tenure, with the power
+of removal for actual misfeasance in office.</p>
+
+<p>It was therefore provided in the Federal Constitution
+that judges of the courts of the United States
+should hold their offices during good behavior and
+they were subject to removal, only by impeachment,
+like other civil officers of the Government.<a id="FNanchor_211" href="#Footnote_211" class="fnanchor">[53]</a></p>
+
+<p>The first Congress, in 1789, enacted the first federal
+judiciary act, formulated by Oliver Ellsworth, a
+member of the convention which framed the Constitution
+and afterwards Chief Justice of the Supreme
+Court.</p>
+
+<p>Speaking of this earnest patriot, Mr. Webster said
+that he was “possessed of the clearest intelligence and<span class="pagenum"><a id="Page_97"></a>[97]</span>
+deepest sagacity as well as the utmost purity and integrity
+of character.”</p>
+
+<p>Upon the relative functions of the different branches
+of government and the necessity for an independent
+judiciary, Chief Justice Ellsworth said:</p>
+
+<div class="blockquote">
+
+<p>“If the general legislature should, at any time, overleap
+their limits, the judicial department is a constitutional
+check. If the United States go beyond their
+powers; if they make a law, which the Constitution does
+not authorize, it is void; and the judiciary power, the
+national judges, who, to secure their impartiality, <i>are
+to be made independent</i>, will declare it to be void. On
+the other hand, if the States go beyond their limits, if
+they make a law which is a usurpation upon the general
+Government, the law is void, and upright, <i>independent
+judges</i> will declare it to be so.”</p>
+
+</div>
+
+<p>This, by the gentleman who reported the bill in Congress
+for the organization of the judicial department
+of the general Government, demonstrates that those
+who formed our Government and framed our Constitution,
+realized not only that the judgment seat should be
+dominated by “the cold neutrality of an impartial
+judge,” but that this essential prerequisite to the administration
+of justice, could not be obtained by a
+cringing judiciary, depending upon a vacillating public
+sentiment, as an index to its opinions, but would be
+effectuated only through the untrammeled judgment of
+an independent court.</p>
+
+<p>Next to Oliver Ellsworth, the man most active in the
+establishment of our Federal Judiciary, was perhaps
+Alexander Hamilton, and upon the reasons for an absolutely
+independent judiciary, this great lawyer,
+soldier and patriotic statesman, observed:</p>
+
+<div class="blockquote">
+
+<p>“This independence of the judges is equally requisite
+to guard the Constitution and the rights of individuals
+from the effects of those ill-humors which the arts of<span class="pagenum"><a id="Page_98"></a>[98]</span>
+designing men or the influence of particular conjunctures
+sometimes disseminate among the people themselves
+and which, though they speedily give place to
+better information, and more deliberate reflection, have
+a tendency, in the meantime, to occasion dangerous innovations
+in the Government and serious oppressions
+of the minor party in the community.”<a id="FNanchor_212" href="#Footnote_212" class="fnanchor">[54]</a></p>
+
+</div>
+
+<p>It was also clearly the object of the original thirteen
+colonies to remove the judiciary from politics and
+thereby establish the independence of the State Judiciary,
+as well as that of the Federal Government, for
+the Constitutions of each of the original colonies provided
+for an appointive judiciary.<a id="FNanchor_213" href="#Footnote_213" class="fnanchor">[55]</a> Georgia alone set
+the bad example of providing for an elective judiciary,
+by direct vote of the people, for a short term, a practice
+that historians believe has caused much of the degradation
+and humiliation of the state courts, in the past
+century.<a id="FNanchor_214" href="#Footnote_214" class="fnanchor">[56]</a></p>
+
+<p>In most of the other states in the United States, the
+medium was selected, between the life tenure and the
+complete independence of the judiciary upon the one<span class="pagenum"><a id="Page_99"></a>[99]</span>
+hand, and the recall and disgrace of the judge, without
+the formality of a trial, upon the other, and it was provided
+for the election of judges, for short terms of
+office, subject to impeachment by the legislative branch
+of Government, in cases of misfeasance in office.<a id="FNanchor_215" href="#Footnote_215" class="fnanchor">[57]</a></p>
+
+<p>In one state alone was the English method adopted
+of appointing the judges for life, or during good behavior,
+although four other states have the appointive
+judiciary, and it is not strange that in this one state
+we find the strongest state court in the United States
+and the one whose judgments are received by the various
+courts of the other states with the highest degree
+of respect.<a id="FNanchor_216" href="#Footnote_216" class="fnanchor">[58]</a></p>
+
+<p>By both the Federal and State Constitutions, in the
+United States, the judiciary has always been regarded
+as an equal and co-ordinate branch of government, with
+the legislative and executive. It was accordingly held,
+within the past century, that neither the President nor
+the Governor could remove a judge, during the term
+of office for which he was elected or appointed,<a id="FNanchor_217" href="#Footnote_217" class="fnanchor">[59]</a> but the
+only way to remove or recall a judge, was by impeachment
+for criminal or corrupt conduct.<a id="FNanchor_218" href="#Footnote_218" class="fnanchor">[60]</a></p>
+
+<p>It is thus a serious question whether the experience
+of the past century, in the United States, has vindicated
+the method followed in so many states, of selecting<span class="pagenum"><a id="Page_100"></a>[100]</span>
+judges, for a moderate term, by an elective system,
+subject to impeachment for positive misfeasance in
+office. Many protests, other than the growing demand
+for a popular recall of judges, may be directly or indirectly
+traced to this method of selecting judges and
+as the demands and protests come from states where
+the tenure to office is for the shorter terms, it seems
+that this general policy, when applied to the judiciary,
+is condemned both by the examples of history and the
+practice and experience of the past century, in the
+United States.</p>
+
+<p>There is little doubt but that the great Chief Justice
+Marshall would have been recalled, after his decision
+against the Government, in the trial of Aaron Burr, for
+treason, if the recall of judges by popular vote had then
+obtained, in the United States. The power of Jefferson’s
+administration was used, unsparingly, to obtain
+Burr’s conviction, and he was already convicted in the
+forum of public sentiment, for the populace believed
+him guilty. The Chief Justice, however, firm in the
+consciousness of right, with the true judicial poise, disdained,
+with equanimity, the clamor of the populace
+and refused to sacrifice the individual, to appease the
+public wrath.<a id="FNanchor_219" href="#Footnote_219" class="fnanchor">[61]</a> No wonder that through the genius of
+this patriot, the Court he presided over was “placed
+upon a pedestal of imperishable granite and has become
+the admiration of the publicists throughout the
+civilized world.”<a id="FNanchor_220" href="#Footnote_220" class="fnanchor">[62]</a></p>
+
+<p><span class="pagenum"><a id="Page_101"></a>[101]</span></p>
+
+<p>If such a system had then obtained, the country
+would have been denied the genius and ability of this
+just man, for he would never have been responsible to
+the fickle flames of a vacillating public sentiment for the
+correctness of his opinions. Addressing himself upon
+the necessity for an absolutely independent judiciary,
+Chief Justice Marshall said:</p>
+
+<div class="blockquote">
+
+<p>“It is to the last degree important that he should be
+rendered perfectly and completely independent with
+nothing to control him but God and his conscience.”</p>
+
+</div>
+
+<p>Strange, is it not, that the opinions of our patriot
+fathers should so nearly approach the views of the
+patriarchs of the Mosaic period, upon the qualifications
+of the judge, for they too, believed that the courts
+should be presided over by “able men out of Israel,
+such as feared God, men of truth, hating covetousness”
+and when appointed to judge between the alleged rights
+of the ancient Hebrews, they were admonished by the
+Great Law Giver: “Ye shall not be afraid of the face
+of man, for the judgment is God’s.”<a id="FNanchor_221" href="#Footnote_221" class="fnanchor">[63]</a></p>
+
+<p>Right well did Moses warn the ancient judges of the
+Israelites against the fear of men in the prerogative of
+the judgment seat, for public sentiment has ever proven
+variable and the proper and just ideals do not always
+govern the multitude. We have seen them to-day cry
+“Hosanna” and to-morrow “Crucify Him.” And since<span class="pagenum"><a id="Page_102"></a>[102]</span>
+the day when Pilate released Barabas and delivered
+the Nazarene to the multitude, because it was popular
+for him to do so, the judge who feared “the face of
+man” has been deemed unworthy of the trust and dignity
+of the judgment seat.</p>
+
+<p>The millions burned at the stake, during the witchcraft
+craze, in Europe, were convicted before judges
+whose independence had not been established by the
+laws of the realm and they simply followed the expressed
+will of the multitude in the act of pronouncing
+judgment.<a id="FNanchor_222" href="#Footnote_222" class="fnanchor">[64]</a></p>
+
+<p>In our own country, during the spread of this delusion,
+in Salem, Massachusetts, before the courts were
+presided over by judges appointed for life, there were
+nineteen innocent persons burned or hanged for witchcraft
+in less than one year, and of these fourteen were
+women.<a id="FNanchor_223" href="#Footnote_223" class="fnanchor">[65]</a></p>
+
+<p>In the case of the gentle Rebecca Nurse, hanged on
+Gallows Hill, on July 19, 1692, after her acquittal by a
+jury, because the people demanded her blood, and a
+subservient judiciary bowed in humble submission to
+the <i>vox populi</i>, we find one of the most unjust instances
+of the “recall of judicial decisions” in the history of
+any country and one of the grossest travesties upon
+justice that has been produced.<a id="FNanchor_224" href="#Footnote_224" class="fnanchor">[66]</a></p>
+
+<p>The fear of the recall of judges, in France, during
+the provisional Republic, following the French Revolution,
+caused the judges to send a poor weak woman to<span class="pagenum"><a id="Page_103"></a>[103]</span>
+the guillotine, because she possessed the foibles of her
+sex and the flower of the aristocracy of the country
+was sent innocent to their death, because a wrought
+up multitude demanded their slaughter. Oh, for the
+glory of an independent judiciary, in such a crisis and
+what a valuable lesson history affords against the precedents
+made by public sentiment.</p>
+
+<p>The courts alone protect the rights of the minority,
+for the legislative and executive are subservient to the
+expressed will of the majority. In the courts, however,
+the property of the rich and the poor alike is protected
+from the might of the powerful and the will of the
+majority, because the law of the land, in recognition of
+the right of the minority to enjoy life, liberty and property,
+in this free land of ours, has provided that no
+property can be taken, however popular it might be to
+appropriate it, without just compensation, after a trial,
+upon due process. But when the judges were but the
+servants of the majority, of course the wishes of the
+majority controlled them, hence the necessity of making
+them independent of both the majority and minority.</p>
+
+<p>We have seen how the recall of judges by popular
+vote, in Babylon and Greece weakened and destroyed
+their independence and made them subservient tools of
+the popular and great leaders of the majority; that in
+time the respect of the community for the judges so
+situated was completely destroyed and that the fear of
+humiliation and disgrace prevented gentleman of dignity
+and ability from seeking such a precarious place
+and the whole judicial system was thereby perverted
+and deranged.</p>
+
+<p><span class="pagenum"><a id="Page_104"></a>[104]</span></p>
+
+<p>Commenting upon the condition which the recall of
+judges by popular vote brought about in Greece, we
+have the valuable testimony of Aristotle who said:<a id="FNanchor_225" href="#Footnote_225" class="fnanchor">[67]</a></p>
+
+<div class="blockquote">
+
+<p>“Those who have any complaints to bring against
+the magistrates say: ‘<i>Let the people be judges</i>’; the
+people are too happy to accept the invitation and so the
+authority of every office is undermined. Such a democracy
+is fairly open to the objection that it is not a
+constitution at all, for where the laws have no authority
+there is no constitution.”</p>
+
+</div>
+
+<p>The framers of our constitution were familiar with
+the experiments of ancient Greece and the mistakes of
+the early Anglo-Saxons, and this is why the Constitution
+guarantees to “every state in the union a Republican
+form of government.”<a id="FNanchor_226" href="#Footnote_226" class="fnanchor">[68]</a></p>
+
+<p>Shall the illuminating precedents of history, ever be
+forgotten; shall the land-marks of the fathers and the
+light-houses, planted upon the shoals upon which other
+ships of state have floundered, be torn away? Are the
+secrets of the old dooms day books of the Anglo-Saxons,
+to be read in vain and the mistakes of the law of ostracism
+of the Athenians and the discarded and condemned
+law of petalism, of the Syracusans, to be
+adopted in the United States, in the twentieth century?<a id="FNanchor_227" href="#Footnote_227" class="fnanchor">[69]</a></p>
+
+<p>If the day shall ever come, in the United States, when<span class="pagenum"><a id="Page_105"></a>[105]</span>
+this mistaken custom of the Babylonians and the ancient
+Athenians shall be generally established, and the
+disappointed suitor and political demagogue can
+gather his associates and bid the judge come down
+from his judgment seat to answer the excited multitude
+for the correctness of his judgments, then the safeguards
+of the Constitution, guaranteed to us by the
+patriot fathers will be trampled under foot; this will
+cease to be a Government of law and become a mere
+aggregation of people, where law is not the rule of
+life.<a id="FNanchor_228" href="#Footnote_228" class="fnanchor">[70]</a></p>
+
+<p>The statesmen of ancient Greece found that the judge
+could not be safely tried by political methods, for the
+elements of personal ambition, favoritism, money interest,
+envy and divers other equations, were likely to
+be used in passing upon the qualifications of the judge,
+when arraigned before the forum of a wrought up
+public sentiment. Nor would it be different in any
+other country, under similar conditions.</p>
+
+<p>In the days of Hammurabi, when the courts were so
+much concerned about the trials of those supposed to
+“weave spells over a man” and his guilt or innocence
+was determined by his survival of the torrent of the
+“holy river;” when the standards of justice were such
+that the surgeon, who was unsuccessful in an operation,
+lost his hands; when the veterinarian paid for all the
+stock he could not cure; the builder, or artisan, all
+damages resulting from a house he had built afterwards<span class="pagenum"><a id="Page_106"></a>[106]</span>
+falling down. When, in all the relations of life—save
+that of the royal prerogatives—the test of human
+action was the exalted ideal of infallibility, then the
+judge who set aside a judgment was humiliated and disgraced
+and peremptorily removed from office. All
+morality was on a par with such ideals of the exalted
+virtues like justice, and brides were auctioned off by
+their fathers to the highest bidder and all human action
+was in keeping with such dark days of superstition
+and delusion.</p>
+
+<p>The behavior of the judge of the time of Cnut, in
+England, when he was liable to be fined and removed
+for entering “a false judgment,” was in strict accord
+with the low standards of justice then obtaining and
+from this degraded position of the judiciary, to that of
+the exalted notion of an absolutely independent judiciary,
+there was the same difference in the quality of
+justice administered, that obtained between the generally
+ignorant men selected to parcel out the right, for
+remuneration, in those dark days and the pure and
+scholarly jurists, who, for centuries have made the administration
+of the law, in England, the admiration of
+the civilized world. The history of the judiciary, in
+England, has certainly demonstrated the wisdom of an
+independent judiciary, for no country pays the same
+high regard to the majesty of the law and in none are
+the correct ideals in legal standards more nearly approximated,
+than in England.<a id="FNanchor_229" href="#Footnote_229" class="fnanchor">[71]</a></p>
+
+<p><span class="pagenum"><a id="Page_107"></a>[107]</span></p>
+
+<p>One does not have to become an Anglo-Maniac to
+feel a just pride in the stability and perfection of an
+institution, such as the English judiciary, for all who
+make law a rule of life, can but revere the approximation
+of an ideal where its reign is supreme.</p>
+
+<p>In the consideration of this antiquated and condemned
+institution, known as “Judicial Recall,” space
+has forbidden that we should do more than merely
+touch upon the centuries as mile-stones, in hurrying
+through the ages. From the facts of history presented,
+however, it seems strange that in the evolution of the
+race, amid the cultivated ideals of our twentieth century
+civilization, so many of our states would seemingly refuse
+to profit by the mistakes in the Leges Barbarorum
+of the dark ages; that they would apparently turn aside
+from the sad picture of the early struggle for law
+and—defying the axiom that we can but “judge the
+future by the past of man”—indulge the vain hope of
+utilizing the popular recall of judges as a panacea for
+all the social evils of modern times.</p>
+
+<p>The patriot fathers, profiting by the accumulated
+wisdom of the past, builded an edifice in this free land
+of ours, bottomed upon the solid foundation of constitutional
+principles, sufficiently enduring to withstand the
+most tempestuous seas of partisan politics, because
+they profited by the record which history recorded of
+the stranded wrecks of states upon the shores of time.<span class="pagenum"><a id="Page_108"></a>[108]</span>
+Our fathers and their children have occupied this temple
+for over a century and we should have a care how
+we undermine the walls or remove the high priest of
+our liberties, with rough hands, from the sacred altar.
+Many a hearth-stone in this and future ages will need
+the protection guaranteed by the fundamental principle
+of government, which perpetuates the independence
+of the judicial department and the statesmen of the
+present age, without thinking of the permanence of
+their work, are making right and wrong for succeeding
+ages and by tampering with the institutions that time
+has approved, they may incur the everlasting condemnation
+of the citizens of succeeding commonwealths.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_159" href="#FNanchor_159" class="label">[1]</a> Speaking upon the antiquity of courts and judges, John, in
+his “Babylonian and Assyrian Laws,” says: “Partly because specific
+reference to judges and legal processes are not necessarily to be expected
+in historical inscriptions, and partly because we do not really
+know which are the earliest monuments of the human race, it is
+impossible to decide when law-courts first came into existence. It
+is generally admitted, however, that the stele of Manistusu is one
+of the earliest known monuments. There we read of Galzu, a
+judge. There also we find many of the officials, who later acted as
+judges upon occasion. Hence it may fairly be said that judges
+were to be found in ancient Babylonia from time immemorial. They
+must have decided what was right when there was no written law
+to which to appeal.”</p>
+
+<p>“Babylonian and Assyrian Laws,” c. v. p. 80.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_160" href="#FNanchor_160" class="label">[2]</a> Exodus, c. 18, 26.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_161" href="#FNanchor_161" class="label">[3]</a> Exodus, c. 23-2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_162" href="#FNanchor_162" class="label">[4]</a> Deuteronomy, 1-17.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_163" href="#FNanchor_163" class="label">[5]</a> Deuteronomy, 17-9, 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_164" href="#FNanchor_164" class="label">[6]</a> John’s “The Oldest Code of Laws in the World.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_165" href="#FNanchor_165" class="label">[7]</a> New York Independent, Vol. 55, pt. 1,—January-March, 1903—p.
+67; John’s “Babylonian and Assyrian Laws.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_166" href="#FNanchor_166" class="label">[8]</a> John’s “The Oldest Code of Laws in the World,” p. 2; Code of
+Hammurabi, sec. 5; John’s “Babylonian and Assyrian Laws,” p. 44.</p>
+
+<p>A notable case of the recall of judges as late as five hundred
+years before Christ occurred among the Medes and Persians, who
+boasted of their unalterable decrees, once rendered by the incumbent
+of the <i>dangerous</i> judgment-seat.</p>
+
+<p>Herodotus tells the thrilling story of the striking example furnished
+by King Cambyses, in his final recall of the unjust judge,
+named Sisamnes. He caused him to be killed and flayed and the
+judgment-seat to be covered with his skin. He then appointed the
+son of Sisamnes to be his successor, but charged him, while sitting
+in judgment, to remember the fate of his father. This example
+might be resorted to by the agitators for the judicial recall, as a
+more terrible example to an unjust judge than the mere recall and
+degradation.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_167" href="#FNanchor_167" class="label">[9]</a> John’s “Babylonian and Assyrian Laws,” p. 82. Whether the
+reversal of an erroneous judgment was provided for by appeal,
+does not appear, from the Code.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_168" href="#FNanchor_168" class="label">[10]</a> John’s “Babylonian and Assyrian Laws,” p. 90.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_169" href="#FNanchor_169" class="label">[11]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_170" href="#FNanchor_170" class="label">[12]</a> <i>Ante idem.</i> p. 92.</p>
+
+<p>“Shamash-bel-ili sues Nidnusha concerning a house bought by
+him of her. The judges grant him two sheckels of silver. Hammurabi
+I.”</p>
+
+<p>“Shi-lamazi sues her brothers for a field and wins her case.”</p>
+
+<p>“Zariku was put to the oath and replied to Erib-Sin. He was
+told that as his domicile was at Sippara, he must not make his
+appeal to the judges of Babylon, so his case was dismissed. Hammurabi
+28.” This was a case of the wrong venue and hence, a lack
+of jurisdiction over the subject-matter.</p>
+
+<p>“Ilushu-abushu hired a pack-ass, of Ardi-Sin and Silli-Ishtar and
+lost it. The judges awarded them sixteen sheckels of silver as compensation.
+Apel-Sin. 5.”</p>
+
+<p>“Mar-ersitim left a female slave, Damiktum, to Erib-Sin. His
+wife and brother disputed the legacy. The judges inspected a document
+by which Erib-Sin had granted the slave to his wife, so they
+return her to the wife. Hammurabi.”</p>
+
+<p>“A slave, Bariki-ilu, was pledged for twenty-eight sheckels to
+Ahinuri, in the thirty-fifth year of Nebuchadnezzar. In the next
+year we find him in possession of Piru, his wife, Gaga, and a cousin,
+Zirra. They sold him for twenty-three sheckels to Nabu-Zer-ukin. He
+must have fled from his new master, for four years later the same
+people pledged him. He was not a satisfactory pledge, for next
+we find that Gaga’s daughter, about to be married, this slave was
+set down as a part of her marriage portion, and she gave him to her
+husband and his son, and he remained in their possession, but
+when his mistress died, he was handed over to the great banker,
+Itti-Marduk-balatu. During the reign of Nabonidus, the slave, Bariki-ilu,
+attempted to establish his freedom, by pretending to be the
+adopted son of Bal-rim-ani, but was made to confess that he had
+twice run away from his master and had been many days in hiding,
+so it was adjudged that he must return to servitude.” John’s “Babylonian
+and Assyrian Laws,” p. 181.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_171" href="#FNanchor_171" class="label">[13]</a> Code Hammurabi, Sec. 215; John’s “Babylonian Laws,” p. 63.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_172" href="#FNanchor_172" class="label">[14]</a> <i>Ante idem.</i> Sec. 225; John’s “Babylonian Laws,” p. 63.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_173" href="#FNanchor_173" class="label">[15]</a> <i>Ante idem.</i> Sec. 229; John’s “Babylonian Laws,” p. 64.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_174" href="#FNanchor_174" class="label">[16]</a> Diod. Sic. xl, 55; Aelian, V. H. xiii, 23; Smith’s Greek and
+Roman Antiquities.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_175" href="#FNanchor_175" class="label">[17]</a> Polio, iii, 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_176" href="#FNanchor_176" class="label">[18]</a> Smith’s Dictionary of Greek and Roman Antiquities, <i>sub nom.</i>
+<i>Banishment</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_177" href="#FNanchor_177" class="label">[19]</a> Schol. in Aristotle, Equit. 865; Smith’s Greek and Roman Antiq.
+<i>supra</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_178" href="#FNanchor_178" class="label">[20]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_179" href="#FNanchor_179" class="label">[21]</a> Plutarch’s Lives.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_180" href="#FNanchor_180" class="label">[22]</a> Plutarch’s Lives.</p>
+
+<p>Aristeides, from the history of the man, as given us by Plutarch
+was to be classed with that altruistic lot of patriots:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Who cared not to be great</div>
+ <div class="verse indent0">But as they serve or save the State.”</div>
+ </div>
+</div>
+</div>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_181" href="#FNanchor_181" class="label">[23]</a> Plutarch’s Lives.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_182" href="#FNanchor_182" class="label">[24]</a> Plutarch’s Lives.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_183" href="#FNanchor_183" class="label">[25]</a> Plutarch’s Life of Themistocles.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_184" href="#FNanchor_184" class="label">[26]</a> Aristotle, c. 7, p. 135; Smith’s Dictionary of Greek and Roman
+Antiquities.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_185" href="#FNanchor_185" class="label">[27]</a> Plutarch’s Life of Aristeides; Smith’s Dictionary of Greek and
+Roman Antiquities.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_186" href="#FNanchor_186" class="label">[28]</a> Smith’s Dictionary of Greek and Roman Antiquities.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_187" href="#FNanchor_187" class="label">[29]</a> Niebuhr, “History Rome,” i, 504; Diod. Soc. xl, c. 87; Smith’s
+Dictionary of Greek and Roman Antiquities.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_188" href="#FNanchor_188" class="label">[30]</a> Livy, ii, 41; <i>idem.</i>, vi, 20.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_189" href="#FNanchor_189" class="label">[31]</a> Gaius, i, 2; <i>idem.</i>, 20; Tacitus, History, i, 84.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_190" href="#FNanchor_190" class="label">[32]</a> Niebuhr, History Rome; Livy, Sallust, Tacitus, Arnold, Gibbon.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_191" href="#FNanchor_191" class="label">[33]</a> I. Pollock and Maitland History English Law, p. 37.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_192" href="#FNanchor_192" class="label">[34]</a> <i>Ante idem.</i>, p. 42.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_193" href="#FNanchor_193" class="label">[35]</a> Coke, 4 Inst. 272.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_194" href="#FNanchor_194" class="label">[36]</a> I. Reeve’s History English Law, 264; I. Pollock and Maitland’s
+History English Law, 40, 45.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_195" href="#FNanchor_195" class="label">[37]</a> I. Pollock and Maitland’s History English Law, pp. 72, 73;
+Memoirs de la Societe des antiquaires de Normandie, vol. xv, pp.
+196-197.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_196" href="#FNanchor_196" class="label">[38]</a> I. Reeve’s History English Law, 273.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_197" href="#FNanchor_197" class="label">[39]</a> I. Reeve’s History English Law, pp. 283, 465, 466.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_198" href="#FNanchor_198" class="label">[40]</a> I. Reeve’s History English Law, 280.</p>
+
+<p>The conditions existing before the Barons exacted from King
+John the various guaranties of the Great Charter are known to all
+readers of English History. The reasons why they stipulated that
+“Right shall not be sold, delayed or denied”; that the king should
+only appoint “justiciaries, sheriffs and bailiffs, of such as know the
+law of the land and are disposed duly to observe it” is emphasized
+by a consideration of the many highhanded proceedings that the
+people of that long suffering country had been subjected to before
+this Great Charter of liberty was exacted from King John. (I.
+Reeve’s History English Law, 471, 472.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_199" href="#FNanchor_199" class="label">[41]</a> I. Pollock and Maitland’s History English Law, p. 204.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_200" href="#FNanchor_200" class="label">[42]</a> <i>Ante idem.</i> p. 204.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_201" href="#FNanchor_201" class="label">[43]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_202" href="#FNanchor_202" class="label">[44]</a> Cnut, ii, 15, sec. 2; Edgar 1, 3; Brunner, D. R. G. ii, 356, 365;
+II. Pollock and Maitland’s History English Law, 666.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_203" href="#FNanchor_203" class="label">[45]</a> II. Pollock and Maitland’s History English Law, 667.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_204" href="#FNanchor_204" class="label">[46]</a> Note Book, Pl. 1412; Glanvill, viii, 9; Edgar, iii, 3; Cnut, ii, 15;
+Leg. Will. I., 39, sec. 1, II. Pollock and Maitland’s History English
+Law, p. 667.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_205" href="#FNanchor_205" class="label">[47]</a> Note Book, Pl. 67; Note Book, Pl. 1166; II. Pollock and Maitland’s
+History English Law, p. 668.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_206" href="#FNanchor_206" class="label">[48]</a> II. Pollock and Maitland’s History English Law, p. 672; Bracton,
+f. 186.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_207" href="#FNanchor_207" class="label">[49]</a> Verplanck.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_208" href="#FNanchor_208" class="label">[50]</a> I. George III., c. 23.</p>
+
+<p>It has long been axiomatic, in England, that the Crown even,
+cannot interfere with the disinterested performance of its powers,
+by the judiciary. 2 Hawk. P. C. 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_209" href="#FNanchor_209" class="label">[51]</a> Yates vs. Lansing (N. Y.), 5 Johns xx. 282; Hamilton vs.
+Williams, 26 Ala. 527.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_210" href="#FNanchor_210" class="label">[52]</a> State vs. Graves, 8 Mo. 148; 40 Am. Dec. 131; Stone vs. Augusta,
+46 Me. 127; Revill vs. Pettit, 60 Ky. 314; Reed vs. Conway, 20
+Mo. 22; Gault vs. Wallace, 53 Ga. 675; Cope vs. Rainey, 49 Tenn.
+(2 Heisk.) 197.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_211" href="#FNanchor_211" class="label">[53]</a> U. S. Con. Art. III., sec. 1.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_212" href="#FNanchor_212" class="label">[54]</a> See Paper “The Judiciary and Public Sentiment,” read before
+Mo. Bar. Assn. at St. Joseph, Mo., September, 1906, Proc. 24’ Annual
+Meeting of Association.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_213" href="#FNanchor_213" class="label">[55]</a> See interesting article on “Recall of Judges,” by Albert Fink,
+in North American Review, vol. 193, p. 680.</p>
+
+<p>The Massachusetts Bill of Rights, adopted in 1780 declares:</p>
+
+<p>“It is the right of every citizen to be tried by judges as free,
+impartial and independent as the lot of humanity will admit.”
+Would that more of the States had followed this lead of the Great
+Commonwealth of Massachusetts.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_214" href="#FNanchor_214" class="label">[56]</a> Upon this subject, Dr. Fiske observed: “It was Georgia that,
+in 1812, set the bad example of electing judges for short terms by
+the people, a practice which is responsible for much of the degradation
+that courts have suffered in many of our states and which
+will have to be abandoned before a proper administration of justice
+can ever be secured.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_215" href="#FNanchor_215" class="label">[57]</a> Thorpe’s American Charters, Constitutions and Organic Laws.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_216" href="#FNanchor_216" class="label">[58]</a> Massachusetts and New Hampshire judges are appointed and
+hold during good behavior, but in New Hampshire the judge is
+subject to recall by the Legislature and on four different occasions,
+judges have been removed in that state by this method.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_217" href="#FNanchor_217" class="label">[59]</a> United States vs. Guthrie, 58 U. S. (17 How.) 284; State, ex
+rel, Vail, vs. Draper, 48 Mo. 213.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_218" href="#FNanchor_218" class="label">[60]</a> Evans vs. Foster, 1 N. H. 374; McDowell vs. VanDusen, 12
+Johns. 356.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_219" href="#FNanchor_219" class="label">[61]</a> From Address delivered by Judge John F. Philips, December
+22’, 1912, at Omaha Club, Omaha, Nebraska, upon the “Judicial
+Recall.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_220" href="#FNanchor_220" class="label">[62]</a> <i>Ante idem.</i> The great Wirt was asked, after the Burr trial:
+“Why did you not tell Judge Marshall that the people of America
+demanded a conviction?” And his reply showed not only the high-minded,
+professional gentleman that he was, but the patriotic citizen
+as well. It was: “Tell him that? I would as soon have gone to
+Herschel and told him that the people of America insisted that the
+moon had horns as a reason why he should draw her with them.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_221" href="#FNanchor_221" class="label">[63]</a> Deuteronomy, 1-17.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_222" href="#FNanchor_222" class="label">[64]</a> Dr. Sprenger, in his “Life of Mohammed” says 9,000,000 were
+burned.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_223" href="#FNanchor_223" class="label">[65]</a> Upham’s “Salem Witchcraft in Outline”; Nevin’s “Witchcraft
+in Salem Village.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_224" href="#FNanchor_224" class="label">[66]</a> Upham’s “Salem Witchcraft in Outline.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_225" href="#FNanchor_225" class="label">[67]</a> North American Review, Article by Albert Fink, vol. 193, p. 690.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_226" href="#FNanchor_226" class="label">[68]</a> North American Review, vol. 193, p. 673, for decisions holding
+that a Republican form of Government is one where the whole
+people are represented by their representatives.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_227" href="#FNanchor_227" class="label">[69]</a> Mr. Rome G. Brown, in his interesting paper before the Minnesota
+Bar Association, confidently asserts that the United States
+Supreme Court ought to hold the judicial recall, in the United
+States as contrary to the Federal Constitution, because a denial of
+the Republican form of Government, guaranteed by this immortal
+document.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_228" href="#FNanchor_228" class="label">[70]</a> See Excellent Paper of Judge John F. Philips, read at Omaha
+Club, Feb. 22’, 1912.</p>
+
+<p>If such a custom generally prevailed, it is probable that in the
+due course of time we would indeed have:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Red ruin and the breaking up of laws.”</div>
+ </div>
+</div>
+</div>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_229" href="#FNanchor_229" class="label">[71]</a> It is a just source of pride to Englishmen that not a single
+lynching has occurred for three-quarters of a century, in a country
+governed by the English law.</p>
+
+<p>Illustrative of the complete independence that for centuries has
+characterized the English judiciary, it is reported that when accosted
+by King James I. and asked how he expected to decide a
+given case, pending in his court, Sir Edward Coke, then Lord
+Chief Justice of England replied: “When that case shall come
+before me, I will decide it as a good judge ought to decide it, in
+accordance with the law and the evidence.” Percy’s Anecdotes on
+Justice.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_109"></a>[109]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_IV">CHAPTER IV.<br>
+<span class="smcap">Trial by Battle.</span></h2>
+
+</div>
+
+<p>Trial by battle, sometimes called “wager of battel,”
+or “battile,” as Bouvier refers to it, could be claimed
+in appeals of felony and in certain civil cases and was
+of frequent use in affairs of chivalry and honor.<a id="FNanchor_230" href="#Footnote_230" class="fnanchor">[1]</a></p>
+
+<p>No tradition can tell us just when the trial by combat
+first came into existence.<a id="FNanchor_231" href="#Footnote_231" class="fnanchor">[2]</a> Wager of battle was a
+natural accompaniment of the state of society existing
+when men were accustomed to take the law into their
+own hands and test the right by the might that could
+back it up. Battle has always been the law among the
+lower animals and in the evolution of the species, before
+society had developed the standards of our present
+civilization, the males of the human species, in barbarous
+nations, won the females much oftener through the
+law of battle, than by the display of intellectual attainments.</p>
+
+<p>Trial by battle, therefore, may be traced to the most
+ancient period. Sacred writ gives an analogous contest,
+in the memorable battle between King David and
+Goliah, and the destinies of nations, instead of the
+rights of individuals, were made to depend upon the
+outcome of the combat. Goliah challenged the Israelites:</p>
+
+<div class="blockquote">
+
+<p>“Choose you a man for you, and let him come down
+to me. If he be able to fight with me and to kill me,<span class="pagenum"><a id="Page_110"></a>[110]</span>
+then will we be your servants; but if I prevail against
+him, and kill him, then shall ye be our servants and
+serve us.”<a id="FNanchor_232" href="#Footnote_232" class="fnanchor">[3]</a></p>
+
+</div>
+
+<p>And, as the principals in the trial by battle always
+relied upon the grace of God to further the righteousness
+of their cause, so King David, in his battle, relied
+upon the God who had saved him from the lion and delivered
+him from the paw of the bear, to bring to a successful
+issue, his contest with the giant. He went to
+the fight in the name of the “Lord of Hosts,” the God
+of the armies of Israel, and proclaimed that it was
+“His battle,” and he fought not with sword and spear,
+but would deliver the Philistines into his hands.<a id="FNanchor_233" href="#Footnote_233" class="fnanchor">[4]</a></p>
+
+<p>The soldier and historian, Paterculus, is authority
+for the statement that during the first half of the first
+century, when Quintilius Varus attempted the settlement
+of disputes among the Germans by law, he discovered<span class="pagenum"><a id="Page_111"></a>[111]</span>
+that their custom had been to decide all such
+controversies by single combat.<a id="FNanchor_234" href="#Footnote_234" class="fnanchor">[5]</a></p>
+
+<p>Neilson<a id="FNanchor_235" href="#Footnote_235" class="fnanchor">[6]</a> refers to the traditional statement of King
+Frotho the Third in the misty age of Denmark, that he
+“deemed it much fitter to contend with weapons than
+with words,” in the settlement of private disputes, and
+he shows how this sentiment found firm lodgment in
+the breast of the Norseman, whose supreme God was
+Odin, the God of war, for valor was the jewel of his
+soul.</p>
+
+<p>Selden states that the decision of suits by appeal to
+the God of battle is said to have been invented by the
+Burgundi, one of the northern of the German clans that
+flourished before the subjugation of the Gauls by the
+Romans. And it is true, that the first written injunction
+of judiciary combats that we meet with is in the
+laws of Gundibald, A. D. 501, which are preserved in
+the Burgundian code. It was not a mere local custom
+of that particular tribe, however, but was the common
+usage of all those warlike people, from the earliest
+times.<a id="FNanchor_236" href="#Footnote_236" class="fnanchor">[7]</a></p>
+
+<p>Judicial duels, or combats by individuals, according
+to forms of law, obtained among the ancient Goths, in
+Sweden,<a id="FNanchor_237" href="#Footnote_237" class="fnanchor">[8]</a> and this form of “searching out hidden
+truths,” as Selden observes, was practiced by the Russians,
+Hungarians, Almains and Normans.<a id="FNanchor_238" href="#Footnote_238" class="fnanchor">[9]</a></p>
+
+<p><span class="pagenum"><a id="Page_112"></a>[112]</span></p>
+
+<p>History records that the Emperor Otho, A. D. 983, at
+Verona, held a diet at which were assembled many
+lords and princes from France, Germany and Italy and
+in order to discourage perjury in judicial trials, the convention
+substituted the trial by battle in all cases, in
+lieu of the oaths or testimony of witnesses.<a id="FNanchor_239" href="#Footnote_239" class="fnanchor">[10]</a></p>
+
+<p>In the early feudal ages, “when knighthood was in
+flower,” chivalry played no small part in the growth
+and development of the fixed rules governing the trial
+by battle.<a id="FNanchor_240" href="#Footnote_240" class="fnanchor">[11]</a> Chivalry has always been in the world,<span class="pagenum"><a id="Page_113"></a>[113]</span>
+but it finds expression according to the customs obtaining
+in the different stages of man’s growth and development.
+Because fighting was then the order of the day,
+in the olden times, knights were sacrificed by personal
+combat, for their ladies faire. When trial by battle
+was on the decline, Sir Walter Raleigh expressed the
+spirit of chivalry of that period, by spreading his
+cloak upon the ground for his queen to walk upon. And
+in this our twentieth century, with the progress of the
+race,—be it ever recorded to the credit of the manhood
+of the period—this same spirit was exemplified by the
+splendid lesson of hundreds of noble men heroically
+accepting the terrors of a mighty sea, in order to
+rescue the women and children from a sinking ship.<a id="FNanchor_241" href="#Footnote_241" class="fnanchor">[12]</a></p>
+
+<p>The deeds of knighthood, in the England of the
+middle ages, came to be gauged according to fixed and
+settled rules and customs and finally the <i>Court of Honor</i>,
+was recognized, the same as the court of civil procedure,
+for the trial of affairs of honor, for, says Blackstone:
+“This court of chivalry, can order reparation at
+the point of honor.”<a id="FNanchor_242" href="#Footnote_242" class="fnanchor">[13]</a></p>
+
+<p>The proceedings of this court were by petition, in a
+summary manner, and the trial, instead of by a jury,
+as at the present day, with witnesses, was by individual
+combat.<a id="FNanchor_243" href="#Footnote_243" class="fnanchor">[14]</a></p>
+
+<p>The <i>Court of Honor</i> was not a court of record and it
+could not imprison, but the marshalling of arms, was
+then the pride of the best families of the kingdom and<span class="pagenum"><a id="Page_114"></a>[114]</span>
+the success in these affairs of honor, because of the
+spirit of chivalry of the times, was just as much
+guarded as was the attainment of justice through the
+procedure of the civil courts. Heralds and knights
+seconded and backed up the appeals of the principals in
+such encounters and the sacrifice of the individual in
+these mortal combats was regarded as a trifle, compared
+to the preservation of the family name and honor
+and since his attainder and the corruption of his blood
+and family name depended upon his success in the combat,
+the wager of battle was welcomed, as the only vindication
+of one’s manhood and honor.</p>
+
+<p>The trial by battle, therefore, at a very early day,
+proceeded according to fixed, settled rules of law and
+was a recognized mode of legal procedure, just as much
+as was the trial by judicial proceedings. In this it
+differed from duelling, in that the latter was the fighting
+of two persons, at an appointed time and place, in
+the absence of law and order. In other words, the
+trial by battle was a mode of legal procedure, while
+duelling was a crime, in that the duel was not conducted
+according to legal rules and precedents, but the participants
+took the law into their own hands.<a id="FNanchor_244" href="#Footnote_244" class="fnanchor">[15]</a></p>
+
+<p>Trial by battle was introduced into England, among
+other Norman customs, by William the Conqueror. The
+right could only be claimed in three classes of cases, i. e.,
+military, or in the court martial, or court of chivalry<span class="pagenum"><a id="Page_115"></a>[115]</span>
+or honor;<a id="FNanchor_245" href="#Footnote_245" class="fnanchor">[16]</a> criminal, or in appeals of felony,<a id="FNanchor_246" href="#Footnote_246" class="fnanchor">[17]</a> and civil,
+or upon issue joined in a writ of right, the last and
+most solemn decision of real property.<a id="FNanchor_247" href="#Footnote_247" class="fnanchor">[18]</a> The reason
+why battle was allowed in “writs of right,” was said to
+be on account of the inability of establishing one’s title
+by action at law, in case of the death of witnesses or
+the absence of other evidence.</p>
+
+<p>In the criminal practice the one exercising the right
+to wager of battle was called the “Appellee,” from the
+French word “Appeller,” meaning “to call,” the term
+being used because of the practice of calling the parties
+before the court.<a id="FNanchor_248" href="#Footnote_248" class="fnanchor">[19]</a></p>
+
+<p><span class="pagenum"><a id="Page_116"></a>[116]</span></p>
+
+<p>The points of difference between a trial by combat,
+under the writ of right and one for treason, are noted
+by Neilson, in his “Trial by Combat” and principal
+among them are, that the trial at law could be fought
+before any judge, while the trial for treason had to be
+before the King, Constable or Marshal, or a special
+deputy; the forms of oath were different; the duel at
+law was fought on foot, while for treason, it was fought
+on horse-back; the weapon of the trial at law, was the
+baton, while that for treason, was the sword and spear;
+the position of the combatants, in a writ of right, was
+north and south, while in a trial for treason, it was
+east and west, and in the battle under a writ of right,
+since the trial itself was the judgment, there was no
+right to stop the trial, but in a trial for treason, the
+king, or his representatives could stop the trial, if he
+so desired.<a id="FNanchor_249" href="#Footnote_249" class="fnanchor">[20]</a></p>
+
+<p>In the appeal of felony, the prosecutor was bound to
+offer combat with his own body, but in the writ of
+right, the demandant could either participate in his
+own behalf, or through the medium of his champions’
+services.<a id="FNanchor_250" href="#Footnote_250" class="fnanchor">[21]</a> But even in the Norman days, when battle
+was in vogue, “battle did not lie” unless there was a
+charge of crime and at least ten shillings’ worth of property
+was in dispute.<a id="FNanchor_251" href="#Footnote_251" class="fnanchor">[22]</a> In civil cases, professional
+pugilists were commonly employed and perjury became
+so common that the form of the compurgator’s
+oath was changed to prevent the wholesale commission<span class="pagenum"><a id="Page_117"></a>[117]</span>
+of this crime.<a id="FNanchor_252" href="#Footnote_252" class="fnanchor">[23]</a> The commonest cause of battles were
+those urged by an “approver,” or convicted criminal,
+whose pardon was conditional upon his ridding the
+kingdom of some half dozen or more of his associates,
+by his “appeals.” This custom, however, began to decline
+so rapidly, that in Bracton’s day the annual average
+of battles did not exceed twenty.<a id="FNanchor_253" href="#Footnote_253" class="fnanchor">[24]</a></p>
+
+<p>The old books indicate that in appeals of felony, the
+custom was for the combatants to have their heads
+shaved, not to prevent the opponent from catching hold
+of the hair, but because it was an old religious custom.<a id="FNanchor_254" href="#Footnote_254" class="fnanchor">[25]</a></p>
+
+<p><span class="pagenum"><a id="Page_118"></a>[118]</span></p>
+
+<p>In discussing the trial by combat, in finance, Neilson
+shows how, during the reign of Henry II., large sums
+were paid to crown officers, for the privilege of the
+duel; for refusal to fight, or absence, and for fines for
+wrongfully claiming the right to the duel, and the same
+thing was true in the reign of Richard I.<a id="FNanchor_255" href="#Footnote_255" class="fnanchor">[26]</a></p>
+
+<p>During the reign of Edward III. the trial by battle
+was discouraged by the legislation of the period and
+trial by jury was encouraged. The right of trial by
+battle was taken away in the case of an appeal for
+breaking the king’s prison, and the right was also denied
+to one “taken with the manner.”<a id="FNanchor_256" href="#Footnote_256" class="fnanchor">[27]</a> And during
+the reigns of Edward V. and Richard III., the trial by
+battle in criminal cases had become so obnoxious to the
+people of England that it came to be established that if
+a valid indictment was pending for the offense charged,
+the right of trial by battle was denied.<a id="FNanchor_257" href="#Footnote_257" class="fnanchor">[28]</a></p>
+
+<p>In the reign of Henry VI., Priscot, Chief Justice, and
+Needham, one of the Justices, held that in an appeal for
+treason, the battle could only be had before the constable
+and marshal.<a id="FNanchor_258" href="#Footnote_258" class="fnanchor">[29]</a></p>
+
+<p><span class="pagenum"><a id="Page_119"></a>[119]</span></p>
+
+<p>Wager of battle had been but seldom invoked in actions
+of debt, and in the thirteenth century, it was no
+longer allowed in this class of actions.<a id="FNanchor_259" href="#Footnote_259" class="fnanchor">[30]</a></p>
+
+<p>A generation after the Norman conquest, Henry I., by
+Charter to the City of London,<a id="FNanchor_260" href="#Footnote_260" class="fnanchor">[31]</a> granted exemption
+from the trial by battle to citizens of London, or peers
+of the realm, in certain cases, and a woman, a priest,
+an infant, a man of sixty or over, or one maimed, lame,
+or blind, was entitled to refuse the wager of battle and
+insist upon a trial by jury.<a id="FNanchor_261" href="#Footnote_261" class="fnanchor">[32]</a></p>
+
+<p>In civil combat, upon issue joined in a writ of right,
+the tenant or defendant had to try the issue by combat,
+until the reign of Henry II., when the Grand Assize was
+provided for, and then he had his election either to try
+the issue by combat or by the jury trial, provided for
+by this king in this class of cases.</p>
+
+<p><span class="pagenum"><a id="Page_120"></a>[120]</span></p>
+
+<p>Glanville,<a id="FNanchor_262" href="#Footnote_262" class="fnanchor">[33]</a> who wrote during the reign of Henry II.,
+after the tenant was given his election to try his writ
+of right either by combat, or by the Grand Assize, thus
+describes the procedure then obtaining under the rule
+of civil combat:</p>
+
+<div class="blockquote">
+
+<p>“Both parties being present in court, and the demandant
+claiming the land in question, the tenant may
+require the view thereof: but as to this, there is respite
+to be made, to the end it may be known, whether the
+defendant have not more land in that town than what
+is in question; and if he have not, then he shall not be
+allowed any respite; but if he have more, he shall; and
+likewise have assignation of another day; and, when he
+shall be so departed out of the court, at three reasonable
+essoins,<a id="FNanchor_263" href="#Footnote_263" class="fnanchor">[34]</a> the defendant may recover anew; and the
+shireeve of the county wherein the land lieth shall have
+a writ directed to him to send freeholders of his county
+to view the land.</p>
+
+<p>“Then, after three reasonable essoins, concomitating
+the view of the said land, and both demandant and
+tenant appearing again in court, the demandant setteth
+forth his claim in this manner: ‘I do challenge against
+T. H. half a knight’s fee, or two carucates of land in
+that town, as my right and inheritance; and whereof, my
+father, or grandfather, was seised in his demesne, as
+of fee, in the time of King Henry I., or after the first
+coronation of the King that now is, and whereof he
+hath taken the profits, to the value of 10s. at the least,
+viz., in corn sowed, and other commodities; and this I
+am ready to try by this my freeman N.; and if any mischance
+shall befall him, then by that other person who
+hath seen and heard this.’ Or thus,—‘And this I am<span class="pagenum"><a id="Page_121"></a>[121]</span>
+ready to try by this my freeman, S. unto whom his
+father, on his death-bed enjoined, upon the duty wherein
+a son is obliged to a father, that if at any time he
+should hear of a suit for that land, he should adventure
+himself, by combat for it, as that which his father had
+seen and heard.’</p>
+
+<p>“The claim and demand of the demandant being thus
+made, it shall be in the choice of the tenant, either to
+put himself upon trial for the same by <i>combat</i>, or to
+put himself upon the <i>great assize</i> of our lord, the king,
+and to require a recognition which of them hath most
+right in that land.</p>
+
+<p>“And if he will defend it by <i>combat</i>, he is then
+obliged to defend the right of the demandant word to
+word as he sheweth it against him, either by himself or
+some other fitting person; but note, that after the <i>combate</i>
+shall be thereupon waged, it behoveth him who
+holdeth the land, to defend it by <i>combate</i>, and thenceforth
+not to put himself into the <i>great assize</i>; and, after
+the <i>combat</i> waged, he may again reasonably essoins
+himself thrice, as for his own person, and thrice for the
+person of his champion. All which essoins being made,
+as they rightly ought to be, it is necessary that, before
+the <i>combat</i> be begun, the plaintiff do appear in court,
+and have his champion there in readiness to fight; nor
+may he bring any other champion than one of those,
+upon whom he did put the trial of his cause; neither
+may he change another for him, after the first waging
+of the battle....</p>
+
+<p>“And if the defender (i. e., the champion) shall
+happen to be vanquished, his lord shall lose the land by
+him claimed, with the profits and commodities thereof,
+at the time of the seisin found in that fee, and shall
+never after be heard in court again for the same; but
+whatsoever things shall be determined by combat in
+the court of our lord the king are to remain firm forever;
+and thereupon there shall be a precept directed to<span class="pagenum"><a id="Page_122"></a>[122]</span>
+the shireeve, that the victor shall have the land which
+was in dispute....</p>
+
+<p>“This, if the demandant shall prevail in the combat;
+but if he be overthrown by the vanquishing of his
+champion, then the tenant shall be acquitted from his
+claim without recovery by the demandant.”<a id="FNanchor_264" href="#Footnote_264" class="fnanchor">[35]</a></p>
+
+</div>
+
+<p>Selden describes the ceremony governing the civil
+combat, upon issue joined upon a writ of right,<a id="FNanchor_265" href="#Footnote_265" class="fnanchor">[36]</a> as
+follows:</p>
+
+<div class="blockquote">
+
+<p>“A piece of ground is in due time set out of sixty
+feet square, enclosed with lists; and on one side, a court
+erected for the judges of the court of common pleas,
+who attend there in their scarlet robes; and also a bar
+is prepared for the learned serjeants at law. When the
+court sits, which ought to be by sun-rising, proclamation
+is made for the parties and their champions, who
+are introduced by two knights, and are in a coat of
+armour, with red sandals, bare-legged from the knee
+downward, bare-headed, and with bare arms to the elbows.
+The weapons allowed them are only <i>batons</i>, or
+staves of an ell long and a four-cornered leather target,
+so that death very seldom ensued this civil combat ...</p>
+
+<p>“When the champions, thus armed with batons, arrive
+within the lists or place of combat, the champion
+of the tenant then takes his adversary by the hand and
+makes oath that the tenements in dispute are not the
+right of the demandant; and the champion of the demandant
+then taking the other by the hand, swears in
+the same manner that they are; so that each champion
+is, or ought to be, thoroughly persuaded of the truth of
+the cause he fights for. Next an oath against sorcery<span class="pagenum"><a id="Page_123"></a>[123]</span>
+and enchantment is to be taken by both the champions
+in this or a similar form: ‘Here this, ye justices, that I
+have this day, neither eat, drank, nor have upon me
+neither bone, stone, no grass nor any enchantment,<span class="pagenum"><a id="Page_124"></a>[124]</span>
+sorcery, or witchcraft, whereby the law of God may be
+abased, or the law of the devil exalted, so help me, God
+and his saints.’</p>
+
+<p>“The battle is thus begun, and the combatants are
+bound to fight till the stars appear in the evening; and
+if the champion of the tenant can defend himself till
+the stars appear, the tenant shall prevail in his cause;
+for it is sufficient for him to maintain his ground, and
+make it a drawn battle, he being already in possession;
+but if victory declares itself for either party, for him is
+judgment finally given. This victory may arise from
+the death of either of the champions, which indeed, hath
+rarely happened, the whole ceremony, to say the truth,
+bearing a near resemblance to certain rural athletic
+diversions, which are probably derived from this original;
+or victory is obtained, if either champion proves
+<i>recreant</i>; that is, yields, and pronounces the horrible
+word of <i>craven</i>, a word of disgrace and obloquy rather
+than of any determinate meaning: but a horrible word
+it indeed is, to the vanquished champion, since, as a
+punishment to him, for forfeiting the land, of his principal,
+by pronouncing that shameful word, he is condemned
+as a recreant <i>amittere liberam legem</i>; that is, to
+become infamous, and not be accounted <i>liber et legalis
+homo</i> being supposed by the event to be proved foresworn,
+and therefore never to be put upon a jury, or
+admitted as a witness in any cause.”</p>
+
+</div>
+
+<p>Combat in criminal cases was allowed, according to
+Selden<a id="FNanchor_266" href="#Footnote_266" class="fnanchor">[37]</a> not only in cases of treason but</p>
+
+<div class="blockquote">
+
+<p>“For the trial of a particular objected misdeed,
+cognizable by the ordinary course of the common law;<span class="pagenum"><a id="Page_125"></a>[125]</span>
+and of these the justices of the king’s bench have the
+imposition; it is likewise permitted for the purgation
+of an offense against military honor, which the high
+court of chivalry is to marshal by the law of arms.”</p>
+
+</div>
+
+<p>The military form of trial by combat, on a criminal
+charge was as follows:</p>
+
+<div class="blockquote">
+
+<p>“First a bill of challenge is, together with a gauntlet,
+delivered unto the court by the appellant. The defendant
+denieth the point of the bill, and excepteth the
+gauntlet.</p>
+
+<p>“Then, if the appellant have no witnesses to prove
+the matter of his appeal, the marshal prefixes a day,
+within forty, for deraigning the combat, taking pledges
+of both parties, to appear at the day, and to do battle
+between sun-rising and sun-set.</p>
+
+<p>“The place appointed for the combat is a hard and
+even ground, railed within certain lists, sixty feet in
+length and forty feet in breadth; and without the lists
+are certain counter-lists, without which the marshal’s
+men come, as well to attend any extraordinary accident,
+within the lists, as to keep off the press of the people
+without.</p>
+
+<p>“Their weapons are appointed, a glaive, a long
+sword, a short sword, and a dagger. At the day the
+appellant doth appear and come to the east gate of the
+lists, where he is admitted to enter by the marshal himself,
+together with his arms, weapons, victual and also
+his council with him; and then is brought to a certain
+place, within the lists, where he attends the coming of
+the defendant.</p>
+
+<p>“The defendant, if he appear not, is called by three
+proclamations, made by the marshal of the king of
+heralds of that province wherein the battle is deraigned.
+The marshal’s clerk doth enter into his register
+their coming, the time of their coming, and the
+manner, whether on horse-back or on foot; the fashion
+of their arms and their weapons; the colour of their
+horses and the like.</p>
+
+<p>“The marshal doth measure their weapons; and then
+the marshal hath a clerk ready, who brings forth the<span class="pagenum"><a id="Page_126"></a>[126]</span>
+crucifix and a mass book, whereupon both the appellant
+and defendant do take their oaths.</p>
+
+<p>“The bill of challenge of the appellant and the
+answer of the defendant, is read unto them by the
+marshal’s clerk; and then they take their oaths; First,
+that their appeal and defense is true; Second, that
+neither has advantage of other by weapon; Third, that
+either would do his best endeavour to vanquish his
+enemy.</p>
+
+<p>“Then proclamation is made at every corner of the
+lists, for the clearing and voidance of the lists. Then
+the combatants, being ready, the constable and marshal,
+sitting at the king’s feet, pronounce these words, with a
+high voice: ‘<i>Lesses les aller, lesses les aller, lesses les
+aller et faire leur devoir.</i>’</p>
+
+<p>“In the fight, if either of the parties do give any
+sign of yielding; or if the king, being present, do cry
+‘<i>Hoe</i>,’ the constable and the marshal do part them, and
+observe precisely who hath advantage or disadvantage,
+either of other at that instant; for if they should be
+awarded to fight again, they are to be put in the same
+posture as they were before. If the king take up the
+matter, they are brought honorably out of the lists,
+neither having precedency before the other. If the
+battle be performed, and one party be vanquished, then,
+in case of treason, the rails of the lists are broken down,
+and the party vanquished is drawn out at a horse-tail
+and carried presently to execution by the marshal.”<a id="FNanchor_267" href="#Footnote_267" class="fnanchor">[38]</a></p>
+
+</div>
+
+<p>The older books abound in many illustrations where
+the appellee, when charged by a formal accusation, with
+some felony, claimed the wager of battle to establish
+his innocence.<a id="FNanchor_268" href="#Footnote_268" class="fnanchor">[39]</a></p>
+
+<p>Neilson refers to the single combat between Corbis
+and Orsus, fought in the presence of Scipio, for a principality<span class="pagenum"><a id="Page_127"></a>[127]</span>
+in Spain.<a id="FNanchor_269" href="#Footnote_269" class="fnanchor">[40]</a> And the traditional combat, in prehistoric
+Roman days, between the Horatti and the Curiatti
+is also cited, to show that the institution of trial
+by combat was not unknown to the Romans, at an early
+day.<a id="FNanchor_270" href="#Footnote_270" class="fnanchor">[41]</a></p>
+
+<p>Geoffrey of Monmouth, describes the battle between
+King Arthur and Flollo, the Roman Tribune, at the
+siege of Paris, to determine who would be the master
+of the realm, and this realistic story of the battle, on
+horses, with fixed lances and the interesting narration
+of how King Arthur, after his horse was killed under
+him, drove his sword through the helmet of Flollo and
+cut his head in two, reads like some story from the
+works of fiction.<a id="FNanchor_271" href="#Footnote_271" class="fnanchor">[42]</a></p>
+
+<p>Neilson notes<a id="FNanchor_272" href="#Footnote_272" class="fnanchor">[43]</a> that in Mediaeval Germany, disputes
+between men and women were settled by combat, for
+chivalry does not seem to have penetrated into the warlike
+confines of this sturdy nation, at this period, although
+some notion of equalizing the contests between
+the weaker combatant and the stronger, obtained. The
+male was handicapped, in such contests, by placing
+him in a tub, sunk waist deep in the ground, with one
+hand tied behind his back. The woman was allowed a
+paving stone, sewed in the end of the long sleeve of her
+shift, or under garment and she was accorded the privilege
+of manouvering around her antagonist, at will, until
+she found a vulnerable point of attack.<a id="FNanchor_273" href="#Footnote_273" class="fnanchor">[44]</a></p>
+
+<p><span class="pagenum"><a id="Page_128"></a>[128]</span></p>
+
+<p>Perhaps the earliest reference to the trial by battle,
+among the adjudicated English cases, is that of Wulfstan
+vs. Walter, of which Lea reports that the witnesses
+who saw the trial stood ready to prove their
+assertions regarding it, by “oath and battle.”<a id="FNanchor_274" href="#Footnote_274" class="fnanchor">[45]</a></p>
+
+<p>The mandate of the Conqueror’s law, that the mutilated
+trunk, of the defendant, convicted of treason, by
+combat, should remain as an evidence of his crime, in
+order to deter others from this hated offense, was exemplified,
+in the year 1096, in the case of William of
+Eu,<a id="FNanchor_275" href="#Footnote_275" class="fnanchor">[46]</a> who, after trial by combat, had his eyes torn out
+and thus bereft of his sight, was sadly left to wander
+alone and despised through the world, a living example
+of the vengeance of the Lord, for the offense that he
+had been convicted of, by this hap-hazard method.</p>
+
+<p>The battle between Henry, Earl of Essex and Robert
+de Montford, in the year 1163, on an island in the
+Thames, near the Abbey, is well attested by the history
+of that period. The charge of treason was preferred
+in Parliament and the combat was adjudged, because
+of the alleged cowardice of the Earl of Essex, during
+the Welsh war of 1157, in precipitating a panic, during<span class="pagenum"><a id="Page_129"></a>[129]</span>
+a decisive engagement in a narrow pass, by throwing
+down his banner and giving the alarm that the king had
+been slain. De Montford was victorious in the battle
+which followed and though Essex made a fierce attack
+upon him, his blows were warded off and the Earl was
+defeated and left for dead upon the field of battle.
+His body was given to the Monks of Reading, for burial
+and he was revived and allowed to become a Monk
+himself.<a id="FNanchor_276" href="#Footnote_276" class="fnanchor">[47]</a></p>
+
+<p>“Hobbe-the-Werwede,” an approver, much spoken
+of in the old books discussing trial by battle, in the
+fourth year of King Henry III. defeated “Walter-in-the-Grove,”
+but Hobbe soon afterwards faced another
+opponent and like many of our modern pugilists, went
+down to defeat, in his last battle.<a id="FNanchor_277" href="#Footnote_277" class="fnanchor">[48]</a></p>
+
+<p>On October 4’, 1350, Sir John de Visconti fought Sir
+Thomas de la Marche, before King Edward III., within
+the bounds of the royal palace, at Westminster. Sir
+John had charged Sir Thomas with taking bribes from
+the infidel Turks and betraying the Christian army.
+The combatants were clad in armour, but their helmets
+were guarded, at the visor, with small bars of steel.
+Sir Thomas had taken the precaution to wear steel
+knuckles, with which he soon broke the bars of steel
+covering the visor of Sir John’s helmet and thus having
+the advantage, he punished him so severely, by repeated
+blows in the face, that Sir John was compelled
+to yield. Because of the compliment paid to the English
+King, in fighting this duel in his presence, when<span class="pagenum"><a id="Page_130"></a>[130]</span>
+Sir Thomas returned to France, he was tried by his
+brother, the King, upon the charge of treason, and beheaded.<a id="FNanchor_278" href="#Footnote_278" class="fnanchor">[49]</a></p>
+
+<p>The celebrated trial between the Dukes of Hereford
+and Norfolk, made immortal by Shakespeare, in his
+Richard II., occurred at Coventry, on September 16’,
+1398. Hereford appealed the Duke of Norfolk of high
+treason, in Parliament, in the use of words tending to
+the king’s dishonor. Armour and coats of mail had
+been procured from Germany and Milan, for the warriors.
+Hereford, who was the people’s favorite, came
+to the lists mounted on a white horse, barbed with blue
+and green velvet. Norfolk’s horse was draped with
+crimson velvet. Ten thousand armed knights were in
+attendance, to prevent an affray and a large concourse
+of the populace attended, to cheer their respective
+favorites. When the combatants faced each other, the
+King, fearful, no doubt, that Hereford would prevail,
+banished both the combatants. Norfolk soon afterwards
+died, in Venice, but Hereford returned the following
+year to wrest the crown from the weak king and
+proclaim himself King Henry IV.<a id="FNanchor_279" href="#Footnote_279" class="fnanchor">[50]</a></p>
+
+<p>A lawyer entered the lists, in the year 1431, when
+John Upton, a notary, accused John Downe of treason,
+in attempting to accomplish the death of the king. The
+duel was fought in the presence of the king, on the 24’
+of January and the writ, providing for the barriers and
+the making of the lists; the levelling and sanding of the<span class="pagenum"><a id="Page_131"></a>[131]</span>
+ground and the removal of the stones, is fully set forth
+in Coke, on Littleton.<a id="FNanchor_280" href="#Footnote_280" class="fnanchor">[51]</a> There was a fierce fight, but
+the king pardoned both contestants, before the final termination
+of the trial.<a id="FNanchor_281" href="#Footnote_281" class="fnanchor">[52]</a></p>
+
+<p>The battle between the armourer’s servant, John
+Davy and his master, William Catur, described by
+Shakespeare, in the second part of Henry VI., was actually
+fought, on January 31’, 1447. The armourer’s
+body was stripped of its armour and left upon the field
+of battle and the penalty of treason was inflicted, and
+the trunk was mutilated and the head set up on the
+London Bridge.<a id="FNanchor_282" href="#Footnote_282" class="fnanchor">[53]</a></p>
+
+<p>The case of Thomas Whithorn, in the year 1455, reported
+by William Gregory, Mayor of London, is not
+without interest. Whithorn was a convicted thief and
+in accordance with the custom of the period, to save his
+own life, he made a number of appeals against reputable
+citizens, some of whom, because of his physical
+prowess, were unable to stand up against him and were
+hanged, after unsuccessful trials by battle, with him.
+He finally charged crime against one James Fisher,
+who, to save his life, concluded to fight the thief. Both
+contestants were clad in white sheep’s leather, over
+their legs, head, face, hands and bodies and they fought
+with green ash staves, three feet long, with an iron
+ram’s horn on the end. Fisher broke his weapon early
+in the fight and the constable then took the approver’s
+away too and after that they fought “teeth and nail.”<span class="pagenum"><a id="Page_132"></a>[132]</span>
+Fisher finally got the thief’s nose between his teeth and
+his thumbs in his eyes and he so tortured him that he
+cried “craven” and was hanged, “for he was fals unto
+God and unto hym.”<a id="FNanchor_283" href="#Footnote_283" class="fnanchor">[54]</a></p>
+
+<p>One of the last battles judicially fought upon English
+soil was that between Sir James Parker and Sir Hugh
+Vaughan, before Henry VII., in 1492. The battle was
+the result of a quarrel about certain arms given by the
+King to Vaughan. The fight occurred at Richmond
+and resulted in the victory of Vaughan over Parker.
+The former’s spear penetrated the helmet of Sir James
+and cleaved his tongue from his mouth and he died in
+a short time from the wound inflicted.<a id="FNanchor_284" href="#Footnote_284" class="fnanchor">[55]</a></p>
+
+<p>The last trial by battle that was waged in the court
+of common pleas at Westminster,<a id="FNanchor_285" href="#Footnote_285" class="fnanchor">[56]</a> occurred in the
+thirteenth year of Queen Elizabeth, A. D. 1571. This
+was the celebrated case of Lowe vs. Paramour, reported
+by Sir James Dyer<a id="FNanchor_286" href="#Footnote_286" class="fnanchor">[57]</a> and also by Sir Henry Spelman,<a id="FNanchor_287" href="#Footnote_287" class="fnanchor">[58]</a>
+who was himself a witness of the trial. The battle occurred
+in Tothill-fields, Westminster, “<i>non sine magna
+juris consultorum perturbatione</i>,” reports Sir Henry
+Spelman.<a id="FNanchor_288" href="#Footnote_288" class="fnanchor">[59]</a></p>
+
+<p>In the last English case wherein the right of trial by
+battle was recognized, two citizens of the laboring class
+elected to decide their cause by the wager of battle, in<span class="pagenum"><a id="Page_133"></a>[133]</span>
+1818. The case was that of Ashford vs. Thornton.<a id="FNanchor_289" href="#Footnote_289" class="fnanchor">[60]</a>
+The facts giving rise to the appeal by Abraham Thornton,
+in 1817, are briefly told. Mary Ashford, of Warwickshire,
+was drowned, under circumstances directing
+suspicion of foul play, against Thornton. He was arrested
+for her murder and tried and acquitted by a
+jury, but public sentiment was so aroused against him
+that the dead girl’s brother, instituted an appeal for
+murder against Thornton, and while this proceeding,
+after a jury trial, was quite unusual, the court held that
+the proceeding was proper. Thornton demanded the
+right of trial by battle, and the court held that he was
+entitled to such a trial, but before the trial, in April,
+1818, the appeal was withdrawn and Thornton was discharged.
+Upon the legality of the proceeding of trial
+by battle, however, the case proceeded to judgment, before
+the Court of King’s Bench and Lord Ellenborough,
+for the court, decided that:</p>
+
+<div class="blockquote">
+
+<p>“The general law of the land is in favor of the wager
+of battle and it is our duty to pronounce the law as it
+is and not as we may wish it to be; whatever prejudice,
+therefore, may justly exist against this mode of trial,
+still, as it is the law of the land, the court must pronounce
+judgment for it.”</p>
+
+</div>
+
+<p>That this judgment was right, few, if any, lawyers
+would question, as the repeal of existing laws is a legislative,
+not a judicial function; it is the province of the
+courts to expound and apply, not to repeal laws regularly
+enacted and recognized by the legislative branch
+of government and although an absurd law may remain
+unenforced, because over-looked, it is none the<span class="pagenum"><a id="Page_134"></a>[134]</span>
+less a law, although not enforced, until repealed by the
+proper department.</p>
+
+<p>It was the judgment of the court, in the above case,
+however, that brought about the repeal of the right of
+trial by battle, in England, by the 59’ George III., c.
+46.<a id="FNanchor_290" href="#Footnote_290" class="fnanchor">[61]</a> By this statute it was enacted that:</p>
+
+<div class="blockquote">
+
+<p>“Appeals of murder, treason, felony and other offenses,
+and the manner of proceeding therein, have
+been found to be oppressive; and the <i>trial by battle</i>, in
+any suit, is a mode of trial unfit to be used; and it is
+expedient that the same should be wholly abolished.”</p>
+
+</div>
+
+<p>Accordingly, the act proceeded to abolish all appeals,
+in criminal cases and,</p>
+
+<div class="blockquote">
+
+<p>“In any writ of right now depending, or hereafter to
+be brought, the tenant shall not be received to wage
+battle, nor shall issue be joined, or trial be had by
+battle in any writ of right.”</p>
+
+</div>
+
+<p>Trial by battle was abolished in France, in 1260, by
+the good Saint Louis, for the reason that it often
+happened that in the contests between a rich man and a
+poor man, the former hired all the champions, and left
+the latter without help.<a id="FNanchor_291" href="#Footnote_291" class="fnanchor">[62]</a> The right to a trial by battle
+was last recognized, in Scotland, near the close of the
+sixteenth century,<a id="FNanchor_292" href="#Footnote_292" class="fnanchor">[63]</a> so it survived in England, after it<span class="pagenum"><a id="Page_135"></a>[135]</span>
+had long ceased to exist, as a mode of judicial proceeding,
+in the other European countries.</p>
+
+<p>Trial by battle has ever been an interesting theme in
+English literature. And it is little wonder that this
+sturdy struggle for justice, according to the light then
+obtaining, should be selected as the climax of the vivid
+plots, by the masters of poesy and fiction, depicting the
+chivalry of the age “when knighthood was in flower.”</p>
+
+<p>If human interest were lacking in this antique procedure
+of the past as we read of it in the unadorned details
+of the trials of the period, certainly no one can
+fail to entertain the deepest concern for the fate of the
+principals we meet with in this struggle for justice, as
+portrayed by the poets and novelists of English literature.
+And instead of being overdrawn, such representations
+are often but true portrayals of many of the
+concrete cases that have come down to us, of the trials
+by battle, of the past centuries.</p>
+
+<p>The song of Roland, chanted at the battle of Hastings,
+in the eleventh century, was really attuned to the
+theme of wager by battle, and from the appeal, to the
+conclusion of the duel, between Pinabel and Thierry,
+before Charles the Great, resulting in the punishment
+of the treason of Ganelon, for the fall of Roland, the
+legal procedure of wager by battle of chivalry is truthfully
+presented, even as the law writers of the period
+would reproduce the history of such a trial.</p>
+
+<p>Chaucer, in his pure and antique style, uses the trial
+by battle as the expression of the chivalry and knighthood
+shown by Palamon and Arcite, in their battle with
+their hundred chosen warriors, before Theseus, for the<span class="pagenum"><a id="Page_136"></a>[136]</span>
+love of the beautiful Emelye, and accurately portrays
+the different points of law, governing the trial by
+battle, in his description of this combat, from the assembling
+of the knights,</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Armed for lystes, up at alle rightes,</div>
+ <div class="verse indent0">All redy to derrayne hire by bataylle,”</div>
+ </div>
+</div>
+</div>
+
+<p class="noindent">to the final conclusion of the trial, by the conquering of
+Palamon and his knights.<a id="FNanchor_293" href="#Footnote_293" class="fnanchor">[64]</a></p>
+
+<p>That the immortal Shakespeare was familiar with
+the exact details of the procedure in trials by battle, is
+apparent from a perusal of the various plays where he
+introduces this method of trial.<a id="FNanchor_294" href="#Footnote_294" class="fnanchor">[65]</a></p>
+
+<p>In King Richard II., Thomas Mowbray and Bolingbroke,
+as “accuser and accused,” are introduced, in all
+of their habiliments of war, into the presence of the
+king, “face to face, and frowning, brow to brow.”<a id="FNanchor_295" href="#Footnote_295" class="fnanchor">[66]</a></p>
+
+<p>In the same play, a Lord offers the gage to the Duke
+of Aumerle, in the following challenge:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Lord.</i> From sun to sun, there is my honor’s pawn;</div>
+ <div class="verse indent6">Engage it to the trial, if thou dar’st.”<a id="FNanchor_296" href="#Footnote_296" class="fnanchor">[67]</a></div>
+ </div>
+</div>
+</div>
+
+<p>The Duke of Surrey, is likewise made to offer battle,<span class="pagenum"><a id="Page_137"></a>[137]</span>
+in Richard II., to Lord Fitzwater, in the following
+words:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Surrey.</i> In proof whereof, there is my honor’s pawn,</div>
+ <div class="verse indent6">Engage it to the trial, if thou dar’st.”<a id="FNanchor_297" href="#Footnote_297" class="fnanchor">[68]</a></div>
+ </div>
+</div>
+</div>
+
+<p>Vernon and Bassett implore the right of trial by
+battle, in 1’ Henry VI.,<a id="FNanchor_298" href="#Footnote_298" class="fnanchor">[69]</a> and the details of the trial by
+battle between the master, Horner, and his apprentice,
+Peter, are set forth, with precision, in II Henry VI.,
+much as the details are given in the case from which
+this scene is actually taken by the Poet.<a id="FNanchor_299" href="#Footnote_299" class="fnanchor">[70]</a></p>
+
+<p>Edgar and his bastard brother, Edmund, are made to
+try their cause by the wage of battle, in King Lear, and
+the rule of Knighthood, then obtaining, is adverted to,
+giving the challenged one the right to decline the combat,
+if the right were not equal and the wronged Edgar
+truthfully asserts “Yet am I noble as the adversary, I
+came to cope withal.”<a id="FNanchor_300" href="#Footnote_300" class="fnanchor">[71]</a></p>
+
+<p>Sir Walter Scott has added the zest of human interest,
+commonly felt for the innocent, wrongfully accused,
+to the uncertain fate of the gentle and lovely Rebecca,
+falsely accused of sorcery and witchcraft, by the valiant
+and fearless, but selfish, amorous and vacillating Brian
+de Bois-Guilbert, in Ivanhoe, and the trial by battle
+is utilized as the instrument of justice whereby the innocence
+of this gentle Jewess is established.</p>
+
+<p>True to the faith of her fathers, and charitable, out<span class="pagenum"><a id="Page_138"></a>[138]</span>
+of the goodness of her heart, Rebecca ministers to the
+wants of the peasant and then, because she turns a
+deaf ear to the importunities of the faithless Templar,
+she is arraigned and tried for sorcery and the practice
+of witchcraft, and would have been left without a
+champion, but for the chivalrous conduct of Wilfred of
+Ivanhoe, who, though sick and maimed, placed his implicit
+faith in the righteousness of his cause and the
+assistance of Divine aid, and the wicked de Bois-Guilbert
+is stricken by a power from on high, because he
+fought upon the side of an unrighteous cause.</p>
+
+<p>From the time that Rebecca offers the gage of battle,
+until the close of this interesting trial, by her tardy
+champion, who hazarded his life in her defense, against
+such fearful odds, in the tilt-yard of Temple stowe, we
+can but see that the author of this humanly interesting
+story had accurately studied the details of these trials
+by battle, as given in the older books.</p>
+
+<p>After the evidence of the witnesses to her sorcery,
+had been taken, the accused demanded her right of
+trial by battle, through the service of a champion, in
+“respect of lawful essoine of her body.” The author
+uses the exact words, given by Glanville, whereby she
+invokes the preliminary delay to prepare for trial. The
+herald opened the court and made announcement of the
+pending issues, in the usual manner; the court was
+regularly adjourned to a day certain for the trial. On
+the appointed day, the details of the trial are presented,
+just as such trials obtained in the courts of chivalry
+and honour of the period depicted. The accused, in the
+presence of the court, was interrogated, from her black
+chair, placed near the funeral pile, as to her readiness<span class="pagenum"><a id="Page_139"></a>[139]</span>
+for the combat. She begged the indulgence, which the
+law granted to her, of a short delay, after invoking the
+aid of Divine wisdom, for her deliverance. Her champion
+appears in true knightly fashion at the last moment
+and after gaining the recognition of the court, and
+permission to do battle for his fair principal, he throws
+the customary words of defiance into the very teeth of
+the false Bois-Guilbert and the battle proceeds, until
+the death of Bois-Guilbert, pronounced by the Court, in
+accordance with the superstition of the times, as a consummation
+devoutly to be wished, because it was, in
+fact, “the judgment of God.”</p>
+
+<p>In “The Fair Maid of Perth,” Scott also describes
+the trial by battle as used to decide the destinies of the
+Clan Quhele and the Clan Chattan, assisted by the volunteer
+Henry Wynd, upon the field of North Inch,
+whereat the whole tribe of the Clan Quhele was annihilated
+in the combat with the race of the “Cat-a-Mountain.”<a id="FNanchor_301" href="#Footnote_301" class="fnanchor">[72]</a></p>
+
+<p>Thackeray had also studied the procedure of trial by
+battle, for he introduces it into his plot in his realistic
+story of “Henry Esmond” and Crockett, in his “Black
+Douglas,” makes the Earl William and James Douglas,
+of Avondale, enter into a legal trial by battle, just as
+the law of Scotland in the fifteenth century governed
+such trials.</p>
+
+<p>But it is not the purpose of this chapter to treat extensively
+of trials by battle, as presented in the literature<span class="pagenum"><a id="Page_140"></a>[140]</span>
+of England, but only to trace the rise, growth and
+decay of this mediaeval institution, as evidenced by the
+law writers of the past and illustrated by the works of
+poetry and fiction, portraying this ancient mode of
+trial, which was superceded by the fairer method of
+jury trial and with the other barbarous customs of the
+dark, misty past, has faded away, with the generations
+that have crept to rest, before the dawn of our modern
+jurisprudence.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_230" href="#FNanchor_230" class="label">[1]</a> Herbert’s Antiquities, pp. 110, 130; Coke, Lyttleton, sec. 294.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_231" href="#FNanchor_231" class="label">[2]</a> Neilson says: “Trial by combat came into existence—no tradition
+knows when.” Neilson’s “Trial by Combat,” p. 1.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_232" href="#FNanchor_232" class="label">[3]</a> 1 Samuel, XVII., 8, 9.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_233" href="#FNanchor_233" class="label">[4]</a> The Mirror (C. 3, Par. 23) states that the trial by battle was
+allowable upon the warranty of the combat between the Shepard
+King of the Israelites and the Giant of the Philistines, but Pope
+Nicholas I. quite seriously decides this precedent to be inconclusive.
+(Decret. Par. 2, Caus. 2, qu. 5, c. 22.)</p>
+
+<p>The belief that the Deity would interfere on the side of the right,
+in these combats, originated with the institution itself, for we are
+told, that when King Gundobald, in the year 501, decreed the trial
+by battle as an antidote to perjury, he replied to the remonstrances
+of the churchmen by the argument that “The event both of national
+wars and private combat is directed by the judgment of God and
+Providence awards the victory to the juster cause.” (II. Gibbon, ch.
+38; Esprit des Lois, book 28, ch. 17; Neilson’s Trial by Combat, p. 6.)</p>
+
+<p>Neilson rejects the suggestion that trial by battle was divinely
+instituted when David, with his Sling, slew the mighty man of
+war of the Philistines, as did Pope Nicholas First, in the year 867.
+Neilson’s “Trial by Combat,” p. 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_234" href="#FNanchor_234" class="label">[5]</a> Velleius Paterculus, ii, ch. 117; Tacitus, Germania, ch. 10;
+Neilson, “Trial by Combat,” p. 4.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_235" href="#FNanchor_235" class="label">[6]</a> Neilson, “Trial by Combat,” p. 10.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_236" href="#FNanchor_236" class="label">[7]</a> Selden, on Duels, ch. 5; Herbert’s “Antiquities of Inns of Court,”
+pp. 109, 115; Bl Com.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_237" href="#FNanchor_237" class="label">[8]</a> Stiernh. de jure Sueon, I. 1. c. 7.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_238" href="#FNanchor_238" class="label">[9]</a> Herbert’s “Antiquities of Inns of Court,” p. 109, 115.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_239" href="#FNanchor_239" class="label">[10]</a> Henrion de Pansey, <i>Auth. Judic.</i> Introd. E. 3.</p>
+
+<p>Some historians trace the origin of trial by battle to the fact that
+perjury became so prevalent that this procedure was resorted to
+to avoid the evil effects of this crime. (I. Pollock and Maitland’s
+History English Law., p. 50.)</p>
+
+<p>It is rather to be accounted for by the fact that it originated in
+the customs of a warlike race, where force and superstition were
+a part of the habits and customs of the people. (Lea. “Superstition
+and Force,” 4 ed. p. 409.)</p>
+
+<p>The Burgundian and Lombard rulers, in accordance with the
+natural fighting tendency of their subjects, were brought to recognize
+the trial by battle, because it combined the physical joy of
+battle with the higher ideals of an approved formal procedure, whereby
+the virtue known as justice was supposed to be attained. In
+other words, the trial by battle was the natural expression of the
+inclinations of both ruler and subject of the period when it was
+established and crept into the established procedure of the period,
+just as naturally as did the superstitions of the past centuries,—the
+belief in witchcraft and ghosts,—find expression along with the
+gems of literature of the same and a later period. The institution
+was a product of the barbarism of the time. And trial by battle was
+recognized as a form of ordeal which obtained among the warlike
+German tribes from very ancient times, but it was not practiced by
+the ancestors of the Anglo-Saxons. (I. Pollock and Maitland’s
+History English Law, p. 51.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_240" href="#FNanchor_240" class="label">[11]</a> Neilson, in speaking of the effect of chivalry, upon the trial
+by battle, observed: “It reached its legal prime in the early feudal
+ages and enjoyed a new era of activity under the auspices of later
+chivalry.” Neilson’s “Trial by Combat.” p. 1.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_241" href="#FNanchor_241" class="label">[12]</a> This is <i>de hors</i> the subject at hand, but demonstrates that chivalry
+and heroism are still abroad in the land and that these virtues
+are confined to no particular class.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_242" href="#FNanchor_242" class="label">[13]</a> 3 Cooley’s Bl. Com. 104; Coke, Litt. 261.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_243" href="#FNanchor_243" class="label">[14]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_244" href="#FNanchor_244" class="label">[15]</a> Comyns Dig. 252.</p>
+
+<p>Neilson states that private duels succeeded trial by battle, in
+the 16’ and 17’ centuries, but of course trial by battle was not
+abolished in England until the year 1819, and duelling had continued
+for several centuries then. (Neilson’s “Trial by Combat,” pp.
+18, 328.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_245" href="#FNanchor_245" class="label">[16]</a> Coke, Litt. 261.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_246" href="#FNanchor_246" class="label">[17]</a> 2 Hawk. P. C. c. 45.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_247" href="#FNanchor_247" class="label">[18]</a> Neilson’s “Trial by Combat,” p. 40.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_248" href="#FNanchor_248" class="label">[19]</a> Coke, III. Inst. 157; I. Russell, Crimes, 495.</p>
+
+<p>That Trial by Battle was introduced into England by the Normans,
+is now quite generally conceded. “One ordeal the Normans recognized
+which had no place in English law, namely, the ordeal of
+battle.” I. Pollock and Maitland’s History Eng. Law, p. 74.</p>
+
+<p>We find that William of Normandy, with his studious desire to preserve
+English institutions and protect Englishmen, in defining the
+procedure which should obtain if a Frenchman accused an Englishman,
+or <i>vice versa</i>, provided that the Englishman whom a Frenchman
+accused had the choice between battle and ordeal, but if the Englishman
+accused the Frenchman, the former had the right to compel the
+latter to join battle, or otherwise the Frenchman could swear away
+the charge, with oath helpers, according to Norman law. The
+Englishman was thus recognized as the Norman’s peer, but as
+was not accustomed to the ordeal by battle, he was given the
+choice of this procedure, if he preferred to avail himself of it, and
+the Norman, by a strict rule of justice, was required to purge
+himself, even though the Englishman would not fight. (Laws of
+William, c. 6; Forschungen, 328; I. Pollock and Maitland’s History
+English Law, pp. 89, 90.)</p>
+
+<p>For reference to the trial by battle, during the reigns of William
+I. to Henry II., see, I. Reeve’s History English Law, pp. 329, 331,
+and note citing the Mirror.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_249" href="#FNanchor_249" class="label">[20]</a> Neilson’s “Trial by Combat,” pp. 188, 189.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_250" href="#FNanchor_250" class="label">[21]</a> II. Pollock and Maitland’s History English Law, p. 632, Bracton,
+fol. 347.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_251" href="#FNanchor_251" class="label">[22]</a> Leg. Hen. 59, sec. 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_252" href="#FNanchor_252" class="label">[23]</a> I. St. Westm. c. 41.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_253" href="#FNanchor_253" class="label">[24]</a> Bracton, fol. 152, 153; Select Pl. Crown, pl. 109, 140, 190, 199.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_254" href="#FNanchor_254" class="label">[25]</a> Neilson’s “Trial by Combat,” pp. 56, 57.</p>
+
+<p>In the class of civil or criminal cases where the right of trial
+by battle obtained, when the plaintiff offered battle, the defendant was
+bound to accept the offer. Having offered to defend the charge
+preferred against him, in legal contemplation, he volunteered to
+defend it with his own body, or with the body of his freeman, “when
+and where the court shall consider that defend he ought.” He then
+tendered his gage and pledges to the court that on the given day
+set, he would perform the task assigned to him. (Year Book, 21, 22,
+II. Edw. I., pp. 9, 167; II. Pollock and Maitland’s History English
+Law, pp. 610, 611.)</p>
+
+<p>The champion, originally, was a witness and it was as such that
+he intervened. In a plea for land, he testified to having seen the
+seisin and that either he or his father saw the claimant in the possession
+of the land. (Neilson’s “Trial by Combat,” p. 48.)</p>
+
+<p>While hired champions were forbidden by the law, it became a
+very common practice and Neilson gives many such contracts in
+his interesting and thorough book, on “Trial by Combat,” pp. 48,
+54.</p>
+
+<p>Maynard’s Year Books, contain the history of many trials occurring
+during the reigns of Edward III. and Henry VI. The report
+of one such trial, in the year 1329, describes the champions
+as appearing with shaven heads, ungirt coats, bare legged and bare
+armed, tendering a glove, with a penny in each finger, to the judge,
+who afterwards offered the pennies on the altar of the nearest
+church, in order that “God might give the victory to him who was
+in the right.” (Maynard’s Year Books, I. Henry VI., pp. 6, 7; <i>idem.</i>
+21 Henry VI., pp. 19, 20.)</p>
+
+<p>As the pugilists of the present day, have managers, who conduct
+the combats between the champions for the wager of the ringside,
+so men of the thirteenth century kept pugilists for hire, whose
+services were quite generally used in these trials. One of these
+champions was Richard of Newnham, whose master, or manager,
+was William of Cookham (Note Book, pl. 185, 400, 551), whose
+expert services were much in demand about the year 1220.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_255" href="#FNanchor_255" class="label">[26]</a> Neilson’s “Trial by Combat,” p. 40; Maddox, 71, 66, 311, 349, 379.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_256" href="#FNanchor_256" class="label">[27]</a> III. Reeve’s History English Law, p. 329.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_257" href="#FNanchor_257" class="label">[28]</a> 22 Edward IV., 19; IV. Reeve’s History English Law, p. 58.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_258" href="#FNanchor_258" class="label">[29]</a> 37 Henry VI. 20; IV. Reeve’s History English Law, p. 58.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_259" href="#FNanchor_259" class="label">[30]</a> II. Pollock and Maitland’s History English Law, p. 214.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_260" href="#FNanchor_260" class="label">[31]</a> Herbert’s “Antiquities of Inns of Court,” p. 130.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_261" href="#FNanchor_261" class="label">[32]</a> Neilson’s “Trial by Combat,” p. 46.</p>
+
+<p>Clergymen were exempted from the trial by battle and by 41
+Edward III., an appellant, on entering the field of battle could avoid
+the fight, by praying his clergy. (Herbert’s “Antiquities of the Inns
+of Court,” 130.)</p>
+
+<p>By the Charter of London, the following citizens were also exempted
+from trial by battle, <i>viz.</i>, <i>sexagenarii</i>, or men of three
+score years; <i>coecus</i>, or those blind by accident after issue joined.
+(<i>Ante idem.</i>)</p>
+
+<p>The exemption granted by Henry I., by the Charter of London,
+was followed by many other similar exemptions. Newcastle-on-Tyne,
+Norwich, Oxford and Winchester, soon followed and almost
+every borough strove to procure like exemptions. (Stubbs’ Charters,
+Thompson’s English Mun. History.)</p>
+
+<p>Mayhem was a good ground for exemption from trial by combat.
+Crown Pleas, No. 4, 9; Bracton, ii, 458, 468; Glanville, XIV., ch. I;
+Neilson’s “Trial by Combat,” 46.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_262" href="#FNanchor_262" class="label">[33]</a> Beames Glanville, pp. 36, 41; Herbert’s “Antiquities of the Inns
+of Court,” pp. 110, 115.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_263" href="#FNanchor_263" class="label">[34]</a> An <i>essoin</i> is defined by Sir Edward Coke as an excuse, the
+term being taken from the French verb, <i>essonier</i>, or <i>exonier</i>. The
+term was introduced into England by the Normans. Note to Beame’s
+Glanville, p. 6.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_264" href="#FNanchor_264" class="label">[35]</a> Beames, Glanville, p. 41; Herbert’s “Antiquities of Inns of
+Court,” 115.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_265" href="#FNanchor_265" class="label">[36]</a> Selden, impr. Duello, Lond. 1610; Herbert’s “Antiquities of the
+Inns of Court,” pp. 115, 117; Select Pleas of Crown, Pl. 87; II.
+Pollock and Maitland’s History English Law, p. 634.</p>
+
+<p>During the twelfth century, in controversies between the Lord
+paramount and the tenant as to the right to the possession of real
+estate, the duel or battle was a method of trial generally in vogue.
+In the reign of Henry II., while the tenant, in a writ of right, had
+his election to defend his title by duel, “as a royal benefit conferred
+on the nation, by the prince in his clemency, by the advice
+of his nobles, as an expedient whereby the lives and interests of his
+subjects might be preserved, and their property and rights enjoyed
+<i>without being any longer obliged to submit to the doubtful chance
+of the duel</i>,” we find the institution of the <i>assize</i> guaranteed to the
+subjects by the king, and this constitution is perhaps the first
+guaranty of the trial by jury in the English law. (Glanv. lib. 2,
+c. 4, 5, 6; I. Reeve’s History Eng. Law, pp. 393, 395.)</p>
+
+<p>The proceeding for the recovery of land during the reign of
+Henry II. and preceding reigns, is not without interest. The claim
+of the demandant, or claimant, was based only upon evidence <i>de
+visu et auditu</i>, or by the proof furnished by his freeman, whose
+evidence was either as to what he had actually seen and knew, or
+upon what his father had told him, and had enjoined upon him,
+on his death-bed, by the faith that a son owed to a father, which
+he was to assert, if he ever heard of any plea being urged as to
+the land in controversy. (Glanv. lib. 2, c. 3.)</p>
+
+<p>If the tenant elected to try the issue by the duel, or battle, he
+could not afterwards resort to the assize, but must meet the issue
+<i>de verbo in verbam</i>, as the demandant, or claimant had asserted his
+title. The demandant could not be his own champion, but the
+tenant could defend himself, either in person or by a champion, and
+after the customary essoins, the battle proceeded. If the champion
+of the demandant was conquered, the demandant lost his suit and
+the champion was never again a competent witness in a duel. If
+the champion of the tenant, or the tenant himself was conquered,
+he lost the land with all the fruits and produce on it, and he was
+never afterwards to be heard in a court of justice concerning the
+same. In other words, the final effect of a trial by battle was as
+conclusive as the judgment of a court of competent jurisdiction
+and furnished the basis for a good plea of <i>res adjudicata</i> in all
+subsequent controversies over the same land in the future, between
+the same parties. (Glanv. lib. 2. c. 4, 5; I. Reeve’s History Eng.
+Law, p. 394.)</p>
+
+<p>Neilson complains because neither Glanville, Bracton, Britton,
+nor Fleta, describe the procedure governing the actual fighting of
+the duel in an English plea for land under a “writ of right.” (Neilson’s
+“Trial by Combat,” p. 86.) The above description of such a
+combat, is deemed accurate, from sources consulted and for the
+authorities consulted, the reader is referred to Herbert’s “Antiquities
+of the Inns of Courts,” pp. 115, 117.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_266" href="#FNanchor_266" class="label">[37]</a> Selden, Duello, impr. Lond. 1610; Mich. 6 R. I. ret. 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_267" href="#FNanchor_267" class="label">[38]</a> This is a quotation from an old manuscript book, belonging to
+Sir Edw. Windham, knight, Marshal of the Camp, to King Henry
+VIII. See, Herbert’s “Antiquities of the Inns of Court,” pp. 119, 131.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_268" href="#FNanchor_268" class="label">[39]</a> Coke, Litt. 287; 4 Shars. Bl. Comm. 312, 318, and notes.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_269" href="#FNanchor_269" class="label">[40]</a> Neilson’s “Trial by Combat,” p. 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_270" href="#FNanchor_270" class="label">[41]</a> Livy, book I., ch. 24, book 28, ch. 21.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_271" href="#FNanchor_271" class="label">[42]</a> Geoffrey of Monmouth, lx, ch. II; Neilson’s “Trial by Combat,”
+p. 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_272" href="#FNanchor_272" class="label">[43]</a> Neilson’s “Trial by Combat,” p. 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_273" href="#FNanchor_273" class="label">[44]</a> If this procedure obtained today, it would have a wholesome
+effect, in some of the disgraceful controversies in our divorce courts.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_274" href="#FNanchor_274" class="label">[45]</a> Lea, “Superstition and Force,” (4 ed.) 120.</p>
+
+<p>Thayer states that the earliest reference to the trial by battle
+in English adjudicated cases, is that of Bishop Wulfstan vs. Abbot
+Walter, in the year 1077. (Essays in Anglo-Saxon Law, 379; Bigelow’s
+Placita Anglo-Normanica, 19; Brunner, Schw. 197, 400-1;
+Thayer’s Older Modes of Trial, V. Harvard Law Review, 66; II.
+Essays in Anglo-American Legal History, 397.)</p>
+
+<p>The history of cases of trial by battle that were preserved, in
+England, prior to Glanville’s time, are to be found in Bigelow’s
+Placita Anglo-Normanica.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_275" href="#FNanchor_275" class="label">[46]</a> I. Ancient Laws England, 494; Neilson’s “Trial by Combat,”
+p. 59.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_276" href="#FNanchor_276" class="label">[47]</a> Carlyle’s “Past and Present,” book II., ch. 14; Jocelin of Brakelond’s
+Chronicle, p. 52; Neilson’s “Trial by Combat,” pp. 61, 62.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_277" href="#FNanchor_277" class="label">[48]</a> Neilson’s “Trial by Combat,” pp. 43, 44.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_278" href="#FNanchor_278" class="label">[49]</a> Galfridus le Baker, 208, 210; Walsingham, i, 275; Myrick, ii,
+32; Neilson’s “Trial by Combat,” pp. 168, 170.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_279" href="#FNanchor_279" class="label">[50]</a> Hall, 4; Adam of Usk, 131; Trekolowe, 225; Neilson’s “Trial
+by Combat,” pp. 190, 193.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_280" href="#FNanchor_280" class="label">[51]</a> IV. Coke, Littleton, ed. 1817, ch. 17.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_281" href="#FNanchor_281" class="label">[52]</a> John Stowe’s Survey, iii, 239, 371; Neilson’s “Trial by Combat,”
+199.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_282" href="#FNanchor_282" class="label">[53]</a> Gregory, 187; Nichols’ “Illustrations of Manners,” (1797) p.
+217; John Stowe, 385; Neilson’s “Trial by Combat,” p. 201.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_283" href="#FNanchor_283" class="label">[54]</a> Gregory, 199, 200; Neilson’s “Trial by Combat,” pp. 154, 157.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_284" href="#FNanchor_284" class="label">[55]</a> John Stowe, 475; Neilson’s “Trial by Combat,” pp. 203, 204.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_285" href="#FNanchor_285" class="label">[56]</a> Afterwards a battle occurred in the court of chivalry, in 1631.
+(Rushw. Coll. vol. II., part 2, fol. 112; 19 Rym. 322.) And another
+in the county palatine of Durham, in 1638. (Cro. Car. 512.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_286" href="#FNanchor_286" class="label">[57]</a> Dyer, 301.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_287" href="#FNanchor_287" class="label">[58]</a> Spelman’s Gloss (<i>sub voc.</i> Campus, 1625), 102.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_288" href="#FNanchor_288" class="label">[59]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_289" href="#FNanchor_289" class="label">[60]</a> I. Barn. &amp; Ald. 405.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_290" href="#FNanchor_290" class="label">[61]</a> I. Barn. &amp; Ald. 405; 3 Shars. Bl. Comm. 339; 4 <i>idem.</i> 347.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_291" href="#FNanchor_291" class="label">[62]</a> Grandes Chroniques de France, M. Paulin, Paris, vol. IV., pp.
+427, 430; Brunner, Schw. 297; “Older Modes of Trials,” by Thayer,
+V. Harvard Law Rev., p. 67; II. Essays in Anglo-American Legal
+History, note, p. 398.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_292" href="#FNanchor_292" class="label">[63]</a> Stephens’ History Criminal Law, in England; Neilson’s “Trial
+by Combat,” p. 319.</p>
+
+<p>The reader, interested in following the many illustrations of the
+trial by combat, in individual instances occurring at various periods
+during the centuries from 1100 to 1600, in Scotland, will find
+copious references to such trials, in Neilson’s “Trial by Combat.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_293" href="#FNanchor_293" class="label">[64]</a> For full explanation of the different legal phases presented in
+this poem, see, Neilson’s “Trial by Combat,” pp. 180, 188.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_294" href="#FNanchor_294" class="label">[65]</a> See White’s “Law in Shakespeare,” for full discussion of this
+and other scenes on “Trial by battle,” as used by Shakespeare.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_295" href="#FNanchor_295" class="label">[66]</a> King Richard II., Act I., scenes I. and III.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_296" href="#FNanchor_296" class="label">[67]</a> King Richard II., Act IV., Scene I.</p>
+
+<p>The dramatic quarrel between Henry, earl of Hereford (afterward
+King Henry IV.) and the Duke of Norfolk, presented by
+Shakespeare in his play, Richard II., is described by a graphic
+writer in Herbert’s “Antiquities,” pp. 145, 146.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_297" href="#FNanchor_297" class="label">[68]</a> King Richard II., Act IV., Scene I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_298" href="#FNanchor_298" class="label">[69]</a> Act IV., Scene I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_299" href="#FNanchor_299" class="label">[70]</a> Act I., Scene III., and Act II., Scene III.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_300" href="#FNanchor_300" class="label">[71]</a> King Lear, Act V., Scene III.</p>
+
+<p>For exposition of the above portions of Shakespeare’s plays, dealing
+with “Trial by Battle,” see, White’s “Law in Shakespeare,” Sec.
+191, pp. 229, 232.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_301" href="#FNanchor_301" class="label">[72]</a> The combat between the Clan Chattan and Clan Kay, on the
+Inch of Perth, made memorable by this great novelist, actually
+occurred in the year 1396. (Neilson’s “Trial by Combat,” 239; 244;
+250; Bower, xv, ch. 3.)</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_141"></a>[141]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_V">CHAPTER V.<br>
+<span class="smcap">Trial by Ordeal.</span></h2>
+
+</div>
+
+<p>Trial by ordeal was the method used to ascertain the
+guilt or innocence of a person accused of crime, according
+to his ability to perform certain acts, or accomplish
+results which would, in the ordinary course of events,
+be hurtful to him.<a id="FNanchor_302" href="#Footnote_302" class="fnanchor">[1]</a></p>
+
+<p>If the suspected criminal was injured or killed in the
+performance of the act required of him, he was adjudged
+guilty, but if he performed the part assigned to
+him without injury, he was declared innocent. The
+tests that the suspected person was subjected to were
+called ordeals,<a id="FNanchor_303" href="#Footnote_303" class="fnanchor">[2]</a> or judgments of God.</p>
+
+<p>The custom of referring disputed questions such as
+the guilt or innocence of a person accused of crime, to
+the judgment of God, to be determined either by lot,
+or the success of certain dangerous experiments, has
+existed, from the earliest times, among various widely
+separated nations and peoples.<a id="FNanchor_304" href="#Footnote_304" class="fnanchor">[3]</a></p>
+
+<p>We find that according to the “law of jealousies,”
+laid down in the Mosaic code Fifteen hundred years before
+Christ, the guilt of a woman, accused of infidelity,
+by her husband, was determined according to this trial
+of ordeal, for it is recorded:</p>
+
+<div class="blockquote">
+
+<p>“And the spirit of jealousy come upon him, and he
+be jealous of his wife, and she be defiled; or if the<span class="pagenum"><a id="Page_142"></a>[142]</span>
+spirit of jealousy come upon him and he be jealous of
+his wife, and she be not defiled; then shall the man
+bring his wife unto the priest....</p>
+
+<p>And the priest shall charge her by an oath, and say
+unto the woman, If no man have lain with thee, and if
+thou hast not gone aside to uncleanness; with another,
+instead of thy husband, be thou free from this bitter
+water, that causeth the curse: ...</p>
+
+<p>And he shall cause the woman to drink the bitter
+water that causeth the curse; and the water that causeth
+the curse shall enter into her, and become bitter....</p>
+
+<p>And when he hath made her to drink the water, then
+it shall come to pass that, if she be defiled, and have
+done trespass against her husband, that the water that
+causeth the curse shall enter into her and become bitter,
+and her belly shall swell and her thigh shall rot; and
+the woman shall be a curse among her people.</p>
+
+<p>And if the woman be not defiled, but be clean, then
+shall she be free, and shall conceive seed.”<a id="FNanchor_305" href="#Footnote_305" class="fnanchor">[4]</a></p>
+
+</div>
+
+<p>Compurgation of accused persons, by fire, existed
+among the ancient Greeks,<a id="FNanchor_306" href="#Footnote_306" class="fnanchor">[5]</a> and the Hindus practiced<span class="pagenum"><a id="Page_143"></a>[143]</span>
+ordeal in nine different ways,—by the balance, by fire,
+by water, by poison, by the <i>cosha</i>, or drinking water,
+in which the images of the sun and other deities had
+been washed, by chewing rice, by hot oil, by red hot
+iron, and by drawing two images out of a jar, into
+which they had been thrown.<a id="FNanchor_307" href="#Footnote_307" class="fnanchor">[6]</a></p>
+
+<p>The most generally used ordeals throughout ancient
+Europe were: Trial by battle, in which the vanquished
+one was adjudged guilty; trial by the ordeal of fire;
+trial by water; trial by the corsned; the trial of the
+eucharist; the trial by the cross and the test by judgment
+of the bier.</p>
+
+<p>In trial by battle, the accuser and accused fought
+in mortal combat to determine the guilt or innocence of
+the suspected person.<a id="FNanchor_308" href="#Footnote_308" class="fnanchor">[7]</a> In the trial by fire, the accused
+walked bare-footed, over red hot plow-shares, or coals
+of fire,<a id="FNanchor_309" href="#Footnote_309" class="fnanchor">[8]</a> carried a red hot iron in his hand, or walked
+through flames, clad in a suit of wax, spread over
+woolen cloth, known as the “trial of the waxen shirt,”
+because if he was unhurt by the fire and the wax was
+unmelted, he was considered innocent, but otherwise
+was adjudged guilty.<a id="FNanchor_310" href="#Footnote_310" class="fnanchor">[9]</a></p>
+
+<p>The trial by water was either by cold or boiling
+water. If the former, which was the test usually applied
+to witches, the guilt was determined by the ability
+of the accused to float or sink, when cast into the
+water.<a id="FNanchor_311" href="#Footnote_311" class="fnanchor">[10]</a> Where the ordeal by boiling water was used,
+the accused had to take a stone out of boiling water, by<span class="pagenum"><a id="Page_144"></a>[144]</span>
+inserting his hand into a caldron, containing boiling
+water, as deep as his wrist, and if the triple ordeal was
+used, the boiling water was deepened so that he had to
+insert his arm as far as the elbow to get the stone.<a id="FNanchor_312" href="#Footnote_312" class="fnanchor">[11]</a></p>
+
+<p>In the <i>offa execrata</i>, or corsned ordeal, a priest put
+the corsned or hallowed cheese and bread, in the mouth
+of the accused, with various chants and imprecations
+and if he swallowed it, he was freed from the judgment,
+but if it stuck in his throat, he was held to be proven
+guilty of the offense with which he was charged.<a id="FNanchor_313" href="#Footnote_313" class="fnanchor">[12]</a></p>
+
+<p>The test of the eucharist was chiefly applied among
+the monks and clergy, for it was believed that when
+they took the test, God would smite the guilty, with
+sickness or death.<a id="FNanchor_314" href="#Footnote_314" class="fnanchor">[13]</a></p>
+
+<p>In the ordeal of the cross, the accuser and accused
+were placed under the cross, with their arms extended,
+and the one whose hands moved first was adjudged to
+be the guilty one and the other the innocent. A trial
+by lot, similar to this latter ordeal, occurred when the
+accused was placed before certain relics with two dice
+before him, one of which was marked with a cross. If
+the cross was selected, at hazard, he was acquitted, but
+otherwise was adjudged guilty.<a id="FNanchor_315" href="#Footnote_315" class="fnanchor">[14]</a></p>
+
+<p><span class="pagenum"><a id="Page_145"></a>[145]</span></p>
+
+<p>And finally, the ordeal known as the judgment of the
+bier was used to determine the guilt of the accused,
+under a charge of murder. The deceased, supposed to
+have been murdered, was placed upon a bier, and the
+accused was made to touch his body. If blood flowed,
+or foam appeared in the mouth of the murdered person,
+or the body changed position, the accused was adjudged
+guilty of the murder, but if none of these signs appeared,
+he was acquitted.<a id="FNanchor_316" href="#Footnote_316" class="fnanchor">[15]</a></p>
+
+<p>According to the Institute of Narada,<a id="FNanchor_317" href="#Footnote_317" class="fnanchor">[16]</a> the ordeal
+was used four or five centuries before Christ, in India,
+for we find that the balance, fire, water, poison and the
+sacred libation, were considered the five divine tests,
+for determining the guilt or innocence of suspected persons.</p>
+
+<p>From the formulas given in the Institute of Narada,
+the most solemn ceremonies accompanied the application
+of the tests used in the trials by ordeal, in India, in
+ancient days. In describing the different tests, it is said:</p>
+
+<div class="blockquote">
+
+<p>“Having adjured the balance by imprecation, the
+judge should cause the accused to be placed in the
+balance again. ‘O balance, thou only knowest what
+mortals do not comprehend. This man, being arraigned<span class="pagenum"><a id="Page_146"></a>[146]</span>
+in a cause, is weighed upon thee. Therefore mayst
+thou deliver him lawfully from his perplexity.’ ...
+If the individual increased in weight, he was adjudged
+guilty; if he was found to be lighter or equal
+in weight, his innocence was established.</p>
+
+<p>In the ordeal of fire, the judge thus addressed the
+fire: ‘Thou, O fire, dwellest in the interior of all creatures,
+like a witness. Thou only knowest what mortals
+do not comprehend. This man is arraigned in a cause
+and desires acquittal. Therefore, mayst thou deliver
+him lawfully from his perplexity.’ ... Seven
+circles of fire, with a diameter of a foot each and thirty-two
+inches distant from each other were marked on the
+ground, and the man, having fasted and cleansed himself,
+has seven <i>acvattha</i> leaves fastened on his hands
+and he takes a smooth ball of red hot iron in his hands
+and walks slowly through the seven circles of fire and
+deposits the ball on the ground. If he is burnt, he is
+adjudged guilty, but if he is unburnt, he is declared innocent.</p>
+
+<p>In the ordeal of water, the judge adjures the water,
+as in the preceding tests, by the balance and by fire,
+and the accused wades into water to his waist, while
+another shoots an arrow. The accused dives into the
+water and if he remains under while a swift runner returns
+the arrow, he is innocent, but otherwise is adjudged
+guilty.</p>
+
+<p>In the poison ordeal, after the selection of the particular
+poison the judge thus adjures the poison: ‘Thou,
+O poison, art the son of Brahma,<a id="FNanchor_318" href="#Footnote_318" class="fnanchor">[17]</a> thou are persistent
+in truth and justice; relieve this man from sin and by
+thy virture become an ambrosia to him. On account of
+thy venomous and dangerous nature, thou art the destruction
+of all living creatures; thou art destined to
+show the difference between right and wrong, like a
+witness.’ The accused person eats the poison and if it
+easily digested, without violent symptoms, the king<span class="pagenum"><a id="Page_147"></a>[147]</span>
+shall recognize him as innocent, and dismiss him, after
+having honored him, with presents.</p>
+
+<p>In the ordeal of sacred libation, the judge should give
+the accused water in which an image of that deity to
+whom he is devoted, has been bathed, thrice calling out
+the charge, with composure. One to whom any misfortune
+or calamity happens, within a week, or a fortnight,
+is proved to be guilty.”<a id="FNanchor_319" href="#Footnote_319" class="fnanchor">[18]</a></p>
+
+</div>
+
+<p>Charlemagne apparently did not place much dependence
+in the <i>judicium Dei</i>, by means of the ordeal, at the
+beginning of his reign, for in 779, by his edict the trial
+by ordeal was to be used in the more trifling offenses,
+while cases of greater magnitude were to be tried by the
+civil law of the realm.<a id="FNanchor_320" href="#Footnote_320" class="fnanchor">[19]</a></p>
+
+<p>Later on in his reign, however, by his edicts of the
+year 806 and 809 this monarch seems to have come to<span class="pagenum"><a id="Page_148"></a>[148]</span>
+regard the ordeal with much greater favor, for he frequently
+referred to this method of trial; when dividing
+up his empire between his sons he directed that all disputes
+should be settled by ordeal, and endeavored to
+force a greater regard for the judgments in trials by
+ordeal, on the part of the subjects, whom, it seems,
+had come to entertain his own early distrust in this
+species of trials.<a id="FNanchor_321" href="#Footnote_321" class="fnanchor">[20]</a></p>
+
+<p>It seems that Charlemagne completely believed in
+the efficacy of the ordeal, by the year 794, for we are
+told that in this year, a certain Bishop Peter, who was
+condemned by the Synod of Frankfort to clear himself
+of the suspicion of complicity in a conspiracy of treason
+against Charlemagne, being unable to obtain conjurators,
+one of his vassals offered to attempt the test of
+the ordeal, as his proxy, and on his success, the Bishop
+was adjudged innocent of the charge and was reinstated.<a id="FNanchor_322" href="#Footnote_322" class="fnanchor">[21]</a></p>
+
+<p>Soon after the death of Charlemagne, in the year
+816, Louis-le-Debonnaire, at the Council of Aix-la-Chapelle,
+prohibited the continuance of the ordeal of the
+cross,<a id="FNanchor_323" href="#Footnote_323" class="fnanchor">[22]</a> because it had a tendency to bring the Christian
+symbol into contempt and his son, the Emperor Lothair
+also issued a similar edict against the use of this ordeal,
+after he assumed the reigns of government.<a id="FNanchor_324" href="#Footnote_324" class="fnanchor">[23]</a></p>
+
+<p>Among the early Saxons, the ordeals by fire and<span class="pagenum"><a id="Page_149"></a>[149]</span>
+water were practiced, for we find that the <i>ordale</i> signified
+<i>judicium aequum, justum, indifferens</i>, “an upright,
+just and indifferent judgment.”<a id="FNanchor_325" href="#Footnote_325" class="fnanchor">[24]</a></p>
+
+<p>Tacitus tells us that the ancestors of our Saxon forefathers,
+during pagan times, were addicted to divination
+and risked certain results upon the flying of birds,
+the neighing of horse and trial by combat.<a id="FNanchor_326" href="#Footnote_326" class="fnanchor">[25]</a> And
+trial by ordeal was used by them in both civil and criminal
+cases, to determine the issues later solved by the
+testimony of witnesses, or the oaths of compurgators.<a id="FNanchor_327" href="#Footnote_327" class="fnanchor">[26]</a></p>
+
+<p>The ordeal of hot water appears in the laws of Ine,<a id="FNanchor_328" href="#Footnote_328" class="fnanchor">[27]</a>
+who began his reign in the year 710, and the ordeals by
+fire and water had become so common by the time of
+King Athelstan, that we find the procedure governing
+such trial, fully covered by his Constitutions,<a id="FNanchor_329" href="#Footnote_329" class="fnanchor">[28]</a> by
+which they were considered in the light of religious
+ceremonies:</p>
+
+<div class="blockquote">
+
+<p>“Concerning ordeal, we command, in the name of
+God, and by the precept of our archbishops and bishops,
+that no man enter into the church after the fire is
+brought in, wherewith the judgment is to be made hot,
+except the priest, and he who is to undergo the trial;
+and let there be measured nine feet from the stake unto
+the mark, according to the measure of the foot, who is
+to come thus to judgment.</p>
+
+<p>And if the trial be by water, let it be made hot, till it
+boil, in a vessel of iron, brass, lead, or clay; and if it
+be single, let his hand be put therein after a stone or<span class="pagenum"><a id="Page_150"></a>[150]</span>
+stock up to his wrist; but if the accusation be threefold,
+then to his elbow; and when the judgment shall be prepared,
+let two men be brought in on either side, to make
+experiment, that it be as hot as is afore expressed.</p>
+
+<p>Let as many also come in on each side the judgment,
+along the church; and let them be fasting and abstain
+from their wives that night; and the priest shall
+sprinkle holy water on them, and give them the text of
+the holy gospel to kiss, as also the sign of the cross;
+and no man shall make the fire any longer than whilst
+the benediction beginneth, but shall cast the iron upon
+the coals until the last collect; afterwards it shall be put
+upon the <i>ceac</i> (cauldron)<a id="FNanchor_330" href="#Footnote_330" class="fnanchor">[29]</a> without any more words,
+then that they pray earnestly to God that he will vouch
+safe to manifest the truth therein; then shall the person
+accused drink holy water and his hand wherewith he
+shall carry the judgment shall be sprinkled therewith;
+and so let him go, the nine feet measured being distinguished
+by three and three.</p>
+
+<p>At the first mark next to the stake, he shall set his
+right foot and at the second his left foot; and thence he
+shall remove his right foot unto the third mark, where
+he shall throw down the iron and hasten to the holy altar;
+which done, his hand shall be sealed up, and the
+third day after viewed, whether it be clean or unclean
+where it was so sealed. And he who shall transgress
+these laws, let the ordeal judgment or trial be done
+upon him, that he pay 120 s. for a fine or mulct.”<a id="FNanchor_331" href="#Footnote_331" class="fnanchor">[30]</a></p>
+
+</div>
+
+<p>For three days before the trial, the accused was to
+attend the priest, to be constant at mass, to make his
+offering and in the interim, to sustain himself on nothing
+but bread, salt, water and onions. On the day of
+the trial he was to take the sacrament and swear he was
+not guilty of the crime imputed to him. The accuser
+and accused both came to the place of trial, with not<span class="pagenum"><a id="Page_151"></a>[151]</span>
+more than twelve persons each, to stay any interposition
+or violence and the accuser then renewed his charge
+upon oath and the accused made his purgation on oath
+also. If the ordeal was by hot water, he put his wrist
+or arm into the boiling water, accordingly whether it
+was the simple or triple test, and if the trial was by
+cold water, his thumbs were tied to his toes and he was
+cast into the water. If he escaped the boiling water unhurt,
+or sank in the cold water, he was adjudged innocent,
+but if he was burned by the hot water, or swam in
+the cold water, he was adjudged guilty, as charged by
+his accuser.<a id="FNanchor_332" href="#Footnote_332" class="fnanchor">[31]</a></p>
+
+<p>These trials by water and fire were called <i>judicium
+Dei</i>, or, as the Mirror of Justice puts it, miracles of
+God, but “Christianity suffered not that they be by such
+wicked arts cleared, if one may otherwise avoid it.”<a id="FNanchor_333" href="#Footnote_333" class="fnanchor">[32]</a></p>
+
+<p>From this observation in the Mirror, it has been contended
+that the Anglo-Saxons distinguished between
+open and manifest offenses and those not so public as
+to be susceptible of proof and that trial by ordeal was
+only used in the latter class of crimes.<a id="FNanchor_334" href="#Footnote_334" class="fnanchor">[33]</a></p>
+
+<p>It is true that in Alfred’s time there were trials by
+jury, and it seems that trial by ordeal may have been
+re-established, after trial by jury, in doubtful cases,
+as a refuge or solution of an otherwise doughty problem
+for the barbarian mind to solve.<a id="FNanchor_335" href="#Footnote_335" class="fnanchor">[34]</a></p>
+
+<p><span class="pagenum"><a id="Page_152"></a>[152]</span></p>
+
+<p>Pursuance to the terms of a certain league, made between
+Edward the Elder and Guthrun, the Dane, ordeals
+were forbidden upon festivals or fasting days<a id="FNanchor_336" href="#Footnote_336" class="fnanchor">[35]</a>
+and the same provision was inserted in the constitution
+made by the synod held at Eanham, under King Ethelred.<a id="FNanchor_337" href="#Footnote_337" class="fnanchor">[36]</a></p>
+
+<p>The laws of Canute and Edward the Confessor also
+contained provisions forbidding trials by ordeal upon
+festivals or fasting days, for we read that the <i>judicium
+Dei</i>, upon these auspicious occasions, was to be postponed,
+until the affairs of mortals could be better arranged
+for its reception, by the following provision:<a id="FNanchor_338" href="#Footnote_338" class="fnanchor">[37]</a></p>
+
+<div class="blockquote">
+
+<p>“We forbid ordeals and oaths” (the name law trials
+at that time were called) “on feast days and ember
+days, and from the advent of our Lord till the eighth
+day after twelfth be past; and from Septuagesima till
+fifteen nights after Easter. And the sages have ordained
+that St. Edward’s day shall be festival all England
+on the fifteenth cal. of April, and St. Dunstan’s,
+on the fourteenth cal. of June; and that all Christians,
+as right it is, should keep them hallowed and in peace.”</p>
+
+</div>
+
+<p>In the simple ordeal, of the Anglo-Saxons, the hot
+iron weighed one pound and in the triple ordeal, it was
+to weigh three pounds. The triple ordeal was used in
+the crimes of arson and murder, treason and forgery.<a id="FNanchor_339" href="#Footnote_339" class="fnanchor">[38]</a></p>
+
+<p>In the laws of Edward the Elder, perhaps the earliest
+reference in Anglo-Saxon laws, to the ordeal, it was<span class="pagenum"><a id="Page_153"></a>[153]</span>
+provided that perjured persons, or those once convicted
+should not thereafter be deemed oath-worthy, but
+on their accusation, should be hurried to the ordeal,<a id="FNanchor_340" href="#Footnote_340" class="fnanchor">[39]</a>
+and similar provisions are to be found in the laws of
+Ethelred, Cnut and Henry I.<a id="FNanchor_341" href="#Footnote_341" class="fnanchor">[40]</a></p>
+
+<p>Trial by ordeal at first carried with it the sanction of
+the priest, as well as the civil power and the clergy continued
+to approve and interject the spiritual portion of
+the proceeding, until the early portion of the thirteenth
+century.<a id="FNanchor_342" href="#Footnote_342" class="fnanchor">[41]</a> Under the law of William the Conqueror,
+the conduct of the ordeal, as a known ecclesiastical procedure,
+was declared to be the business of the bishop,
+but the civil and spiritual powers were to co-operate
+harmoniously, in the trial by ordeal, the court of the
+hundred making the original order by which a man was
+sent to the ordeal of fire or water, but the bishop presided
+at the ceremony and regulated the course of the
+proceeding, in accordance with the solemn religious
+ceremony, whereby the element used was blessed and
+the Divine Wisdom of Omnipotence was invoked to the
+conclusion of the whole proceeding.<a id="FNanchor_343" href="#Footnote_343" class="fnanchor">[42]</a></p>
+
+<p>The Normans were attached to the procedure, elsewhere
+discussed, as the <i>trial by battle</i> and they did not
+relish a procedure which seemed to them to be a mere
+superstitious formality, fit only for women and old
+or maimed men. However, ever since the reign of Ina,<span class="pagenum"><a id="Page_154"></a>[154]</span>
+the Saxons had been accustomed to the ordeal and the
+laws of Ina and later monarchs continued in effect, and
+the accused person was entitled to select the ordeal of
+hot iron, or that of hot water and to undergo, under the
+supervision of the priest or bishop, a trial, to determine
+his guilt or innocence of the offense charged.<a id="FNanchor_344" href="#Footnote_344" class="fnanchor">[43]</a></p>
+
+<p>In the year 1166, in the Assize of Clarendon, and
+again in the year 1176, in the Assize of Northampton,
+Henry II. provided for a public mode of accusation for
+the capital felonies and trial by ordeal was the method
+of procedure fixed to determine the guilt or innocence
+of the person charged.<a id="FNanchor_345" href="#Footnote_345" class="fnanchor">[44]</a></p>
+
+<p>Prior to the thirteenth century perjury was so common
+and it was so impossible to avoid the effects of a
+false oath, by the proceedings of men, that the Laws of
+Henry provided that “No one is to be convicted of a
+capital crime by testimony.”<a id="FNanchor_346" href="#Footnote_346" class="fnanchor">[45]</a> Mere human testimony
+was not enough to send a man to the gallows, but one
+accused of a capital offense was to be entitled to one
+of the old-world sacred processes, wherein the <i>judicium
+Dei</i>, was supposed to take the place of the false standards,
+too often erected by ordinary mortals. The ordeal
+was then so far “the law of the land” that one
+accused of a capital offense, who refused the ordeal,
+could be executed, as an outlaw, because he had thus
+defied the law of the realm. But one who had not been
+accorded this “law of the land,” based upon the sacred<span class="pagenum"><a id="Page_155"></a>[155]</span>
+and Divine belief in the infallibility of the test of ordeal,
+could not legally be condemned, as trial by jury
+or by the oaths of witnesses was not yet an accredited
+method of procedure in cases of capital offense.<a id="FNanchor_347" href="#Footnote_347" class="fnanchor">[46]</a></p>
+
+<p>Glanville tells us that in his time, about the year 1187,
+an accused person, who was so far disabled by mayhem
+that he could not test his guilt or innocence by the ordeal
+of battle, was entitled to the ordeal of fire or water,
+to determine his guilt or innocence, this author of the
+first law book observing:<a id="FNanchor_348" href="#Footnote_348" class="fnanchor">[47]</a></p>
+
+<div class="blockquote">
+
+<p>“In such case, the Accused is obliged to purge himself
+by the Ordeal, that is, by the hot Iron, if he be a
+free Man—by water, if he be a Rustic.”</p>
+
+</div>
+
+<p>This corresponds with the statement elsewhere made,
+that in the early use of this trial, the hot iron ordeal,
+was confined to the nobility, or patricians, while the
+water ordeal was generally used among the common
+people, accused of minor offenses or other than the
+capital felonies.<a id="FNanchor_349" href="#Footnote_349" class="fnanchor">[48]</a></p>
+
+<p>By the latter part of the twelfth century, the ordeal
+had become so discredited, in the time of Henry II. that
+the law of that reign provided that any one charged before
+the king’s justices with the crime of murder, theft,
+robbery, or the receipt of such offenders, or of arson,
+or forgery, by the oaths of twelve knights of the
+hundred, or of twelve free and lawful men, in the absence<span class="pagenum"><a id="Page_156"></a>[156]</span>
+of such knights, should submit to the water ordeal,
+and if he failed in the experiment, he should lose
+one foot; and this law afterwards amended, at Northampton
+in order to make the punishment more severe
+and the felon also lost his right hand, as well as one of
+his feet. He was also required to abjure the realm, within
+forty days and even though he was acquitted by the
+water ordeal, he was required to find pledges to answer
+for his good behavior, and if he were later charged with
+murder, or other felony, he was then required to abjure
+the realm within the forty days, with all his goods, save
+what his lord might distrain to discharge his obligations
+due him.<a id="FNanchor_350" href="#Footnote_350" class="fnanchor">[49]</a> This law was to remain in effect, as
+long as the king pleased and the effect of this law was
+that the accused, if convicted, lost a limb and suffered
+banishment and even if acquitted, by ordeal, he was
+likewise banished, for such was the doubt then entertained
+as to the justness of the trial by ordeal.<a id="FNanchor_351" href="#Footnote_351" class="fnanchor">[50]</a></p>
+
+<p>This doubt upon the justness of the trial by ordeal,
+was due, in large measure to the fact that many such
+trials were fraudulently managed, by the Bishops, to
+bring about the acquittal of the accused.</p>
+
+<p>It is related that William Rufus, who had caused
+fifty Englishmen of good family, to be tried by ordeal
+for the violation of some law of the realm, after their
+acquittal by the ordeal of the hot iron, declared that he
+would try them again by the judgment of his court
+and would not abide by this pretended judgment of
+God, “which was made favorable or unfavorable, at<span class="pagenum"><a id="Page_157"></a>[157]</span>
+any man’s pleasure.”<a id="FNanchor_352" href="#Footnote_352" class="fnanchor">[51]</a> And Henry II., likewise convinced
+of the fraud accompanying such acquittals, by
+this means, also refused to give final effect to such acquittals.<a id="FNanchor_353" href="#Footnote_353" class="fnanchor">[52]</a></p>
+
+<p>Trial by ordeal continued in England until the judgments
+of councils, in the reign of Henry III., but in the
+third year of the reign of this monarch on January 27’,
+1219, direction was given to the justices itinerant for
+the northern counties of the kingdom not to try persons
+charged with murder, arson, robbery, theft or other
+felonies, by the ordeals of fire or water, but for the
+present, until further provision could be made, to keep
+them in prison, <i>so as not to endanger their life or limb</i><a id="FNanchor_354" href="#Footnote_354" class="fnanchor">[53]</a>
+and those charged with the inferior offenses were to be
+compelled to abjure the realm.<a id="FNanchor_355" href="#Footnote_355" class="fnanchor">[54]</a></p>
+
+<p>This order of council, during the reign of Henry III.,
+had such a potent influence toward abolishing the superstitious
+trial of ordeal, that it went quite out of use by
+the time of Bracton, who makes no mention of it in his
+book.<a id="FNanchor_356" href="#Footnote_356" class="fnanchor">[55]</a></p>
+
+<p><span class="pagenum"><a id="Page_158"></a>[158]</span></p>
+
+<p>Compurgation by witnesses was substituted, in England
+in the early part of the thirteenth century, for the
+former mode of compurgation by ordeal and the latter
+became an obsolete procedure in England, until revived
+in the crime of witchcraft, by James I., where it was
+quite generally used, to determine the guilt or innocence
+of persons accused of sorcery, because of the absence
+of any other test to apply, to determine their guilt
+or innocence.<a id="FNanchor_357" href="#Footnote_357" class="fnanchor">[56]</a> This superstitious monarch maintained
+that trial by ordeal was an infallible test in cases of
+witchcraft, because the pure elements of fire and water
+would not receive those who had renounced the sacred
+privileges of their baptism and by his authority and example
+thousands of cases of cruelty and oppression resulted,
+in the use of the ordeal, as applied to cases of
+sorcery, during the craze of that delusion, in Europe,<a id="FNanchor_358" href="#Footnote_358" class="fnanchor">[57]</a>
+but otherwise, the trial by ordeal passed into history,<span class="pagenum"><a id="Page_159"></a>[159]</span>
+along with the many other cruel institutions of a past
+age.</p>
+
+<p>The ordeal was frequently used, in ancient Europe,
+to establish the paternity of children or the chastity of
+women, the success or failure of the test being generally
+accepted as the judgment of God.</p>
+
+<p>In 887 Charles-le-Gros accused his wife, the Empress
+Richarda, of adultery with Bishop Liutward, and she
+offered to prove her innocence by the judicial combat,
+or the ordeal of the red-hot iron.<a id="FNanchor_359" href="#Footnote_359" class="fnanchor">[58]</a></p>
+
+<p>St. Cunigundi, referred to as the “virgin-wife” of
+the Emperor St. Henry II., is also reported to have
+eagerly appealed to the judgment of God, to establish
+her innocence of the baseless charge of infidelity, preferred
+against her by her jealous lord, and in vindication
+of her honor, to have successfully trod, unharmed,
+the red-hot plow-shares.<a id="FNanchor_360" href="#Footnote_360" class="fnanchor">[59]</a></p>
+
+<p>In the eleventh century, the unholy purpose of Edward
+the Confessor—who was himself too ascetic to
+make his own wife, Editha, the partner of his bed<a id="FNanchor_361" href="#Footnote_361" class="fnanchor">[60]</a>—in
+his desire to accomplish the death of his own Mother,
+Queen Emma, because of her partiality to his half
+brother, Hardicanute—the son of Canute,—was frustrated
+by the Queen invoking this judgment of God,
+through the ordeal of the red-hot iron, to establish her
+innocence of the charge of adultery with Alwyn, the
+Bishop of Winchester. The Queen triumphantly
+purged both herself and the Bishop, by the help of St.<span class="pagenum"><a id="Page_160"></a>[160]</span>
+Sowthin, by walking bare-footed over nine red-hot
+plow-shares and out of gratitude for this vindication,
+the Queen and the Bishop each gave nine manors to
+the Church of Winchester in memory of the nine plow-shares,
+and it is reported that the King, for preferring
+the false charge against them, was corrected with
+stripes.<a id="FNanchor_362" href="#Footnote_362" class="fnanchor">[61]</a></p>
+
+<p>The Confessor was more successful in ridding himself
+of his father-in-law, however, and the interesting
+case of Godwin, Duke of Kent, father of Harold and
+sometimes called the “King maker of England,” during
+the reign of Edward the Confessor, also illustrates
+the superstitious belief in the corsned ordeal.</p>
+
+<p>As the story goes, Duke Godwin was dining with his
+royal son-in-law Edward the Confessor—for the latter
+had then married his daughter Editha—and whether<span class="pagenum"><a id="Page_161"></a>[161]</span>
+premeditated or not, the King repeated the accusation
+that his brother Alfred had met his death at the hands
+of Duke Godwin. To vindicate himself old Godwin
+then invoked the ordeal of the corsned and seizing a
+morsel of bread he dramatically exclaimed: “May God
+cause this bread to choke me if I am guilty in thought
+or in deed of this crime.” Then the King took the
+bread and blessed it, and, whether he poisoned it or
+not, when Godwin put it in his mouth and swallowed
+it, he was suffocated by it and fell down dead.<a id="FNanchor_363" href="#Footnote_363" class="fnanchor">[62]</a></p>
+
+<p>In this age of scepticism it is hard to accept this
+superstitious explanation for the end of old Duke Godwin,
+but the secret of his death is more reasonably accounted
+for, on the theory of Boccascio’s story of Calen
+Drino, where the expected miracle was brought about
+by the secret mixture of aloes in the bread of the corsned,
+for, as Lea suggests, Edward the Confessor, both
+because of his dislike for his father-in-law, and his desire
+to cast off the tutelage in which he was held, in
+order to further his self interest and rid himself of a
+hated enemy, would no doubt have secretly mixed
+poison with the corsned used in this ordeal and then
+caused the story to be circulated among the superstitious
+subjects, to account for the Duke’s sudden demise.<a id="FNanchor_364" href="#Footnote_364" class="fnanchor">[63]</a></p>
+
+<p>We find that the ordeal was utilized in France, in the
+tenth century in the notable case of Teutberga, the
+wife of King Lothair, great-grandson of Charlemagne.<span class="pagenum"><a id="Page_162"></a>[162]</span>
+Desiring to rid himself of his wife, this degenerate
+grandson of a worthy grand-sire, accused her of incest
+and forced her to a confession. She afterwards recanted
+and denied the truth of her confession and
+offered to establish her innocence by the ordeal of hot
+water, by proxy.<a id="FNanchor_365" href="#Footnote_365" class="fnanchor">[64]</a></p>
+
+<p>Hincmar, the most distinguished divine of this period
+championed the cause of the unfortunate queen and
+wrote a dissertation upon the infallibility of the test of
+the ordeals, because they had the guidance of the Divine
+Wisdom, effectually convincing himself and a
+large number of the French subjects of the correctness
+of the judgment by this ordeal, especially when King
+Lothair so far estopped himself from claiming that he
+had not desired to get rid of his wife, by espousing his
+concubine, Waldrada, whom he had, in fact, preferred
+to the wife he had discredited by the criminal charge
+against her.<a id="FNanchor_366" href="#Footnote_366" class="fnanchor">[65]</a></p>
+
+<p>Illustrating the prevalence with which the pagan
+practice of ordeal had taken possession of the minds of
+the churchmen of the ninth century, Lea quotes the
+argument of Hincmar, in his interesting work, “Superstition
+and Force,”<a id="FNanchor_367" href="#Footnote_367" class="fnanchor">[66]</a> as follows:</p>
+
+<div class="blockquote">
+
+<p>“In boiling in water the guilty are scalded and the
+innocent are unhurt, because Lot escaped unharmed
+from the fire of Sodom, and the future fire which will
+precede the terrible judge, will be harmless to the
+saints, and will burn the wicked as in the Babylonian
+furnace of old.”</p>
+
+</div>
+
+<p><span class="pagenum"><a id="Page_163"></a>[163]</span></p>
+
+<p>Of course the correctness of this syllogism, depends
+upon the correctness of the first assumption, based upon
+the delusions and superstitions of a past age, but
+the conclusion seemed to satisfy a large number of that
+day, judged by the standards then obtaining, among
+which was the idea of a Deity who was a bigger,
+stronger, crueler man—a more “terrible judge.”</p>
+
+<p>Some few of the many interesting trials by ordeal,
+which obtained during the twelfth century in the reigns
+of Richard I. and King John, have been reproduced by
+Sir F. Palgrave, in his “Proofs and Illustrations,” to
+be found in the <i>Rotuli Curiae Regis</i><a id="FNanchor_368" href="#Footnote_368" class="fnanchor">[67]</a> for those reigns.
+Let us examine a few of these old Rolls.</p>
+
+<div class="blockquote">
+
+<p>“<i>Roll of the Iter of Wiltshire, 10 Richard I.</i>—The
+jurors say that Radulphus Parmentarius was found
+dead with his neck broken, and they suspect one Christina,
+who was formerly the wife of Ernaldus de
+Knabbewell, of his death, because Radulphus sued
+Christina in the ecclesiastical court for breach of a
+promise of marriage she had made to him and after the
+death of her husband Ernaldus, Reginald, a clerk, frequented
+her and took her away from Radulphus, and
+Reginald and Christina hated Radulphus for sueing
+her, and on account of that hatred, the jurors suspect
+her and the clerk of his death. And the country says
+it suspects her. Therefore, it is considered that the
+clerk and Christina appear on Friday, and that Christina
+purge herself by fire.<a id="FNanchor_369" href="#Footnote_369" class="fnanchor">[68]</a> <i>Roll of the Iter of Stafford,
+in 5 John.</i>—One Elena is suspected by the jurors,<span class="pagenum"><a id="Page_164"></a>[164]</span>
+because she was at the place where Rainalda de Henchenhe
+was killed and because she was killed by her help
+and consent. She denies it. Let her purge herself by
+the judgment of fire; but as she is ill, let her be respited,
+till she gets well.</p>
+
+<p>Andrew of Bureweston is suspected by the jurors of
+the death of one Hervicus, because he fled for his death,
+therefore let him purge himself by the judgment of
+water.”<a id="FNanchor_370" href="#Footnote_370" class="fnanchor">[69]</a></p>
+
+</div>
+
+<p>During the witchcraft craze, in Europe, the ordeal of
+fire and water was frequently invoked by the accused
+persons, to clear themselves of the charge, but so incensed
+were the people against those arraigned for this
+offense that it was difficult to convince the courts and
+juries of the innocence of the alleged offender, even by
+this supposed infallible test of the judgment of God. It
+was presumed that the Devil interfered with the correctness
+of the termination of the tests in this hated
+crime and so the poor suspects were condemned, after
+suffering untold tortures, even though the test of the
+ordeal favored their innocence of the charge.</p>
+
+<p>The Inquisitor Sprenger cites the case of a witch,
+tried before the Count of Furstenberg, in 1484. The
+accused invoked the test of the red-hot iron and the
+Inquisitor attributed his acquiescence to his youth and
+inexperience and the fact that he was not acquainted
+with the methods of the Devil, to further the cause of
+the sorcerers. Although sentenced to carry the hot
+iron only six paces, the supposed witch carried it six
+paces and offered to hold it still longer, if required, as
+she displayed her hand wholly uninjured. The Count<span class="pagenum"><a id="Page_165"></a>[165]</span>
+was thus compelled to render a judgment of not guilty
+against the accused person and at the time Sprenger
+wrote, in 1487, he reported that she still lived “to the
+scandal of the faithful.”<a id="FNanchor_371" href="#Footnote_371" class="fnanchor">[70]</a></p>
+
+<p>The superstition connected with the trial by ordeal,
+as a means of detecting the guilt or innocence of the
+participants of the foul crimes of the middle ages, early
+took a firm hold of the popular imagination and we find
+repeated references to the ordeal, in the dramatic and
+popular literature of the different countries where this
+mode of trial obtained.</p>
+
+<p>The heroic Iceland song of the Elder Edda, supposed
+to have been composed between the sixth and eighth
+centuries, utilizes the ordeal as a means of bringing
+to justice the false witness borne by the accuser, the
+Concubine Herkia, in her charge of adultery against
+Gudrun, the wife of Atli.<a id="FNanchor_372" href="#Footnote_372" class="fnanchor">[71]</a> First describing the test,
+resulting in the innocence of Gudrun, and then the
+proof of the guilt of her accuser, the poem proceeds:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“She to the bottom plunged her snow-white hand,</div>
+ <div class="verse indent0">And up she drew the precious stones,</div>
+ <div class="verse indent0">‘See now, ye men, I am proved guiltless,</div>
+ <div class="verse indent0">In holy wise, boil the vessel as it may.’</div>
+ <div class="verse indent0">Laughed then Atli’s heart within his breast</div>
+ <div class="verse indent0">When he unscath’d beheld, the hand of Gudrun.”</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">“‘Now must Herkia to the cauldron go,</div>
+ <div class="verse indent0">She who Gudrun had hoped to injure.’</div>
+ <div class="verse indent0">No one has misery seen, who saw not that,</div>
+ <div class="verse indent0">How the hand there of Herkia was hurt.</div>
+ <div class="verse indent0">They then the woman led to a foul slough.</div>
+ <div class="verse indent0">So were Gudrun’s wrongs avenged.”</div>
+ </div>
+</div>
+</div>
+
+<p><span class="pagenum"><a id="Page_166"></a>[166]</span></p>
+
+<p>The ordeal of the bier was exemplified in the current
+literature of the age of Richard Coeur-de-Lion, for the
+histories of that King report that when he met the
+funeral procession of his father Henry II., at Fontevraud,
+the blood spurted from the nose of the deceased,
+because of the treason and rebellion of which his son
+had been guilty.<a id="FNanchor_373" href="#Footnote_373" class="fnanchor">[72]</a></p>
+
+<p>Shakespeare utilizes this story of Richard Coeur-de-Lion,
+in the funeral scene, in Richard III., where Lady
+Anne, when interrupted in her grief at the bier of
+Henry VI., is made to say to the by-standers:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“O gentlemen, see, see: dead Henry’s wounds</div>
+ <div class="verse indent0">Open their congeal’d mouths, and bleed afresh.”<a id="FNanchor_374" href="#Footnote_374" class="fnanchor">[73]</a></div>
+ </div>
+</div>
+</div>
+
+<p>In Sir Walter Scott’s “Minstrelsy of the Scottish
+Border” we also find a reference to this ordeal of the
+bier, when, in the ballad of Earl Richard, this author
+established the innocence of the maid, by this test:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“‘Put na the wite on me,’ she said;</div>
+ <div class="verse indent0">‘It was my may Katherine.’</div>
+ <div class="verse indent0">Then they hae cut baith fern and thorn,</div>
+ <div class="verse indent0">To burn that maiden in.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">It wadna take upon her cheik,</div>
+ <div class="verse indent0">Nor yet upon her chin;</div>
+ <div class="verse indent0">Nor yet upon her yellow hair,</div>
+ <div class="verse indent0">To cleanse that deadly sin.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">The maiden touched that clay-cauld corpse,</div>
+ <div class="verse indent0">A drap it never bled;</div>
+ <div class="verse indent0">The ladye laid her hand on him,</div>
+ <div class="verse indent0">And soon the ground was red.”</div>
+ </div>
+</div>
+</div>
+
+<p><span class="pagenum"><a id="Page_167"></a>[167]</span></p>
+
+<p>And thus Scott uses the ordeal of the bier to establish
+that the accuser was herself the guilty person<a id="FNanchor_375" href="#Footnote_375" class="fnanchor">[74]</a> and the
+Bard of Avon and the Elder Edda utilize this ordeal
+and that of the boiling water, to demonstrate the infallibility
+of this Divine test, when applied, to ascertain
+the guilt or innocence of one accused of such crimes
+as may legitimately be the subject of this character of
+proceeding, known to the ancient law as one of the
+Judgments of God.</p>
+
+<p>The ordeal was entirely a judicial proceeding, regularly
+used, in an early day, for the trial of criminal
+cases, before the civil and ecclesiastical courts. The
+accused had no alternative but to undergo the trial by
+ordeal, for when ordered to submit to it, the order had
+the force and effect of a regular judgment of the
+court.<a id="FNanchor_376" href="#Footnote_376" class="fnanchor">[75]</a> A failure to comply with the order of the
+court to undergo a trial by ordeal, was treated as a contempt
+of court, and under the early English law, the
+accused who refused to submit to such a test, was outlawed
+and his property was confiscated, the same as if
+he had been adjudged guilty of the offense, for in refusing
+a compliance with the mandate of the law, he
+placed himself beyond the pale of the law and later
+could not claim the right to a lawful trial.<a id="FNanchor_377" href="#Footnote_377" class="fnanchor">[76]</a> The Anglo-Saxon
+codes allowed no alternative but contained direct<span class="pagenum"><a id="Page_168"></a>[168]</span>
+and specific provisions for the trial by ordeal, in
+all its different phases.<a id="FNanchor_378" href="#Footnote_378" class="fnanchor">[77]</a></p>
+
+<p>The circumstances and conditions under which ordeal
+was employed, in the trial of the various felonies known
+to the early Saxon laws, varies, necessarily, with the
+customs and legislation of the different rulers, and
+sometimes we find that the right of selection obtained,
+between this and other modes of compurgation, or between
+the different forms of ordeal.<a id="FNanchor_379" href="#Footnote_379" class="fnanchor">[78]</a></p>
+
+<p>Little, if any good, could result from a discussion of
+the power of a Court to order submission to such barbarous
+treatment, for the courts assumed the power
+and it was backed-up with the influence of the Church
+and the authority of the King. The citizens could do
+little else than submit to such a formidable alliance,
+which proceeded in the name of the Majesty of the Law
+and the Solemn Assurance of the Church, for there
+were no constitutions to protect the citizens from cruel
+or unusual punishments; might was right when used
+against the weak and oppressed and the power of the
+Church and State was too much for any individual to
+overcome. Society was not organized, as at present,
+to protect the rights of the individual, but the Church
+and State were all-powerful and their orders had the
+force to overcome all private resistance.</p>
+
+<p>As shown, in the beginning, the institution known
+as trial by ordeal, like many other of the cruel customs
+of the ancient world, had the Mosaic law as its foundation
+and the Church’s approval, in the construction of
+the foundation and the recognition of the whole institution.
+The Church was not only ready to accept the barbarous<span class="pagenum"><a id="Page_169"></a>[169]</span>
+practices of its pagan converts but itself gave
+them fresh claim to confidence, by throwing around
+them the solemn ceremonies of its own approval. The
+ordeals were all conducted with the aid of the priests,
+and prelates in all the Catholic countries were everywhere
+granting special charters authorizing the privilege
+of trials by ordeals.<a id="FNanchor_380" href="#Footnote_380" class="fnanchor">[79]</a></p>
+
+<p>But as the Church was partly responsible for the
+practice of trials by ordeal, because the Churchmen
+were but human and, as such, entered into the manners
+and customs of the people of the period when they
+lived, the Church had no inconsequential part in abolishing
+this barbarous custom, for ever since the sixth
+century and perhaps from the beginning of the custom,
+eminent Churchmen had opposed the institution as a
+pagan custom, not authorized by the teachings of the
+ancient Jews or the religion of Christ, and finally, the
+protests of these wise Churchmen culminated in the
+suppression of this old test, and in 1215 the Lateran
+Council forbade the clergy from afterward taking part
+in the ceremony known as trial by ordeal.<a id="FNanchor_381" href="#Footnote_381" class="fnanchor">[80]</a> And Henry III.,
+following the lead made by the Church, “Seeing
+that the judgment of fire and water is forbidden by the
+Church of Rome,” directed his judges, starting on their
+circuits, to adopt other methods of proof and to forever
+discard this brutal test.<a id="FNanchor_382" href="#Footnote_382" class="fnanchor">[81]</a></p>
+
+<p><span class="pagenum"><a id="Page_170"></a>[170]</span></p>
+
+<p>If the Church was remiss in its duty to oppose the
+ordeal, therefore, in the beginning, it brought about the
+repression of the practice, and is, at least, entitled to
+the benefit of the approval of the friends of humanity
+for this tardy beneficence, upon its part.</p>
+
+<p>If true that every age, like every person, has its own
+sins and short-comings to answer for, and that is the
+happiest which best succeeds in hiding them for a
+time,<a id="FNanchor_383" href="#Footnote_383" class="fnanchor">[82]</a> then the age of the trial by ordeal, according to
+our twentieth century standard, was guilty of a sin that
+the past centuries must atone for, if atonement is essential
+for the wayward customs of a pagan race,
+struggling without compass or needle, amid the darkness
+of a barbarous age, to steer a straight course.
+They should not be held to more than the ordinary
+standards of right and wrong then prevailing, in their
+efforts to find the higher law for society, when just
+able to attempt to clamber up the mountain heights of
+wisdom. The inhabitants of the centuries who utilized
+the trial by ordeal had not then perfected their judicial
+system so that very high ideals of individual right obtained,
+but they had made wonderful strides in the
+arts and sciences, while practicing this hideous custom
+of trusting to the wisdom of God, in the trials of men
+and women for their offenses against society, as judged<span class="pagenum"><a id="Page_171"></a>[171]</span>
+by man made laws. We have elevated the standards of
+the judicial system somewhat, since that period, but in
+our own time, a large number of people, instead of further
+establishing the independence of the judiciary, are
+favorable to submitting to popular vote, the correctness
+of a given decision, or the judicial fitness of a judge;
+mormonism only recently was abolished and instead of
+the superstition and delusion which invoked the judgment
+of God in trials of witches and others accused of
+unproven crimes, we have spiritualism and other similar
+protests against rationalism and reason, so we are
+not yet in a position to condemn, in unmeasured terms,
+our older brothers of the day of trials by ordeal.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_302" href="#FNanchor_302" class="label">[1]</a> Pattetta, Ordalia, c. I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_303" href="#FNanchor_303" class="label">[2]</a> From the Anglo-Saxon, <i>Ordaal</i>, <i>or</i>, primitive, and <i>daal</i>, judgment,
+meaning “primitive judgment,” or <i>urtheil</i>, according to the
+German.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_304" href="#FNanchor_304" class="label">[3]</a> Thayer says: “Nothing is older,” Harvard Law Review, Vol. V.,
+p. 63; II. Essays in Anglo-American Legal History, 392.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_305" href="#FNanchor_305" class="label">[4]</a> Numbers, V., 14, 15, 19, 24, 27, 28.</p>
+
+<p>This same ordeal is in use among the Africans, of the Gold Coast,
+to determine incontinence on the part of a woman.</p>
+
+<p>From Herodotus it would seem that the ancient Egyptians believed
+in ordeals, with other divine power, to solve the guilt of
+prisoners, in cases where the evidence was doubtful, as he narrates
+instances where Aames II. who led a dissolute life, was convicted
+on the supposed divine judgment of the oracle. Herodotus II., 174.</p>
+
+<p>In their excellent history of English Law, Pollock and Maitland
+say, of the trial by ordeal: “The history of ordeals is a long chapter
+in the history of mankind; we must not attempt to tell it.
+Men of many, if not all races, have carried the red-hot iron or
+performed some similar feat, in proof of their innocence.” (Vol. II.,
+p. 598.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_306" href="#FNanchor_306" class="label">[5]</a> Sophocles’ <i>Antigone</i>, 264; Aeschylus, fr. 284.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_307" href="#FNanchor_307" class="label">[6]</a> Asiatic Researches, vol. i., p. 389.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_308" href="#FNanchor_308" class="label">[7]</a> Neilson’s “Trial by Combat.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_309" href="#FNanchor_309" class="label">[8]</a> Thayer’s “Older Modes of Trial,” II. Essays in Anglo-American
+Legal History, p. 393.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_310" href="#FNanchor_310" class="label">[9]</a> Pattetta, Ordelie.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_311" href="#FNanchor_311" class="label">[10]</a> Mackay’s Delusions; Athelstane.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_312" href="#FNanchor_312" class="label">[11]</a> Pattetta, Ordalie.</p>
+
+<p>In Sophocles’ Antigone, the guards protest their innocence to
+Creon, of any complicity in the burial of Polynices and offer to
+establish their innocence by ordeal, in the following lines:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Ready with hands to bear the red-hot iron,</div>
+ <div class="verse indent0">To pass through fire, and by the gods to swear</div>
+ <div class="verse indent0">That we nor did the deed, nor do we know</div>
+ <div class="verse indent0">Who counselled it, or who performed it.” (PP. 264-267.)</div>
+ </div>
+</div>
+</div>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_313" href="#FNanchor_313" class="label">[12]</a> Pattetta, Ordalie; I. Reeve’s History English Law, p. 203.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_314" href="#FNanchor_314" class="label">[13]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_315" href="#FNanchor_315" class="label">[14]</a> Mackay’s “Memoirs of Delusions.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_316" href="#FNanchor_316" class="label">[15]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_317" href="#FNanchor_317" class="label">[16]</a> According to Jolly, the translator of this book, the materials
+for the text date back many centuries before Christ and some of
+the old laws treated of, belong to the remotest antiquity, p. XX.</p>
+
+<p>Rishi Narada was a celebrated Hindu Sage and Lawgiver, supposed
+to have been the son of Brahma and Saraswari. Mrs. Manning’s
+“Ancient and Med. India,” Vol. I., pp. 146, 249; Vol. II., pp. 119, 134.</p>
+
+<p>The ordeal of the eucharist was based upon the statement of the
+Apostle, construed with pious veneration and accepted literally
+“he that eateth and drinketh unworthily eateth and drinketh damnation
+to himself.” <i>I. Corinthians</i> XI., 28, 29; Lea, “Superstition
+and Force,” (3 ed.) 304.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_318" href="#FNanchor_318" class="label">[17]</a> Brahma, the first person, in the Triad, of the Hindus, was the
+god of the fates, master of life and death, the author of the Vedas
+and the great lawgiver and teacher of India.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_319" href="#FNanchor_319" class="label">[18]</a> Institute Narada, Pt. I., c. 5, sec. 102, to Pt. II., pp. 44, 45.
+According to an eminent authority, ordeals are still practiced in
+India, in private life. Sir Henry Maine’s “Life and Speeches,” p. 426;
+Manning’s “Ancient and Mediaeval India,” Vol. I., pp. 146, 249; Vol.
+II., pp. 119, 134.</p>
+
+<p>From the fragments of the Avesta, which have come down to
+us, containing snatches of the prehistoric law of the ancient Persians,
+the ordeal of boiling water was a fixed, settled legal procedure, at
+that distant day, for it is there recorded:</p>
+
+<p>“Creator: he who knowingly approaches the hot, golden, boiling
+water, as if speaking truth, but lying to Mithra;</p>
+
+<p>What is the punishment for it?</p>
+
+<p>Then answered Ahura-Mazda: Let them strike seven hundred
+blows with the horse goad, seven hundred with the craesho-charaha.”
+This was the punishment affixed for using this particular ordeal
+for fraudulent purposes, just as if one trifled with one of the settled
+legal processes of the present day and as perjury was then
+prevalent, the punishment of twice seven hundred blows to the
+perjurer, was the penalty for using this ordeal to further perjury,
+or false swearing. Vendidad, Farg. IV., 156; “Records of the Past,”
+VII., 109; Lea, “Superstition and Force,” (3’ ed.) 233.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_320" href="#FNanchor_320" class="label">[19]</a> Cap. Car. Mag. ann. 779, sec. 10; Lea, “Superstition and Force,”
+(3 ed.) 348.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_321" href="#FNanchor_321" class="label">[20]</a> Capit. iv ann. 803, secs. iii, vi; in L. Longobard, Lib. ii, Tit.
+xxviii, sec. 3; Tit. iv, sec. 25; Capit. Car. Mag. I., ann. 809, sec. 20.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_322" href="#FNanchor_322" class="label">[21]</a> Capit. Car. Mag. ann. 794, sec. 7; Lea, “Superstition and Force,”
+p. 338.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_323" href="#FNanchor_323" class="label">[22]</a> Concil. Aquisgran. cap. xvii.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_324" href="#FNanchor_324" class="label">[23]</a> L. Longobard, Lib. II., Tit. lv, sec. 32; Lea, “Superstition and
+Force,” p. 298.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_325" href="#FNanchor_325" class="label">[24]</a> Herbert’s Antiquities (1804), p. 146.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_326" href="#FNanchor_326" class="label">[25]</a> De Moribus Germanorum, cap. X.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_327" href="#FNanchor_327" class="label">[26]</a> Herbert’s Antiquities, p. 147.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_328" href="#FNanchor_328" class="label">[27]</a> <i>Ante idem.</i>; I. Pollock and Maitland’s History English Law, p.
+39; Dr. Liebermann’s Sitzungsberichte der Berliner Akademie,
+1896, XXXV., p. 829.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_329" href="#FNanchor_329" class="label">[28]</a> Leg. Athelstan, 23; I. Reeve’s History English Law, p. 201;
+Analecta Anglo-Brit. lib. ii, cap. 8, inter Leges Athelstan, cap xxx.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_330" href="#FNanchor_330" class="label">[29]</a> Dr. Liebermann’s Sitzungsberichte der Berliner Akadamie,
+XXXV., 829; I. Pollock and Maitland’s History English Law, p. 39,
+note.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_331" href="#FNanchor_331" class="label">[30]</a> Herbert’s Antiquities (1804), pp. 147, 148.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_332" href="#FNanchor_332" class="label">[31]</a> I. Reeve’s History English Law, pp. 201, 202; Leges Athelstan,
+23.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_333" href="#FNanchor_333" class="label">[32]</a> Mirror of Justice, c. 7, s. 24.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_334" href="#FNanchor_334" class="label">[33]</a> I. Reeve’s History English Law, p. 203.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_335" href="#FNanchor_335" class="label">[34]</a> Finlason’s note to I. Reeve’s History English Law, p. 201.</p>
+
+<p>Pollock, in his “Anglo-Saxon Law,” says “A man of good repute
+could usually clear himself by oath, but circumstances of grave
+suspicion or previous bad character, would drive the defendant to
+stand his trial by ordeal.” I. Essays in Anglo-American Legal
+History, p. 93.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_336" href="#FNanchor_336" class="label">[35]</a> Lamb, de priscis Angl. Leg. cap. 39.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_337" href="#FNanchor_337" class="label">[36]</a> Herbert’s Antiquities (1804), p. 156.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_338" href="#FNanchor_338" class="label">[37]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_339" href="#FNanchor_339" class="label">[38]</a> Leges, Aesthelstan, iv, sec. 6; Aetheldred, iii, sec. 7; Cnut,
+Secular. sec. 58; Lea, “Superstition and Force” (3 ed.), 253.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_340" href="#FNanchor_340" class="label">[39]</a> Legg. Edwardi, cap. iii; Lea, “Superstition and Force” (3 ed.)
+340.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_341" href="#FNanchor_341" class="label">[40]</a> Legg. Aethelredi, cap. i, sec. I; Cnuti Saecul. cap. xxii; Henrici,
+I., cap lxv, sec. 3; Lea, <i>supra</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_342" href="#FNanchor_342" class="label">[41]</a> Schmid, Gesetze, p. 357; Stubbs, Select Charters; I. Pollock and
+Maitland’s History English Law, p. 450.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_343" href="#FNanchor_343" class="label">[42]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_344" href="#FNanchor_344" class="label">[43]</a> LL. Inae, c. 77; <i>Traites sur les coutumes Anglo-Normand</i>. Tom.
+I., p. 577; Hale’s History Common Law, p. 152.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_345" href="#FNanchor_345" class="label">[44]</a> Thayer “Older Modes of Trial,” V. Harvard Law Review, 64;
+II. Essays in Anglo-American Legal History, p. 394.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_346" href="#FNanchor_346" class="label">[45]</a> Leges Henri, 31, sec. 5; Foedera, i, 154; II. Pollock and Maitland’s
+History English Law, p. 650.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_347" href="#FNanchor_347" class="label">[46]</a> Palgrave, Commonwealth, p. 207; II. Pollock and Maitland’s
+History English Law, p. 650.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_348" href="#FNanchor_348" class="label">[47]</a> Glanville (Beame’s tr.), p. 283.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_349" href="#FNanchor_349" class="label">[48]</a> I. Reeve’s History English Law, pp. 456, 457; Mirror of Justice,
+cap. III., sec. 23; Lea, “Superstition and Force,” (3 ed.) 256.</p>
+
+<p>“The water ordeals, both hot and cold, were stigmatized as
+plebian, from an early period, as the red-hot iron and the duel
+were patrician.” Lea, 283.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_350" href="#FNanchor_350" class="label">[49]</a> I. Reeve’s History English Law, p. 456; I. Pollock and Maitland’s
+History English Law, p. 152.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_351" href="#FNanchor_351" class="label">[50]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_352" href="#FNanchor_352" class="label">[51]</a> I. Reeve’s History English Law, p. 456.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_353" href="#FNanchor_353" class="label">[52]</a> Litt. Hen. II., vol. iv, 279; I. Reeve’s History English Law, 457.</p>
+
+<p>Instead of the <i>judicium Dei</i>, the success of the fifty men would
+look more like <i>judicium clericus</i>. Eadmer, Hist. Nov. 102; II. Pollock
+and Maitland History English Law, 599.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_354" href="#FNanchor_354" class="label">[53]</a> This order to the justices, as we have seen, in the Essay on
+<i>Peine forte et dure</i>, had the effect of filling the jails of the kingdom
+with prisoners content to await the invention of some other method
+of trial than that of ordeal, and since none such was provided, to
+refuse to plead and thus baffle the king’s justices. To overcome
+this custom, the order not to <i>endanger their lives or limbs</i>, soon
+gave place to the terrible torture, by which they were literally
+<i>pressed to death</i>, for standing mute.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_355" href="#FNanchor_355" class="label">[54]</a> II. Reeve’s History English Law, 286.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_356" href="#FNanchor_356" class="label">[55]</a> II. Reeve’s History English Law, 287, and note.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_357" href="#FNanchor_357" class="label">[56]</a> Lea “Superstition and Force,” (3 ed.) 291; Daemenologiae, Lib.
+III., cap. vi.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_358" href="#FNanchor_358" class="label">[57]</a> <i>Ante idem.</i></p>
+
+<p>The Lateran Council of 1215 forbade the clergy to take part in
+the ceremony of the ordeal any further and in prompt obedience
+to this decree in England, Henry III. abolished it in the kingdom,
+as England was then at the Pope’s feet, and aside from the cases
+of witchcraft and sorcery, in the reign of James I., the ordeal last
+appears, as a method of judicial trial, in the old rolls of the reign
+of King John. (Concil. Lateran. IV., c. 18; Foedera, i, 154; Rolls
+of King’s Court, Pipe Roll Soc. 80, 86, 89;) Select Pl. Cr; Note
+Book, pl. 592; Lea, “Superstition and Force,” (3 ed.) 421; II. Pollock
+and Maitland’s History English Law., p. 599 and notes.</p>
+
+<p>Lord Hale informs us: “That in all the time of King John ...
+trial by ordeal continued, ... but it seems to have ended with
+this king, for I do not find it in use any time after.” (History
+Common Law, p. 152.)</p>
+
+<p>In Nigeria the trial by ordeal still obtains in cases of witchcraft
+and to vindicate the chastity of women. P. Amaury Talbot’s article,
+in London Telegraph, July, 1912.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_359" href="#FNanchor_359" class="label">[58]</a> Regino. ann. 886—Annales Metenses; Lea, “Superstition and
+Force,” (3 ed.) 257.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_360" href="#FNanchor_360" class="label">[59]</a> Lea, “Superstition and Force,” <i>supra</i>; S. Kunegundae, cap. 2;
+Ludewig Script. Rer. German. I., 346.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_361" href="#FNanchor_361" class="label">[60]</a> Green’s History English People, vol. I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_362" href="#FNanchor_362" class="label">[61]</a> Freeman’s Norman Conq. Vol. II; Rapin, History d’ Angleterre,
+I., 123; Wm. of Malmesbury, Giles’ note, ann. 1043; Lea, “Superstition
+and Force,” (3 ed.) 258.</p>
+
+<p>It seems that the charges against Queen Emma were preferred
+by Robert, Archbishop of Canterbury. She was accused both of
+consenting to the death of her son, Alfred, and of preparing poison
+for her son Edward, the Confessor, and also of intimacy with Alwyn,
+the Bishop of Winchester. The Dowager Queen, on the night preceding
+the trial, prayed for help, in the Abbey of St. Swithune, at
+Winchester and the next day she passed over the nine plow-shares
+unhurt. Archbishop Robert fled the kingdom and the King, who
+had brought about her trial, did penance for his credulity.</p>
+
+<p>(The Percy Anecdotes, p. 161.)</p>
+
+<p>The paternity of two children resulting from a morganitic marriage
+of Robert Curthose, son of William the Conqueror, is reported
+to have been established by the ordeal of the red-hot iron, which
+the mother carried unhurt, and Curthose, then Duke of Normandy,
+thus convinced of the legitimacy of the boys, regularly adopted
+them. Roger de Wendover, Ann. 1085; Lea, “Superstition and
+Force,” (3 ed.) 259.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_363" href="#FNanchor_363" class="label">[62]</a> Roger of Wendover, ann. 1054; Matthew of Westminster, ann.
+1054; Chronicles of Croyland, ann. 1053; Henry of Huntington, ann.
+1053; Wm. of Malmesbury, Lib. II., cap. 13; Lea, “Superstition and
+Force,” (3 ed.) p. 301.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_364" href="#FNanchor_364" class="label">[63]</a> Lea, “Superstition and Force,” <i>supra</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_365" href="#FNanchor_365" class="label">[64]</a> Lea, “Superstition and Force,” (3 ed.) p. 247.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_366" href="#FNanchor_366" class="label">[65]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_367" href="#FNanchor_367" class="label">[66]</a> Lea, “Superstition and Force,” (3 ed.) p. 247; Hincmar, de
+Divert. Lothat. Interrog. vl.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_368" href="#FNanchor_368" class="label">[67]</a> Palgrave erroneously states that the <i>Retuii Curia Regis</i> is the
+“oldest judicial record in existence.” The records of trials obtaining
+during the reign of Hammurabi, 2250 years before Christ, are in
+existence. See Chapter on “<i>Recall of Judges</i>;” John’s “Laws of
+Babylonia,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_369" href="#FNanchor_369" class="label">[68]</a> Palgrave’s “Proofs and Illustrations,” clxxxviii; Stephen’s “Criminal
+Procedure,” II. Essays in Anglo-American Legal History, pp.
+487, 488.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_370" href="#FNanchor_370" class="label">[69]</a> Palgrave’s “Proofs and Illustrations,” clxxxv; Stephen’s “Criminal
+Procedure,” <i>supra</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_371" href="#FNanchor_371" class="label">[70]</a> Malleus Maleficar. Francof. 1580, pp. 523-31; Lea, “Superstition
+and Force,” (3 ed.) 264.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_372" href="#FNanchor_372" class="label">[71]</a> Benjamin Thorpe’s Elder Edda, pp. 106, 107; Prof. Bugge’s Ed.
+of Copenhagen, (1867); Prof. Rask’s ed. of 1818; Lea, “Superstition
+and Force,” (3 ed.) 335.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_373" href="#FNanchor_373" class="label">[72]</a> Benedicti Abbatis Gest. Henr. ann. 1189; Roger de Hoveden,
+ann. 1186; Lea, “Superstition and Force,” (3 ed.) 316.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_374" href="#FNanchor_374" class="label">[73]</a> Richard III., Act I., Scene II.</p>
+
+<p>Sir Walter Scott uses the ordeal of the bier in the “Fair Maid
+of Perth,” in connection with the killing of Oliver Proudfute, who
+was killed with a lochabar axe. On the principle that “murder
+will out,” while the body lay in state at the High Church of St.
+John, in Perth, the servants of Sir John Ramorny were required
+to pass by the corpse and touch it, but when Bonthron, the person
+who had really slain the deceased, came to the body, he refused
+to touch it and claimed the right of trial by battle. (“Fair Maid
+of Perth,” Chapter XXIII.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_375" href="#FNanchor_375" class="label">[74]</a> Lea, “Superstition and Force,” (3 ed.) 335.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_376" href="#FNanchor_376" class="label">[75]</a> II. Pollock and Maitland’s History English Law, 650; Lea
+“Superstition and Force,” (3 ed.) 333.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_377" href="#FNanchor_377" class="label">[76]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_378" href="#FNanchor_378" class="label">[77]</a> II. Cnuti, Saec. cap. xxx, xli.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_379" href="#FNanchor_379" class="label">[78]</a> L. Henrici, I., cap. lxv, sec. 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_380" href="#FNanchor_380" class="label">[79]</a> Lea, “Superstition and Force,” (3 ed.) 354, 356; Annal. Benedict.
+L. 57, No. 74, ann. 1036.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_381" href="#FNanchor_381" class="label">[80]</a> Concil. Lateran. IV., c. 18; II. Pollock and Maitland’s History
+English Law, 599.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_382" href="#FNanchor_382" class="label">[81]</a> Rymer, Foed. I., 228; II. Pollock and Maitland’s History Eng.
+Law, <i>supra</i>.</p>
+
+<p>Illustrative of the approval of the church of Rome in the ancient
+procedure by ordeal, we find, in the ninth century that Hincmar
+expatiated upon the blessing of such a test, in that it combines
+“The elements of water and of fire: the one representing the
+deluge—the judgment inflicted on the wicked of old; the other
+authorized by the fiery doom of the future—the day of judgment,
+in both of which we see the righteous escape and the wicked suffer.”
+Hincmar, de Divort. Lothar. Interrog. vl; Lea, “Superstition and
+Force,” (3 ed.) 244.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_383" href="#FNanchor_383" class="label">[82]</a> Lea, “Superstition and Force,” (3 ed.) 370.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_172"></a>[172]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_VI">CHAPTER VI.<br>
+<span class="smcap">Peine Forte et Dure.</span></h2>
+
+</div>
+
+<p><i>Peine forte et dure</i>,<a id="FNanchor_384" href="#Footnote_384" class="fnanchor">[1]</a> or, the “strong and hard pain,”
+as it was most appropriately termed, was the name given
+in Europe to the particular kind of punishment formerly
+inflicted upon a prisoner, charged with felony,
+where he stood mute and refused to answer on his
+arraignment, or having entered his plea of not guilty,
+where he peremptorily challenged more than twenty
+jurors, which was quite generally considered a contumacy
+equivalent to standing mute.<a id="FNanchor_385" href="#Footnote_385" class="fnanchor">[2]</a></p>
+
+<p>Generally, in indictments for high treason and the
+lower felonies and misdemeanors, standing mute was
+held equivalent to a conviction and the prisoner was
+sentenced and received his punishment, just as if he had
+entered a plea of guilty or suffered a conviction. But in
+all other felonies the prisoner was required to plead
+to the indictment, before a conviction could be obtained
+and if he obstinately stood mute, or refused to plead,
+he was subjected to the <i>peine forte et dure</i>, a judgment
+purposely ordained to be exquisitely severe, that by that
+very means it might rarely be put into execution.</p>
+
+<p>The judgment for standing mute, was: That the
+prisoner be remanded to the prison from whence he
+came, and put into a low, dark chamber, and there be
+laid on his back, on the bare floor, naked, unless where
+decency forbids; that there be placed upon his body<span class="pagenum"><a id="Page_173"></a>[173]</span>
+as great a weight of iron as he can bear; and more,
+that he have no sustenance, save only, on the first day,
+three morsels of the worst bread; and on the second day
+three draughts of standing water, that should be nearest
+to the prison door; and in this condition, this should be
+alternately his daily diet, until he answers to the indictment.<a id="FNanchor_386" href="#Footnote_386" class="fnanchor">[3]</a></p>
+
+<p>To understand how such an inhuman institution as
+that of pressing prisoners to death came into existence,
+it is necessary to understand somewhat the history of
+criminal proceedings of the period when it obtained.
+The motive which would induce the prisoner charged
+with felony to submit to this terrible punishment, rather
+than enter his plea, was no doubt to escape the attainder
+which would result from a conviction for felony. If
+he was convicted of felony, his goods were forfeited to
+the crown and in the case of capital felony, corruption
+of blood followed attainder and the felon could neither
+inherit nor transmit landed property.<a id="FNanchor_387" href="#Footnote_387" class="fnanchor">[4]</a> Where the prisoner
+had heirs, therefore, and possessed any estate, his
+attachment and affection for his heirs or children frequently
+prompted him to suffer the punishment of being
+pressed to death, to avoid the attainder of his name
+and the corruption of his blood, for death and attainder<span class="pagenum"><a id="Page_174"></a>[174]</span>
+would both result from the conviction, which was frequently
+certain to result, in any event.</p>
+
+<p>Trial by ordeal obtained in England until the thirteenth
+century,<a id="FNanchor_388" href="#Footnote_388" class="fnanchor">[5]</a> and as a part of the procedure obtaining
+when this barbarous custom prevailed the prisoner
+when asked “Culprit, how will you be tried,” replied,
+“By God,” meaning that he would be tried by ordeal,
+rather than “By my country,” which was the request
+for a jury trial. When the prisoner stood mute and
+refused to plead, the court was so perplexed that frequently
+the prisoner would escape by some trivial
+punishment, as the procedure of the period did not include
+this kind of a case, so the astute criminal lawyers
+of these times no doubt frequently practiced this
+subterfuge to perplex the court and secure the escape
+of a guilty client. Legal forms at this period had much
+greater efficacy than at present when we have statutes
+of jeofails and look to the substance, rather than the
+forms of things, and it was unheard of then to try a
+prisoner by ordeal, before he entered his plea, or even
+to put him upon his country, so where he stood mute,
+the difficult thing was to secure his consent to try him
+by either method.</p>
+
+<p>Under the stress of the perplexity of having found
+concrete cases not covered by the custom and practice
+of the period, the judges instantly ordered some of the
+offenders standing mute on malice, to be put to death,<span class="pagenum"><a id="Page_175"></a>[175]</span>
+for refusing to consent to be tried, according to the
+custom of the realm, but this was practically judicial
+murder, as the defendant had not been legally convicted,
+before sentence, so the pendulum of public sentiment
+swung back from this precedent and brought about
+a great revulsion to this practice.</p>
+
+<p>In the beginning of the thirteenth century the penalty
+for refusing to plead consisted merely of a severe
+punishment, with low diet, until the obstinacy was
+overcome, and latterly, the practice prevailed, which
+had no legal sanction, of tying the thumbs together,
+with whipcord, that the pain might induce the prisoner
+to plead.</p>
+
+<p>During the reign of Edward I., in the year 1275,
+in the proceedings of the Parliament of Westminster,
+the first mention is made of this punishment for standing
+mute through obstinacy or wilfullness. It was enacted
+by this statute that felons refusing to plead
+through obstinacy should be confined in the prison, <i>forte
+et dure</i>. They were to go “barefooted and bareheaded,
+in their coat only, in prison, upon the bare ground continually,
+night and day, fastened down with irons,”
+only eating and drinking on alternate days, until the
+plea was entered.<a id="FNanchor_389" href="#Footnote_389" class="fnanchor">[6]</a> But the courts could not wait for
+the obstinate prisoners to voluntarily renounce their
+obduracy and succumb to such mild treatment and the
+accumulation of cases where the prisoner stood mute
+and the growing popularity of this offense, seemed to
+threaten the speedy dispatch of the criminal business
+of the period. Starvation was then added to the punishment
+of confinement, but this did not accomplish the<span class="pagenum"><a id="Page_176"></a>[176]</span>
+desired end, of forcing these obdurate offenders to
+consent to be tried, according to the custom then obtaining.</p>
+
+<p>As before seen, the first statute, touching upon this
+punishment, passed during the reign of Edward I., applied
+only to “notorious felons,” who were “openly
+of evil name,” for these alone, refusing to plead before
+the justices at the King’s suit, were to have the “strong
+and hard punishment,” that the act called for, and
+by express statutory exception prisoners “taken upon
+light suspicion” were not to suffer the punishment.<a id="FNanchor_390" href="#Footnote_390" class="fnanchor">[7]</a></p>
+
+<p>Some writers have taken the position that the punishment,
+<i>peine forte et dure</i> owed its existence alone to
+this statute, but Sir Edward Coke states that the
+punishment was assessed at common law, before the
+enactment of this statute,<a id="FNanchor_391" href="#Footnote_391" class="fnanchor">[8]</a> and the statute in merely
+providing for an imprisonment <i>forte et dure</i>, was declaratory
+of an existing punishment assessed by the
+common law, but not sufficiently described, or limited.</p>
+
+<p>This view is shared by Reeves, who states that this
+method of treating felons who stood mute was introduced
+sometime between the fifth year of the reign of
+King Henry III. or perhaps from the time of Bracton,
+and the third year of King Edward I. and the punishment
+did not owe its existence to this statute.<a id="FNanchor_392" href="#Footnote_392" class="fnanchor">[9]</a></p>
+
+<p>However this may be, we find that during the reign
+of Henry IV. the mild punishment provided for by the
+statute of Edward I. and the proceedings detailed by
+Fleta and Britton,<a id="FNanchor_393" href="#Footnote_393" class="fnanchor">[10]</a> of merely being fastened down<span class="pagenum"><a id="Page_177"></a>[177]</span>
+with irons, on the bare ground of the prison, “until
+the plea was entered,” had given way to the harsher
+punishment of being compelled to lie under a “<i>peine</i>,”
+“<i>till they were dead</i>,” an event most likely to follow
+speedily from the quantity of weight or iron placed
+upon such prisoners. The <i>peine forte et dure</i>, as it
+was known, therefore, from the fifteenth to the eighteenth
+century, seems to have been firmly established as
+an institution of the English Criminal Law, during the
+time of Henry IV., and the reason for its existence
+is to be found in the object of the justices in eyre and
+justices of gaol delivery, of obviating the necessity of
+remaining for long periods in the English country
+towns, waiting for the mild effect of the formerly prevailing
+punishment, provided for by the statute of the
+reign of Edward I., in inducing prisoners charged with
+felony to consent to be tried.<a id="FNanchor_394" href="#Footnote_394" class="fnanchor">[11]</a></p>
+
+<p>The prevalency of the practice of standing mute in
+such cases, under the milder form of punishment, increased
+to such an extent that the patience of the justices
+was sorely tried. They determined, about the beginning
+of the fifteenth century, to put an end to such
+a practice, by furnishing such a harsh punishment that
+the example of inflicting it would discourage prisoners
+from thus defying the law, even if it resulted in the
+speedy and painful death of the offender. All exhortations
+and mild treatment were abandoned and the
+obdurate prisoner, thus defying the court, was sentenced
+to be literally “pressed to death,” unless he
+recanted and submitted himself to a trial, according
+to the fixed customs of the realm.</p>
+
+<p><span class="pagenum"><a id="Page_178"></a>[178]</span></p>
+
+<p>It may justly be doubted if the defiance of the majesty
+of the law by this failure to plead was sufficient to
+justify such a barbarous practice, with the object of
+compelling a respect for the law, or if the remedy was
+not really worse than the disease, but upon this philosophical
+phase of the subject we are not concerned.
+Whether justly or unjustly, this species of punishment
+obtained for three centuries and a half in the English
+criminal law and a great many concrete cases, illustrating
+the application of the custom, arose during this
+period. And it is interesting to note how the punishment
+was made more severe with the increasing prevalency
+of the offense.</p>
+
+<p>In the year 1219, when the first eyre of Henry III.’s
+reign was in session, a case arose for the instruction
+and advice of the King’s Council regarding the course
+to be pursued where the prisoner refused to plead.<a id="FNanchor_395" href="#Footnote_395" class="fnanchor">[12]</a></p>
+
+<p>It was decided that although the prisoner was
+charged with the gravest kind of a felony, he was to
+be safely kept in prison, but the imprisonment was not
+to endanger life or limb. No suggestion was made of
+attempting to compel the submission to a trial, and the
+details of assessing the punishment to be inflicted was
+left wholly to the discretion of the justices.<a id="FNanchor_396" href="#Footnote_396" class="fnanchor">[13]</a></p>
+
+<p>The cases occurring before the passage of the statute
+of Westminster in the reign of Edward I., show that
+the justices did not have any fixed method of handling
+the cases wherein the prisoner refused to plead, but
+took such course as seemed best suited to the individual<span class="pagenum"><a id="Page_179"></a>[179]</span>
+case before the court. Sometimes the expedient was
+resorted to of taking the verdict of an exceptionally
+strong jury and condemning the prisoner, if he was
+found guilty, regardless of whether he had formally
+entered his plea or not. During the Warwickshire eyre
+of 1221 Martin Pateshull pursued this course, on two
+different occasions.<a id="FNanchor_397" href="#Footnote_397" class="fnanchor">[14]</a> The prisoner stood mute and refused
+to plead, but the twelve hundredors and twenty-four
+other knights, having sworn to his guilt, he was
+hanged.<a id="FNanchor_398" href="#Footnote_398" class="fnanchor">[15]</a></p>
+
+<p>In 1222, on the refusal of a prisoner accused of receiving
+felons, to plead to the charge, at Westminster,
+the court merely committed him to prison, to be held
+in solitary confinement, although the townships and
+the knights of the shire had declared him guilty.<a id="FNanchor_399" href="#Footnote_399" class="fnanchor">[16]</a></p>
+
+<p>During Bracton’s time, the procedure does not seem
+to have taken the course that it did in later years, as
+he speaks of the method of compelling a man to place
+himself upon the country and states that he was considered
+undefended and quasi-convict, if he refused.<a id="FNanchor_400" href="#Footnote_400" class="fnanchor">[17]</a></p>
+
+<p>Thus, it appears that before the enactment of the
+statute of Edward I. the cases arising were determined
+without any fixed rule governing the punishment to
+be assessed, but a few years after this act, the prisoner
+was laden with irons and in the course of a short
+period the hideous <i>peine forte et dure</i> was developed.<a id="FNanchor_401" href="#Footnote_401" class="fnanchor">[18]</a></p>
+
+<p>During the reign of Edward III. the courts adopted
+starvation as a remedy for refusing to plead to an indictment<span class="pagenum"><a id="Page_180"></a>[180]</span>
+for murder, as the case of Cecelia Rygeway
+illustrates. She was indicted for the murder of her
+husband and refusing to plead, she obstinately stood
+mute. She was committed to prison and lived without
+meat or drink for a period of forty days and nights,
+when she was allowed to go free, as her wonderful
+longevity, without food, was ascribed to the influence
+of the Virgin Mary, whose intercession could only be
+reconciled with the innocence of the defendant.<a id="FNanchor_402" href="#Footnote_402" class="fnanchor">[19]</a></p>
+
+<p>Starvation was generally discarded sometime after
+the statute of Edward I. and after the reign of Henry
+IV. the <i>peine forte et dure</i> was the regular and lawful
+mode of punishing persons who stood mute and obstinately
+refused to plead in charges of felony.</p>
+
+<p>In 1442 Juliana Quick was arraigned upon a charge
+of high treason, for speaking contemptuously of the
+King, Henry VI. She refused to plead and it having
+been determined that her refusal was obstinate, rather
+than by an infirmity of nature, she was “pressed to
+death,” in a summary manner.</p>
+
+<p>The case of Margaret Clitherow, who was pressed
+to death at York, on Lady Day, March 25’, 1586, is
+most pathetic, as narrated by her spiritual adviser,<span class="pagenum"><a id="Page_181"></a>[181]</span>
+the good John Mush, a friendly priest. Margaret’s
+husband was a Protestant, but she was accused of
+harboring Jesuit and Seminary priests, of hearing mass
+and other similar offenses and so she was committed
+to York Castle and later was regularly arraigned in the
+Common Hall. When plied with the usual question,
+“Culprit, how will you be tried?” instead of making
+the usual answer, “By God and my country,” the prisoner
+refused to make any other answer than that she
+would be tried “by God and your consciences.” After
+repeated entreaties by the court, and continued obstinacy
+of the prisoner, she was committed to prison and
+during the intercession of the court Parson Whigington,
+a puritan preacher, labored long and hard with her
+to convince her that she ought to forego her obduracy
+and enter her plea, but she refused to do so. On her
+second arraignment, when the court seemed about to
+condemn her to the <i>peine forte et dure</i>, Parson Whigington
+spoke in the interest of the prisoner, calling the
+court’s attention to the fact that “this woman’s case
+is touching life and death; you ought not, either by
+God’s law, or man’s, to judge her to die upon the
+slender witness of a boy.” Entreating her twice again
+to renounce her obdurate plea and to throw her case
+upon the country, on her refusal, the court ordered “the
+law to take its course”; she had her arms pinioned
+with a cord, by the Sheriff and as she was led through
+the crowd, the jeers and taunts, ever levelled at the
+unfortunate, in keeping with “man’s inhumanity to
+man,” gave the Sheriff the idea that he was to soon
+become a popular man, by the murder of this defenseless<span class="pagenum"><a id="Page_182"></a>[182]</span>
+woman, so he proceeded to his work as if he were,
+in fact, a hero.</p>
+
+<p>She was urged to press the exemption of pregnancy,
+but refused, and the Lord Mayor of York, on his knees
+begged her to enter her formal plea to the charge
+against her and to submit to trial, as did her friend
+the good Parson Whigington. She stood firm, as if
+courting martyrdom, in an attempt to demonstrate
+the injustice of such a hideous punishment, and finally
+even the sympathetic Parson Whigington, after expressing
+his pity, left her and came again no more.</p>
+
+<p>Her execution having been set for Friday, as if in
+commemoration of the day when the gentle Saviour took
+his departure upon the cross of Calvary, this innocent
+woman, on Lady Day, in 1586, also suffered martyrdom
+and died her death, that the horrible example of this
+hideous punishment could be made the more detestable.
+She refused the offer of friends to add sufficient weight
+to dispatch her immediately, but subjected herself to
+the torture, as deliberately as any martyr ever took
+the rack. She was led bare legged and bare-footed
+through the street, with a loose gown to hide her nakedness
+and distributed alms to the idle spectators as
+she passed along. The inhuman wretch who acted as
+Sheriff was named Fawcett and with no instinct of
+decency or chivalry, he bade her “put off her apparel,”
+whereupon she pleaded on her knees, that she might
+be allowed to die in her “smock” and that “for the
+honor of womankind, they would not see her naked.”
+Fawcett refused this becoming plea, but finally, on
+the entreaty of her friends, she was allowed to die
+in a long loose linen robe she had made for the occasion.</p>
+
+<p><span class="pagenum"><a id="Page_183"></a>[183]</span></p>
+
+<p>She was placed flat upon the ground on her back,
+with a handkerchief on her face; a door was laid upon
+her body and her hands were bound by Fawcett to two
+posts, so that her arms and body made a perfect cross;
+even as the Holy One of Galilee was taunted by the mob
+who followed Him to Calvary, so this innocent soul
+was crossed by the taunts and gibes of the vulgar mob,
+until finally the weights were placed upon the door.
+A large, sharp stone had been placed under her back,
+and seven or eight hundred pound weight was placed
+on the door and this weight broke her ribs and caused
+them to burst through the flesh on her sides. She gave
+but a single cry and exclaimed: “Jesu, Jesu, Jesu,
+have mercy upon me.”<a id="FNanchor_403" href="#Footnote_403" class="fnanchor">[20]</a> Let us hope that with the wail
+of this lost soul the weeping Christ made room for
+the misguided martyr, in a realm where such Satanic
+tyranny and intolerable cruelty are unknown. Strange,
+is it not, that the death knell of this hideous and cruel
+procedure did not follow immediately, as a result of
+the aroused and outraged public feeling, after the
+death of this good woman, in this cruel manner? But
+when it is considered that such Satanic cruelty could
+have lasted for sixteen hundred years after the crucifixion
+of the Saviour—and that all traces of his presence
+are not entirely eliminated from the earth, as yet—it
+is quite evident that the ideals of holiness and righteousness
+are slow to permeate the hearts of all the
+human family.</p>
+
+<p>Anthony Arrowsmith stood mute and refused to
+plead to the charge of felony, in 1598, and was accordingly
+pressed to death, in the usual manner.<a id="FNanchor_404" href="#Footnote_404" class="fnanchor">[21]</a></p>
+
+<p><span class="pagenum"><a id="Page_184"></a>[184]</span></p>
+
+<p>Walter Calverly, of Calverly in Yorkshire, was arraigned
+at the York assizes in 1605, for murdering his
+two children and stabbing his wife, and on refusing to
+enter his plea he was pressed to death, in the castle, by
+a large iron weight, placed on his breast.<a id="FNanchor_405" href="#Footnote_405" class="fnanchor">[22]</a></p>
+
+<p>It would be impossible, in any reasonable space, to
+recount all the most interesting cases where this inhuman
+punishment was inflicted, during the last half
+of the sixteenth and the early part of the seventeenth
+centuries, as a great many prisoners underwent this
+torture about this time. For the nine years between
+1609 and 1618, for instance, there were thirty-two prisoners
+subjected to this punishment and among this
+number three were women, in Middlesex county alone.
+In the record of these cases the Clerk wrote the words:
+“<i>Mortuus en pen fort et dur</i>,” which furnished the sad
+epitaph for each of the beknighted sufferers who underwent
+this fearful punishment. The records show that
+many of these poor prisoners were totally destitute
+and suffered this punishment either through stupidity
+of the prisoner or of his counsel, or through obstinacy
+or indifference to his personal suffering and death.<a id="FNanchor_406" href="#Footnote_406" class="fnanchor">[23]</a></p>
+
+<p>In 1615 Sir Richard Weston, a prisoner of some note,
+was arraigned for the murder of Sir Thomas Overbury.
+He stood mute and obstinately refused to plead to the
+indictment, after being solemnly warned by the judges
+of the terrible consequences of his persisting in his
+defiance of the laws of his country. The proceedings
+were adjourned to give him time for reflection, but<span class="pagenum"><a id="Page_185"></a>[185]</span>
+on his continued obstinacy, he was adjudged to suffer
+the <i>peine forte et dure</i>.<a id="FNanchor_407" href="#Footnote_407" class="fnanchor">[24]</a></p>
+
+<p>Major Strangeways was pressed to death, at Newgate,
+in 1657, for obstinately refusing to plead to an
+indictment charging him with the murder of his brother-in-law,
+Mr. Fussell. At the Coroner’s inquest he was
+made to take the corpse by the hands and touch the
+wounds, upon the supposition that if he had committed
+the murder, the wounds would bleed afresh. Although
+he was innocent, according to this test, it availed him
+nothing, however, and he was placed upon trial at the
+Old Bailey, where so many tragedies were enacted, in
+the olden time, in the name of the law, and refusing
+to plead and standing mute, in order to prevent the
+attainder of his blood and the forfeiture of his estate,
+resulting from his conviction, so certain to follow his
+trial, he was condemned to the <i>peine forte et dure</i>.
+The press was placed upon him angle-wise and although
+of sufficient weight to cause him much pain, it was
+not heavy enough to kill him, so the spectators, through
+pity, no doubt, for the sufferer, added the weight of
+their bodies to that of the press and soon he was out
+of his suffering and in keeping with the custom of<span class="pagenum"><a id="Page_186"></a>[186]</span>
+the period his dead body was displayed to the vulgar
+gaze,<a id="FNanchor_408" href="#Footnote_408" class="fnanchor">[25]</a> that the morbidly curious could advertise the
+details of the tragedy and thus deter other offenders
+from a similar offense.</p>
+
+<p>In the year 1720, a man named Phillips, who stood
+mute and refused to plead to an indictment for felony,
+was adjudged to undergo the <i>peine forte et dure</i>; he was
+placed under the press at Newgate and suffered the
+torture for a considerable time, until he concluded to
+enter his plea of not guilty and stand trial, in the ordinary
+manner, so the press was removed and he entered
+his plea and stood trial.<a id="FNanchor_409" href="#Footnote_409" class="fnanchor">[26]</a></p>
+
+<p>And in the following year, one Nathaniel Hawes,
+upon his arraignment for a felony, stood mute and
+obstinately refused to enter his plea and on being
+sentenced to the <i>peine forte et dure</i>, he suffered the
+pressure of a weight of two hundred and fifty pounds
+for a period of seven minutes and then gave up his
+resolution and craved the privilege of entering his
+plea and throwing himself upon the country in his
+trial.<a id="FNanchor_410" href="#Footnote_410" class="fnanchor">[27]</a></p>
+
+<p>In 1726 a man named Burnworth, arraigned for
+murder, concluded that he would stand mute and try
+the effects of the <i>peine forte et dure</i>. He was sentenced
+at Kingston to suffer this punishment for his obstinate
+defiance of his country’s laws and after being pressed
+for an hour and three-quarters, with four hundred
+pounds of iron, his will was broken. He was taken to
+the dock and was tried, convicted and hanged.<a id="FNanchor_411" href="#Footnote_411" class="fnanchor">[28]</a></p>
+
+<p><span class="pagenum"><a id="Page_187"></a>[187]</span></p>
+
+<p>From the number of reported cases that have been
+inspected, it seems that a great many were unable to
+withstand the suffering resulting from the application
+of the weight to their bodies, but when the torture
+was experienced, they would weaken and conclude to
+enter their plea.</p>
+
+<p>This was true of John Durant, who was arraigned
+at the Old Bailey, in 1734. Upon his obstinately refusing
+to enter his plea upon a charge of felony, his thumbs
+were first tied together with whipcord and the Sheriff
+pulled him up taut in the presence of the court and
+the latter dignitary promised him the <i>peine forte et
+dure</i>, forthwith, if he did not regularly enter his plea
+to the indictment. On reflection, he concluded to do
+this, so he was placed upon his trial and filed his plea
+of not guilty.<a id="FNanchor_412" href="#Footnote_412" class="fnanchor">[29]</a></p>
+
+<p>As late as the year 1741, it is reported that a prisoner
+was pressed to death, at the Cambridge assizes,
+for standing mute and refusing to plead to a charge of
+felony, after the tying of his thumbs and other customary
+procedure was found to be unavailing.<a id="FNanchor_413" href="#Footnote_413" class="fnanchor">[30]</a></p>
+
+<p>The only instance noted in which this punishment
+was ever inflicted in the United States, was in the case
+of Giles Cory, of Salem, who stood mute and obstinately
+refused to plead, when arraigned upon a charge
+of witchcraft and sorcery.<a id="FNanchor_414" href="#Footnote_414" class="fnanchor">[31]</a></p>
+
+<p>He was arraigned at Salem, in April, 1692, before
+Hawthorn and Jonathan Curwin. “Mary Walcott,
+Mercy Lewis, Ann Putnam, Jr., and Abigail Williams
+affirmed he had hurt them.” He was accused of giving<span class="pagenum"><a id="Page_188"></a>[188]</span>
+Elizabeth Hubbard a fit; of hurting Benjamin Gold;
+of bringing the book to these various witnesses; of
+being frightened in the cowhouse and of threatening
+suicide.<a id="FNanchor_415" href="#Footnote_415" class="fnanchor">[32]</a></p>
+
+<p>On September 16’ “just as the Autumn leaves were
+beginning to glorify the earth,” he was laid upon the
+ground, bound hand and foot; stones were piled upon
+him, till the tongue was pressed out of his mouth.
+The Sheriff with his cane, forced it in again, when he
+was dying.<a id="FNanchor_416" href="#Footnote_416" class="fnanchor">[33]</a> And he was the first and last to die for
+this offense in New England.</p>
+
+<p>In his account of this trial, in the “New England
+Tragedies,” the gentle Longfellow, has made Cory
+thus explain to Richard Gardner, why he refused to
+plead:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“I will not plead.</div>
+ <div class="verse indent0">If I deny, I am condemned already,</div>
+ <div class="verse indent0">In Courts where ghosts appear as witnesses,</div>
+ <div class="verse indent0">And swear men’s lives away—If I confess,</div>
+ <div class="verse indent0">Then I confess a lie, to buy a life,</div>
+ <div class="verse indent0">Which is not life, but only death in life.</div>
+ <div class="verse indent0">I will not bear false witness against any,</div>
+ <div class="verse indent0">Nor even against myself, whom I count least.”</div>
+ </div>
+</div>
+</div>
+
+<p>The Sheriff then calls him to his punishment and
+Cory answers him:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“I come.</div>
+ <div class="verse indent0">Here is my body. Ye may torture it,</div>
+ <div class="verse indent0">But the immortal soul, ye cannot crush.”</div>
+ </div>
+</div>
+</div>
+
+<p>Gloyd wonders if</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“The old man will die and will not plead,”</div>
+ </div>
+</div>
+</div>
+
+<p class="noindent">and while thus wondering, arrives too late to view the
+test of martyrdom.</p>
+
+<p><span class="pagenum"><a id="Page_189"></a>[189]</span></p>
+
+<p>In Scene IV. of this tragedy, based upon this sad
+miscarriage of justice in this New England case, the
+field near the graveyard is presented, with Cory lying
+dead, with a great stone upon his breast.</p>
+
+<p>Hathorn and Mather are introduced to the spectators
+and make a vain attempt to explain and justify
+the deed and the former points to the dead body of
+Cory as a horrible example of</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Those who deal in witchcraft and when questioned,</div>
+ <div class="verse indent0">Refuse to plead their guilt or innocence</div>
+ <div class="verse indent0">And stubbornly drag death upon themselves.”</div>
+ </div>
+</div>
+</div>
+
+<p>But Mather, not satisfied with the proceeding, is
+thus made to deliver himself:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“In a land like this,</div>
+ <div class="verse indent0">Spangled with churches, Evangelical,</div>
+ <div class="verse indent0">Inwrapped in our salvation, must we seek,</div>
+ <div class="verse indent0">In mouldering statute-books of English courts,</div>
+ <div class="verse indent0">Some old, forgotten Law, to do such deeds?</div>
+ <div class="verse indent0">Those who lie buried in the Potter’s field,</div>
+ <div class="verse indent0">Will rise again, as surely as ourselves</div>
+ <div class="verse indent0">That sleep in honored graves, with epitaphs,</div>
+ <div class="verse indent0">And this poor man, whom we have made a victim,</div>
+ <div class="verse indent0">Hereafter will be counted as a martyr.”<a id="FNanchor_417" href="#Footnote_417" class="fnanchor">[34]</a></div>
+ </div>
+</div>
+</div>
+
+<p>The <i>peine forte et dure</i>, as an institution of the
+English courts, continued in effect, as a part of the
+criminal procedure of the kingdom, until the year 1772,
+when the statute 12 George III., c. 20, virtually abolished
+the punishment of pressing prisoners to death
+for standing mute, when called upon to plead.</p>
+
+<p>This statute declared that any person who should
+stand mute and refuse to plead, when arraigned for<span class="pagenum"><a id="Page_190"></a>[190]</span>
+felony or piracy, should be convicted, and suffer judgment
+and sentence to be rendered against him, the same
+as if he had been regularly convicted, by verdict or
+confession.</p>
+
+<p>This procedure was again changed in England, in
+the year 1827 by the more humane rule, that upon a
+failure or refusal of the defendant in a felony charge
+to plead to the indictment, “a plea of not guilty should
+be entered for the person accused,”<a id="FNanchor_418" href="#Footnote_418" class="fnanchor">[35]</a> and he was thus
+given the benefit of the legal presumption of innocence,
+which the criminal law surrounds all prisoners with
+and he could be convicted and sentenced for the offense
+charged in the indictment only after this presumption
+of innocence had been overcome by the proof of his
+guilt, even though he stood mute and refused to enter
+his formal plea.</p>
+
+<p>This latter statute, in substance, has been adopted
+in most of the United States and the cases arising
+under these statutes illustrate the beneficence of the
+new procedure.</p>
+
+<p>In Commonwealth vs. Braley,<a id="FNanchor_419" href="#Footnote_419" class="fnanchor">[36]</a> in the year 1804, the
+defendant stood mute and refused to plead and the
+court proceeded to empanel a jury to try the defendant
+to ascertain if he stood mute wilfully, or by Act
+of God, just as the court proceeded when the <i>peine forte
+et dure</i> was in force and on the return of the verdict
+that the defendant wilfully refused to plead, the court
+remanded him to jail.</p>
+
+<p>In Commonwealth vs. Moore,<a id="FNanchor_420" href="#Footnote_420" class="fnanchor">[37]</a> in the year 1812, the
+defendant was arraigned upon a charge of larceny and<span class="pagenum"><a id="Page_191"></a>[191]</span>
+stood mute and upon a finding of the jury that he stood
+mute through wilfullness, the court proceeded to sentence
+him, just as if he had been regularly convicted,
+evidently proceeding under the statute, 12 George III.,
+c. 20.</p>
+
+<p>In State vs. Hare, in the year 1818, in Maryland, the
+prisoner stood mute and refused to plead, but the court
+entered up a plea of not guilty for him and proceeded
+to try him, just as if he had himself entered his formal
+plea. This enlightened procedure was adopted by
+Congress at the beginning of the past century, in all
+cases where prisoners stood mute.</p>
+
+<p>It was provided by Act of Congress, March 3’, 1825,
+that</p>
+
+<div class="blockquote">
+
+<p>“If any person, upon his or her arraignment, upon
+any indictment, before any court of the United States,
+for any offense not capital, shall stand mute or will
+not answer or plead to such indictment, the court shall
+notwithstanding, proceed to the trial of the person
+so standing mute, or refusing to answer or plead, as
+if he or she had pleaded not guilty, and, upon a verdict
+being returned by the jury, may proceed to render
+judgment accordingly.”<a id="FNanchor_421" href="#Footnote_421" class="fnanchor">[38]</a></p>
+
+</div>
+
+<p>Since the enactment of this federal statute, similar
+acts have been adopted in most of the United States
+and the practice now quite generally obtains of entering
+a formal plea of not guilty, whenever the prisoner
+stands mute, for any reason and the trial proceeds
+just as if the defendant had himself entered his plea.<a id="FNanchor_422" href="#Footnote_422" class="fnanchor">[39]</a></p>
+
+<p><span class="pagenum"><a id="Page_192"></a>[192]</span></p>
+
+<p>The punishment for standing mute and refusing to
+plead, as one of the cruel and extreme methods of procedure
+of the olden times, has attracted the attention
+of the poets and writers in the English language.</p>
+
+<p>Shakespeare makes frequent reference to this punishment
+and always in such manner as to demonstrate
+that he was thoroughly familiar with the nature and
+object of the procedure governing the infliction of the
+penalty upon those who obstinately stood mute, when
+called upon to plead to indictments for felonies.</p>
+
+<p>Thus, in “Much Ado About Nothing” he makes
+Hero say to Ursula, when speaking of Beatrice, in the
+Orchard of Leonato:<a id="FNanchor_423" href="#Footnote_423" class="fnanchor">[40]</a></p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Hero.</i> No, not to be so odd and from all fashions</div>
+ <div class="verse indent0">As Beatrice is, cannot be commendable;</div>
+ <div class="verse indent0">But who dare tell her so? If I should speak,</div>
+ <div class="verse indent0">She would mock me into air; O, she would laugh me</div>
+ <div class="verse indent0">Out of myself, press me to death with wit.”<a id="FNanchor_424" href="#Footnote_424" class="fnanchor">[41]</a></div>
+ </div>
+</div>
+</div>
+
+<p>In “Measure for Measure,” when the Duke adjudged
+that Lucio should marry the woman he had wronged,
+the latter replied:</p>
+
+<div class="blockquote">
+
+<p>“<i>Lucio.</i> Marrying a punk, my lord, is pressing to death, whipping
+and hanging.”<a id="FNanchor_425" href="#Footnote_425" class="fnanchor">[42]</a></p>
+
+</div>
+
+<p>In Richard II., on overhearing the talk of the Gardener
+and servant, in the Duke of York’s garden, concerning
+the King, the Queen soliloquizes</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Queen.</i> O, I am pressed to death through want of speaking,”<a id="FNanchor_426" href="#Footnote_426" class="fnanchor">[43]</a></div>
+ </div>
+</div>
+</div>
+
+<p class="noindent">as if she were really in the dock and actually conditioned
+so that she would suffer the customary penalty
+for standing mute.</p>
+
+<p><span class="pagenum"><a id="Page_193"></a>[193]</span></p>
+
+<p>Pandarus also refers to the <i>peine forte et dure</i>, in
+Troilus and Cressida, in advising them to “press” the
+bed to death because it stands mute as to their “pretty
+encounters” thereon:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Pan.</i> ... I will show you a chamber and a bed,</div>
+ <div class="verse indent0">Which bed, because it shall not speak of your pretty encounters,</div>
+ <div class="verse indent0">Press it to death: away.”<a id="FNanchor_427" href="#Footnote_427" class="fnanchor">[44]</a></div>
+ </div>
+</div>
+</div>
+
+<p>By a study of the old cases, decided when the <i>peine
+forte et dure</i> obtained, the development of the law on
+this subject, can best be understood, for like landmarks,
+pointing the devious course of the tortuous procedure
+that obtained for centuries, before the evolution of the
+science, to the point where it was able to preserve the
+just rights of the individual, consistently with the demands
+of society, the later cases evidence the gradual
+decline of the old, harsh punishment for standing mute,
+and thus, with the abolition of this quandam formal
+procedure, that was considered such a material part
+of the old criminal law of England, the law itself has
+reached a higher plane, from which we can look down
+upon the crudities and cruelties of the old system,
+with pity for the multitudes who were subjected to its
+harsh rules and false standards. And judging the
+future by the past, we can indulge the hope that many
+of our own formal procedures will be amended and abolished,
+to the end that unjust results and delays may be
+minimized and the attainment of just ideals promoted.</p>
+
+<p>The science of the law should keep pace with the
+advance of the student of philosophy. The law should
+ever stand aloof—even as a just parent—from any
+punishment prompted solely through the mad power of<span class="pagenum"><a id="Page_194"></a>[194]</span>
+might. When it has attempted to inflict punishment
+unjustly, the causes and effects, the advantages, if
+any and the disadvantage of such procedure, should
+be thoroughly scrutinized. Laws are man-made, in
+popular governments and the laws should be improved
+for the benefit of the people.</p>
+
+<p>We have seen that for centuries, upon the obstinate
+refusal of a prisoner charged with felony, to enter his
+plea, the inhuman judgments of the courts—established
+for the administration of justice—were that he should
+be literally “pressed to death,” regardless of his guilt
+or innocence of the charge that he was called upon to
+answer.</p>
+
+<p>With the passing of this horrible institution—as
+with others of the past centuries—we can perhaps congratulate
+ourselves, that with the evolution of the institutions
+of our civilization, humanity has generally
+triumphed over inhumanity and the mistakes of our
+ancestors, although most dearly bought, furnish a lasting
+object lesson for present and future generations.
+Every generation, however, has its follies and mistakes
+and nonsense is not confined wholly to the past ages, but
+with the errors of the past before us, we ought to avoid
+the same mistakes that it took such suffering and
+experience to correct.</p>
+
+<p>However unwise and unjust the standards of our
+ancestors may have been, which made possible the
+wholesale legal murder of thousands of human beings,
+who, for different reasons, defied the fetish and barbarous
+custom that developed the cruel institution,
+<i>peine forte et dure</i>, this institution, like many others of
+the past, ought to warn us, like a beacon light, of the<span class="pagenum"><a id="Page_195"></a>[195]</span>
+dangerous shoals and reefs, which the ship of state
+should be safely piloted around. But our own procedure
+contains many incongruities and erroneous standards,
+that should be corrected, and while priding ourselves
+upon the fact that nothing so inhuman as “pressing
+to death,” obtains today, we are still guilty of many
+“crimes against criminals,” which succeeding ages, in
+the perfection of the science of jurisprudence, will no
+doubt regard in much the same light as we of the present
+age look upon the cruel punishment, <i>peine forte et
+dure</i>.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_384" href="#FNanchor_384" class="label">[1]</a> The terms are pronounced pān fōrt ā dūr.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_385" href="#FNanchor_385" class="label">[2]</a> II. Reeve’s History English Law, p. 423.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_386" href="#FNanchor_386" class="label">[3]</a> Coke, 2 Inst. 178, 179; Hale’s P. C. vol. ii., 322.</p>
+
+<p>“He was to be laid down, naked, upon the ground, on his back,
+his feet and head and loins covered, his arms and legs drawn apart,
+by cords, and as much weight of iron or stone as he could bear,
+was placed upon his chest.” This punishment was called also,
+“pressing to death.” Bouvier’s Dictionary; II. Reeve’s History
+English Law, 134; 4 Sh. Bl. Comm. 324; Britton, ch. 4 fol. ii;
+Fleta, lib. I., 34, sec. 33.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_387" href="#FNanchor_387" class="label">[4]</a> Coke, Litt. 130a, 391; 6 Coke, 63a, 63b; I. Bishop’s Crim. Law,
+641.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_388" href="#FNanchor_388" class="label">[5]</a> II. Essays in Anglo-American Legal History, 392, 396, 486, 488.</p>
+
+<p>There is no doubt but that for a long time after the year 1215,
+the law did not know what to do with a man who stood mute and
+refused to plead and the <i>peine forte et dure</i> was an institution
+slowly and painfully evolved from the customs of the past. II.
+Pollock and Maitland’s History English Law, p. 650.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_389" href="#FNanchor_389" class="label">[6]</a> II. Reeve’s History English Law, p. 423; Stat. West. l. c. 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_390" href="#FNanchor_390" class="label">[7]</a> Statute West, l. c. 12; II. Reeve’s History English Law, p. 423.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_391" href="#FNanchor_391" class="label">[8]</a> 2 Inst. 178, 179.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_392" href="#FNanchor_392" class="label">[9]</a> II. Reeve’s History English Law, p. 424.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_393" href="#FNanchor_393" class="label">[10]</a> Britton, fol. 11, c. iv; Fleta, lib. l. c. 29, sec. 33.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_394" href="#FNanchor_394" class="label">[11]</a> III. Reeve’s History English Law, 439.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_395" href="#FNanchor_395" class="label">[12]</a> Leges Henri, 31, sec. 5; Foedera, i, 154; Palgrave, Commonwealth,
+207; Thayer, Harvard Law Review, V., p. 265; II. Pollock
+and Maitland’s History English Law, p. 650.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_396" href="#FNanchor_396" class="label">[13]</a> II. Pollock and Maitland’s History English Law, p. 650.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_397" href="#FNanchor_397" class="label">[14]</a> II. Pollock and Maitland’s History English Law, p. 651.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_398" href="#FNanchor_398" class="label">[15]</a> Select Pleas of Crown, pl. 153, 157; Hale’s Pl. Cr. ii, 322.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_399" href="#FNanchor_399" class="label">[16]</a> Note Book, pl. 136.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_400" href="#FNanchor_400" class="label">[17]</a> Bracton, fol. 142b, 143b.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_401" href="#FNanchor_401" class="label">[18]</a> Year Book 30, I. Edward I., 511, 503, 531; Britton, i, 26; Fleta,
+p. 51; II. Pollock and Maitland’s History English Law, p. 652.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_402" href="#FNanchor_402" class="label">[19]</a> Watt’s “The Law’s Lumber Room.”</p>
+
+<p>During the reign of Henry VII., we find two felons, who had
+been taken from sanctuary, at Southwark, on being arraigned before
+Sir Thomas Frowike urged their plea of sanctuary, which was
+overruled, and, on being commanded to plead to the felonies, and
+refusing, they were peremptorily ordered to be taken back to the
+jail and there placed upon the bare ground, and that more weight
+should be placed upon them than they could stand and they be
+given only bread and water, until they die; in short, that they
+be literally <i>pressed to death</i>, or suffer the terrible <i>peine forte et
+dure</i>. (21 Henry VII., Keilway, 70; IV. Reeve’s History English
+Law, Finlason’s note, p. 254.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_403" href="#FNanchor_403" class="label">[20]</a> Law Notes, May, 1910, p. 32; Watt’s “The Law’s Lumber Room.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_404" href="#FNanchor_404" class="label">[21]</a> Surtee’s History of Durham, vol. iii, p. 271.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_405" href="#FNanchor_405" class="label">[22]</a> Stow’s Chronicle.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_406" href="#FNanchor_406" class="label">[23]</a> Watt’s “The Law’s Lumber Room.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_407" href="#FNanchor_407" class="label">[24]</a> Law Notes for May, 1910, p. 31; Watt’s “The Law’s Lumber
+Room.”</p>
+
+<p>According to Rushworth, when John Felton was arraigned for
+the assassination of the Duke of Buckingham, in November, 1628,
+the Privy Council debated the question of their right to place the
+prisoner on the rack. It was finally decided that:</p>
+
+<p>“Torture was not, with one exception, permitted at all, and in
+that one exception, it was permitted neither as a punishment nor
+as a means of getting evidence, but as a <i>persuasion</i>, to induce a
+man charged with felony, to put himself upon his trial.”</p>
+
+<p>Vol. 44, Chamber’s Journal, pt. Jan.-June, 1867, p. 373.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_408" href="#FNanchor_408" class="label">[25]</a> Watt’s “The Laws Lumber Room”; Law Notes, for May, 1910, p. 33.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_409" href="#FNanchor_409" class="label">[26]</a> Stowe’s Chronicle.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_410" href="#FNanchor_410" class="label">[27]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_411" href="#FNanchor_411" class="label">[28]</a> Watt’s “The Law’s Lumber Room.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_412" href="#FNanchor_412" class="label">[29]</a> Watt’s “The Law’s Lumber Room.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_413" href="#FNanchor_413" class="label">[30]</a> XI Inter. Enc. <i>Sub. Nom.</i> <i>Peine forte et dure.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_414" href="#FNanchor_414" class="label">[31]</a> Washburn, Jud. History, 142; I. Chandler, Cr. Trials, 122.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_415" href="#FNanchor_415" class="label">[32]</a> “Wonders of the Invisible World,” by Robt. Calef (1828), pp.
+329, 333.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_416" href="#FNanchor_416" class="label">[33]</a> “The Spirits in 1692,” Putnam’s Magazine, for January and
+June, 1856, No. 7, p. 509.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_417" href="#FNanchor_417" class="label">[34]</a> Longfellow’s “New England Tragedies.”</p>
+
+<p>Tradition has it that Cory was pressed to death in an open field,
+between the Howard street burial ground and Brown street, in
+Salem.</p>
+
+<p>Nevins, “Witchcraft in Salem Village, in 1692,” p. 107.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_418" href="#FNanchor_418" class="label">[35]</a> 7 and 8 George III., c. 28.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_419" href="#FNanchor_419" class="label">[36]</a> I. Mass. 103.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_420" href="#FNanchor_420" class="label">[37]</a> 9 Mass. 402.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_421" href="#FNanchor_421" class="label">[38]</a> 3 Story, U. S. Laws, 2002 Sec. 14.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_422" href="#FNanchor_422" class="label">[39]</a> Fernandez vs. State, 7 Ala. 511; People vs. Thompson, 4 Cal.
+238; Johnson vs. People, 22 Ill. 314; State vs. McCombs, 13 Iowa,
+426; Commonwealth vs. Lannon, 95 Mass. 563, holding that the old
+rule in this state was changed by statute; Thomas vs. State, 6 Mo.
+457; Link vs. State, 50 Tenn. (3 Heisk.) 252.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_423" href="#FNanchor_423" class="label">[40]</a> Act III., Scene I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_424" href="#FNanchor_424" class="label">[41]</a> White’s “Law in Shakespeare,” sec. 40, p. 67.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_425" href="#FNanchor_425" class="label">[42]</a> Measure for Measure, Act V., Scene I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_426" href="#FNanchor_426" class="label">[43]</a> Richard II., Act III., Scene IV.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_427" href="#FNanchor_427" class="label">[44]</a> Troilus and Cressida, Act III., Scene II.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_196"></a>[196]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_VII">CHAPTER VII.<br>
+<span class="smcap">Wager of Law.</span></h2>
+
+</div>
+
+<p>Wager of law, in ancient England, was the practice
+whereby the defendant was allowed to make oath denying
+the charge of the complainant and supporting
+his oath by the oaths of a certain number of his friends
+or neighbors.<a id="FNanchor_428" href="#Footnote_428" class="fnanchor">[1]</a></p>
+
+<p>The term <i>wager of law</i>, comes from the Roman law
+<i>vadiatio legis</i>, from the defendant being put in pledges
+(<i>vadios</i>), to make oath on the day appointed.<a id="FNanchor_429" href="#Footnote_429" class="fnanchor">[2]</a></p>
+
+<p>The practice is traceable to the Mosaic law which
+provided that:</p>
+
+<div class="blockquote">
+
+<p>“If a man deliver unto his neighbor an ass, or an
+ox, or a sheep, or any beast, to keep; and it die, or be
+hurt, or driven away, no man seeing it; then shall an
+oath of the Lord be between them both, that he hath
+not put his hands unto his neighbors’ goods; and the
+owner of it shall accept thereof, and he shall not make
+it good.”<a id="FNanchor_430" href="#Footnote_430" class="fnanchor">[3]</a></p>
+
+</div>
+
+<p>Under the Mosaic law, the rule of practice which
+now obtains in criminal cases, that the good character
+or reputation of the defendant is always proper for him
+to offer, in his own defense, upon the issue of the likelihood
+of his commission of a crime, was extended to
+include his right to actually acquit himself of the debt
+or other cause of action by his own oath, for if he would
+absolutely swear himself not chargeable and was a
+person of good reputation, he stood acquitted of the
+charge, in order to prevent an innocent man from being
+overcome by a multitude of false witnesses.</p>
+
+<p><span class="pagenum"><a id="Page_197"></a>[197]</span></p>
+
+<p>This method of procedure, or similar practices obtained
+in ancient Babylon,<a id="FNanchor_431" href="#Footnote_431" class="fnanchor">[4]</a> among the Romans and the
+northern nations, adjacent to the Roman Empire, as
+well as among the ancient Israelites.<a id="FNanchor_432" href="#Footnote_432" class="fnanchor">[5]</a></p>
+
+<p>He who waged his law, under the old Saxon procedure,
+brought with him, into court, eleven of his
+neighbors, for by the constitution entered into as a
+league between Alfred and Guthrun, the Dane, a man’s
+credit, in a court of law, depended upon his reputation
+among his neighbors, touching his veracity.</p>
+
+<p>The defendant who pleaded <i>nil debit</i>, or denied the
+charge against him, usually concluded his answer with
+the plea containing the formula:</p>
+
+<div class="blockquote">
+
+<p>“And this he is ready to defend against him, the said
+A. B. and his suit, as the court of our Lord, the King,
+shall here consider,” <i>etc.</i></p>
+
+</div>
+
+<p>He was then placed under surety to <i>wage his law</i>, on
+a day appointed by the judge and on the day named
+the defendant, in open court, took his oath, which was
+also confirmed by the oaths of eleven of his neighbors,
+called compurgators.</p>
+
+<p>The defendant stood at the end of the bar and was
+solemnly admonished by the judge of the nature and
+danger of a false oath and if he persisted, he repeated
+an oath like the following:</p>
+
+<div class="blockquote">
+
+<p>“Hear this, ye justices, that I do not owe unto A. B.
+the sum of ten pounds, nor any penny thereof, in manner<span class="pagenum"><a id="Page_198"></a>[198]</span>
+and form as the said A. B. hath declared against
+me, so help me God.”<a id="FNanchor_433" href="#Footnote_433" class="fnanchor">[6]</a></p>
+
+</div>
+
+<p>And thereupon his eleven compurgators avowed,
+upon their oaths, that they believed, in their consciences,
+that he saith the truth.</p>
+
+<p>The oath, therefore, of the defendant, himself, was
+<i>de fidelitate</i>, or on his fidelity, and the eleven compurgators
+testified <i>de credulitate</i> or upon their belief in his
+integrity.<a id="FNanchor_434" href="#Footnote_434" class="fnanchor">[7]</a></p>
+
+<p>These oaths had the legal effect of a verdict for the
+defendant, in all actions of debt, on a simple contract,
+or in actions of detinue, but the defense was not allowed
+to persons who did not enjoy a good reputation among
+their neighbors.</p>
+
+<p>The compurgators acted rather in the capacity of
+jurymen than as witnesses, for they swore to their
+belief, not to what they actually knew. In other words,
+when the accused made oath of his innocence or denied
+the charge filed against him, they swore that they believed
+he was swearing the truth. Yet they differed
+from jurymen in many important particulars. The jury
+was summoned by a public officer and took an oath to
+tell the truth, whatever the truth might be—for jurymen
+then did not sit in trial of issues as today—while
+the oath helper—or compurgator, merely took an oath
+to testify to the truth of his principal’s oath.<a id="FNanchor_435" href="#Footnote_435" class="fnanchor">[8]</a></p>
+
+<p><span class="pagenum"><a id="Page_199"></a>[199]</span></p>
+
+<p>There is authority for the proposition that in the
+earliest times, the oath-helpers were necessarily kinsmen
+of the defendant.<a id="FNanchor_436" href="#Footnote_436" class="fnanchor">[9]</a> The only obligation recognized
+by a defendant in either a civil or criminal case was to
+the injured party and no responsibility was predicated
+upon a duty owing to the state or to society at large.
+With the family as a unit, the person charged with a
+crime could summon his family to repulse an armed
+attack by the injured person and so he took them with
+him to the court, to defend him by their oaths.<a id="FNanchor_437" href="#Footnote_437" class="fnanchor">[10]</a> When
+a person was accused of a crime sufficient to result in
+a blood-feud, his kinsmen were vitally interested in
+his acquittal and it is but natural that they proffered
+their help as oath-helpers for him, but in due course of
+time, the relatives alone were not required and the
+compurgators rather assumed the character of disinterested
+“character witnesses,” such as we see today,
+in all criminal cases, except that instead of swearing
+merely to the good reputation of the defendant, these
+compurgators made oath of their firm belief in his oath
+of innocence of the charge filed against him or of the
+cause of action set up by the injured party.<a id="FNanchor_438" href="#Footnote_438" class="fnanchor">[11]</a></p>
+
+<p>By the laws of Wihtraed,<a id="FNanchor_439" href="#Footnote_439" class="fnanchor">[12]</a> in the seventh century,<span class="pagenum"><a id="Page_200"></a>[200]</span>
+the king or a bishop could rebut an accusation
+by his own simple asservation, and the thane or
+priest by the simple oath, while the laity generally
+were required to undergo the formal procedure of
+waging their law by the regular number of compurgators.</p>
+
+<p>Mr. Reeves, in his History of English Law, says
+that Glanville does not mention the wager of law, as
+a mode of proof for the defendant in civil suits,<a id="FNanchor_440" href="#Footnote_440" class="fnanchor">[13]</a> but
+in this the author must have meant to limit the statement
+to defenses only, for Glanville expressly describes
+the proceeding by the tenant, wherein he observes:</p>
+
+<div class="blockquote">
+
+<p>“If he should deny all the summonses, he shall, as
+to each of them individually, corroborate his denial
+with the oaths of twelve. Should it happen on the day
+appointed that either of the compurgators fail, or
+should the person of either of them be justly excepted
+to, and the vacancy occasioned by either of these circumstances
+not filled up, the tenant shall, on account
+of his default, immediately lose his seisin. But, if the
+tenant thus completely disprove the summonses, he
+shall, on the same day, answer to the action.”<a id="FNanchor_441" href="#Footnote_441" class="fnanchor">[14]</a></p>
+
+</div>
+
+<p>According to Sir Edward Coke, any one who waged
+his law, in a court of record, prior to <i>Magna Charta</i>, in
+England, was required to bring with him <i>Fideles
+Testes</i>,<a id="FNanchor_442" href="#Footnote_442" class="fnanchor">[15]</a> and this learned author intimates that the
+number of compurgators was eleven, besides the principal,<a id="FNanchor_443" href="#Footnote_443" class="fnanchor">[16]</a>
+while the author of “<i>Les Termes de la Ley</i>,”
+in describing the same ceremony, expressly states that
+the number of compurgators was twelve.<a id="FNanchor_444" href="#Footnote_444" class="fnanchor">[17]</a></p>
+
+<p><span class="pagenum"><a id="Page_201"></a>[201]</span></p>
+
+<p>Bracton advises us that it was not necessary that the
+compurgators should be of the same rank as the principal,
+provided they were trustworthy citizens,<a id="FNanchor_445" href="#Footnote_445" class="fnanchor">[18]</a> and,
+when treating of the wager of law, in actions by tenants,
+he states that the land was not to be taken out of the
+tenant’s possession before the tenant had waged his
+law, nor if he failed in waging it.<a id="FNanchor_446" href="#Footnote_446" class="fnanchor">[19]</a> And he states that
+the tenant could not wage his law by means of an attorney,
+constituted for that purpose, but was allowed
+to urge this plea, only by and through himself, personally.<a id="FNanchor_447" href="#Footnote_447" class="fnanchor">[20]</a></p>
+
+<p>In Bracton’s day, wager of law was the normal
+mode of defense and it was then the ordinary procedure
+for establishing that one had never been lawfully
+summoned to appear in court;<a id="FNanchor_448" href="#Footnote_448" class="fnanchor">[21]</a> that a defendant had
+not deprived a guardian of the lawful possession of
+his ward;<a id="FNanchor_449" href="#Footnote_449" class="fnanchor">[22]</a> that the defendant was not guilty of a
+breach of a covenant;<a id="FNanchor_450" href="#Footnote_450" class="fnanchor">[23]</a> that the defendant had not
+wrongfully detained or distrained the plaintiff’s cattle
+or other animals,<a id="FNanchor_451" href="#Footnote_451" class="fnanchor">[24]</a> and during this period it was even
+allowed by way of defense in an action of trespass.<a id="FNanchor_452" href="#Footnote_452" class="fnanchor">[25]</a></p>
+
+<p>According to Bracton, however, compurgation was
+not allowed to dispute evidence of offenses which were
+apparent to the senses, such as waste, which could be
+observed, as a physical condition, by any man, for if
+compurgation were allowed in such cases, the oath of<span class="pagenum"><a id="Page_202"></a>[202]</span>
+compurgators would be allowed to overcome the evidence
+of our senses, which would place a premium on
+perjury and destroy the best evidence by mere secondary
+proof.<a id="FNanchor_453" href="#Footnote_453" class="fnanchor">[26]</a></p>
+
+<p>The wager of law was not confined entirely to the
+defendant, however, for according to this author, if
+the defendant set up an affirmative defense, the plaintiff,
+by way of reply, was allowed to deny the affirmative
+defense and to establish his avoidance of the special
+defense pleaded by the aid of oath-helpers.<a id="FNanchor_454" href="#Footnote_454" class="fnanchor">[27]</a></p>
+
+<p>During the reign of Edward III., the right of a defendant
+to wage his law, was guaranteed in all cases
+where the right existed in the time of Edward I., the
+object of the statute being that “many people were
+grieved and attached by their bodies in the city of
+London, at the suit of citizens, surmising that they
+were debtors, and could be proved so by their papers,
+though they had no deed or tally to produce them,”
+it was therefore enacted that “every man should be
+received <i>to his law</i>, by people of his condition against
+such papers, and the creditor should not put the party
+to plead to the inquest unless he chose,”<a id="FNanchor_455" href="#Footnote_455" class="fnanchor">[28]</a> so the wager
+of law was thus preserved to the citizens of London,
+against mere papers, or verbal testimony as firmly as
+it was previously practiced in the common law courts.<a id="FNanchor_456" href="#Footnote_456" class="fnanchor">[29]</a>
+But it was provided by statute, during the same reign,
+that the fines payable before the justices, should be in
+the presence of the pledges, in all cases, civil or criminal,<span class="pagenum"><a id="Page_203"></a>[203]</span>
+and the pledges were to be advised of the sum of
+the fine, before they departed.<a id="FNanchor_457" href="#Footnote_457" class="fnanchor">[30]</a></p>
+
+<p>The law wager did not seem to be settled so securely
+that there was no doubt left, of the cases in
+which it would lie and those wherein it could not be
+invoked, in this reign, however, for while a defendant
+was denied wager of law, against his written obligation,<a id="FNanchor_458" href="#Footnote_458" class="fnanchor">[31]</a>
+he was allowed to wage his law, in a suit on a
+deed, by the plea of non-summons, in the same manner
+that such plea had long been used.<a id="FNanchor_459" href="#Footnote_459" class="fnanchor">[32]</a> It was allowed
+against a receipt, alleged to be by the hand of another
+than the defendant,<a id="FNanchor_460" href="#Footnote_460" class="fnanchor">[33]</a> and in detinue of charters it was
+allowed,<a id="FNanchor_461" href="#Footnote_461" class="fnanchor">[34]</a> although the charters related to the freehold
+and ought to be equally as binding upon a defendant
+as an obligation creating an action of debt.</p>
+
+<p>Wager of law was allowed in all cases where voluntary
+credit had been extended to the defendant, upon
+the theory that by giving him credit the plaintiff had
+estopped himself from denying that he was a man of
+good reputation, but wager of law was not permitted in
+charges created against the defendant by the law, for
+no man was allowed to thus swear away an obligation
+imposed by the law of the land.<a id="FNanchor_462" href="#Footnote_462" class="fnanchor">[35]</a></p>
+
+<p>It was denied in cases of contempt, trespass, fraud
+or deceit, or for damages for any injury with force;
+executors and administrators were not allowed, upon
+grounds of public policy, to deny under oath the obligations<span class="pagenum"><a id="Page_204"></a>[204]</span>
+of their testators, since no man could safely
+wage law of another’s contracts; the king had certain
+prerogatives, which prevented the wager of law, in
+actions by him, as all wagers of law naturally reflected
+upon the honesty of the plaintiff, so wager did not obtain
+in actions by the king.<a id="FNanchor_463" href="#Footnote_463" class="fnanchor">[36]</a></p>
+
+<p>And since the wager of law only obtained in favor
+of those who bore a good reputation for veracity, one
+who had been outlawed, or attainted for any felony,
+or one who had become infamous, or who had pronounced
+the horrible word, <i>craven</i>, in a trial by battle,
+was denied his wager of law.<a id="FNanchor_464" href="#Footnote_464" class="fnanchor">[37]</a></p>
+
+<p>And under the old practice, since infants, or those
+under twenty-one years were not admitted to take
+oaths, they were also denied the wager of law, but a
+married woman was allowed the defense, when sued
+jointly with her husband and it extended in favor of
+an alien, who was to be sworn in his own language.<a id="FNanchor_465" href="#Footnote_465" class="fnanchor">[38]</a></p>
+
+<p>In the thirteenth and fourteenth centuries compurgators
+were allowed, even in the most serious charges
+of felony, in England, on the part of a defendant. According
+to the London custom, in the “great law” used
+in murder cases, the defendant was required to swear
+six times, with six compurgators for each oath; in the
+“middle law,” used in charges of mayhem, three oaths,
+each backed by six oath-helpers, satisfied the law, and
+in “the third law,” used in the smaller offenses, a<span class="pagenum"><a id="Page_205"></a>[205]</span>
+single oath, corroborated by six helpers, satisfied the
+law.<a id="FNanchor_466" href="#Footnote_466" class="fnanchor">[39]</a></p>
+
+<p>In course of time the “great law” was found to be
+so onerous that the rule requiring six separate compurgators
+to as many separate oaths by the defendant
+was relaxed, so as to allow him to make his compurgation
+by one oath, supported by thirty-six helpers, but
+if any one of these failed to support his oath, he was
+hanged.<a id="FNanchor_467" href="#Footnote_467" class="fnanchor">[40]</a></p>
+
+<p>And by the last of the fourteenth century even when
+charged with the capital crime of murder, a citizen
+liable under the “great law,” which formerly required
+him to make his compurgation by thirty-six oath-helpers,
+was allowed to either make his compurgation
+in this manner, or, at his election, to go to trial before
+a jury of twelve men, for by this period the trial by
+jury was beginning to take its place as one of the fixed
+institutions in the administration of the criminal law
+of England.<a id="FNanchor_468" href="#Footnote_468" class="fnanchor">[41]</a></p>
+
+<p>The trial by oath-helpers, even in murder cases, was
+not speedily superceded by the trial by jury, however,
+for as late as the fifteenth century, according to Palgrave,
+purgation with thirty-six oath-helpers, was allowed
+at Winchelsea and in other jurisdictions subject
+to the English common law.<a id="FNanchor_469" href="#Footnote_469" class="fnanchor">[42]</a></p>
+
+<p><span class="pagenum"><a id="Page_206"></a>[206]</span></p>
+
+<p>By the time of Henry VI., we find the cases in which
+wager of law was allowed still open to much discussion.
+It was recognized in actions of debt and detinue<a id="FNanchor_470" href="#Footnote_470" class="fnanchor">[43]</a>
+and in the action of account, it came to be the
+custom for the justices to examine the attorney for the
+plaintiff and other persons and to allow or refuse the
+wager of law to the defendant,<a id="FNanchor_471" href="#Footnote_471" class="fnanchor">[44]</a> accordingly as the
+account was found to be an account stated in the
+presence of auditors, in which case it was not allowed,
+or an account not taken in the presence of auditors,
+where the wager was held to obtain.<a id="FNanchor_472" href="#Footnote_472" class="fnanchor">[45]</a> The theory of
+denying the wager to cases where an account was had
+in the presence of auditors was that such an account
+arose to the dignity of an obligation admitted before
+competent judges.<a id="FNanchor_473" href="#Footnote_473" class="fnanchor">[46]</a></p>
+
+<p>A defendant sued upon a debt for board and lodging
+was denied his law,<a id="FNanchor_474" href="#Footnote_474" class="fnanchor">[47]</a> but Justices Priscott and
+Needham, decided, near the end of the reign of Henry
+VI. that wager of law would lie in an action for board
+and lodging, if the plaintiff had it in his power to
+furnish the board or lodging at his own volition and
+not upon compulsion,<a id="FNanchor_475" href="#Footnote_475" class="fnanchor">[48]</a> but if the defendant had been
+imprisoned in the Tower and the board and lodging was
+furnished by force of the obligation of common humanity,
+this would so far deprive the plaintiff of his option
+of furnishing the board and lodging, as to make him a<span class="pagenum"><a id="Page_207"></a>[207]</span>
+creditor of such merit as to deprive the defendant of
+his wager of law.<a id="FNanchor_476" href="#Footnote_476" class="fnanchor">[49]</a></p>
+
+<p>Where persons were compelled to serve by the statute
+of laborers, such as plowmen, shepherds, and all
+servants of husbandry, in an action for wages, the defendant
+was not allowed his wager of law, because the
+plaintiff had no option to refuse the service, but in
+cases where the service was not compulsory, wager of
+law would lie.<a id="FNanchor_477" href="#Footnote_477" class="fnanchor">[50]</a></p>
+
+<p>And upon the theory that an attorney could be compelled
+by the judges of the common pleas court to
+render faithful service to his client and was not allowed
+to refuse such service, we find that Chief Justice
+Fortescue decided, during this reign, that in an action
+by an attorney for services rendered in such a court,
+no wager of law would lie on the part of defendant.<a id="FNanchor_478" href="#Footnote_478" class="fnanchor">[51]</a></p>
+
+<p>By the middle of the fifteenth century, in England,
+the wager of law in criminal cases had begun to fall
+into disuse, for the method followed in such trials, at
+Westminster, was such that professional oath-helpers
+were customarily used and such professional swearers
+necessarily debased the wager of law in criminal
+cases.<a id="FNanchor_479" href="#Footnote_479" class="fnanchor">[52]</a> And in the courts of the country districts it
+got to be a very easy matter for a citizen of bad repute<span class="pagenum"><a id="Page_208"></a>[208]</span>
+to produce his oath-helpers, and his neighbors were
+afraid to negative the oaths of men who were frequently
+too desperate to thus antagonize,<a id="FNanchor_480" href="#Footnote_480" class="fnanchor">[53]</a> and this
+led to a gradual preference for the trial by jury, in
+criminal cases, both on the part of the person accused
+of crime and by the general public, who came to regard
+the wager of law, in such cases, with odium.<a id="FNanchor_481" href="#Footnote_481" class="fnanchor">[54]</a></p>
+
+<p>Long before its repeal, by statute, the old defense
+had fallen into disuse, and in 1833, by 3 &amp; 4 William
+IV.,<a id="FNanchor_482" href="#Footnote_482" class="fnanchor">[55]</a> the wager of law was finally abolished in England,
+and compurgation in the ecclesiastical courts
+was abolished during the reign of Queen Elizabeth.</p>
+
+<p>While this irrational procedure obtained in England,
+the accused in the gravest criminal charges, could avoid
+punishment, regardless of the notorious character of
+his crime, without being confronted with evidence of
+his guilt, if he was able to find compurgators who
+would testify to their belief in his innocence.<a id="FNanchor_483" href="#Footnote_483" class="fnanchor">[56]</a> And
+while he could not invoke this procedure in a case of
+theft, if the stolen goods were found upon his person,
+or he had been previously convicted, in all other offenses,
+he was at liberty to thus acquit himself, by
+means of his oath-helpers,<a id="FNanchor_484" href="#Footnote_484" class="fnanchor">[57]</a> and this favorable procedure
+for the criminals continued long after its abuses
+were set forth and denounced in the Council of Bale,<a id="FNanchor_485" href="#Footnote_485" class="fnanchor">[58]</a>
+in municipal and ecclesiastical courts, although in the
+king’s court, in criminal cases of the graver sort compurgation<span class="pagenum"><a id="Page_209"></a>[209]</span>
+is said to have disappeared in consequence
+of what has been styled “the implied prohibition” of
+the Assize of Clarendon, in 1166.<a id="FNanchor_486" href="#Footnote_486" class="fnanchor">[59]</a> But the statute of
+Elizabeth (38 Elizabeth, 3, 5), shows that the wager
+was in common use in 1596, in actions of debt upon
+simple contracts.<a id="FNanchor_487" href="#Footnote_487" class="fnanchor">[60]</a></p>
+
+<p>Turning to some of the instances where the oaths of
+compurgators, or the wager of law, as known under the
+old procedure, was utilized to acquit the accused of
+charges, either in the ecclesiastical or lay courts of
+old England, we find, in the sixth century, that Pope
+Pelagius I., when confronted with charges that he
+was concerned in the troubles which drove his predecessor
+into exile, exculpated himself, by his oath,
+taken in the pulpit, while holding the crucifix above
+his head, denying any implication in the affairs that
+had resulted in the disgrace of his predecessor.<a id="FNanchor_488" href="#Footnote_488" class="fnanchor">[61]</a></p>
+
+<p>And when Gregory of Tours was arraigned for the
+use of words which seriously reflected upon Fredegonda,
+before a Council of Bishops, it was decided that
+he should acquit himself of the charge by oaths upon
+three separate altars, which in due time, the accused
+performed to the complete satisfaction of the Council.<a id="FNanchor_489" href="#Footnote_489" class="fnanchor">[62]</a></p>
+
+<p>In the dispute which arose, in 824, between Hubert,<span class="pagenum"><a id="Page_210"></a>[210]</span>
+bishop of Worcester, and the abbot of Berkeley, in
+regard to the monastery of Westbury, the issue was
+settled by the oath of bishop Hubert, supported by
+fifty priests, ten deacons and a hundred and fifty other
+clerks and ecclesiastics.<a id="FNanchor_490" href="#Footnote_490" class="fnanchor">[63]</a></p>
+
+<p>Again, the bishop of Trent, when accused of simony,
+was ordered by Pope Innocent II. to clear himself with
+the oaths of two bishops and three abbots or monks,
+a course that was followed by the accused, to the complete
+satisfaction of his superiors in the church.<a id="FNanchor_491" href="#Footnote_491" class="fnanchor">[64]</a></p>
+
+<p>Compurgation was, indeed, for many centuries the
+common procedure whereby Churchmen, when accused
+of simony, or other irregularities, cleared themselves
+of the charges filed against them, and it seemed almost
+invariably an easy task to find other brothers of the
+order willing to stand by the accused and render him
+the assistance of an oath in the belief of his innocence,
+perhaps because of the frequency of such charges and
+the uncertainty of the future and that necessity might
+place the compurgators in a position where they might
+desire the reciprocal service, rendered to their unfortunate
+companion.<a id="FNanchor_492" href="#Footnote_492" class="fnanchor">[65]</a></p>
+
+<p>In the thirteenth century the earl of Warenne, or
+his men, slew Alan de la Zouche, in Westminster Hall,
+in the presence of the king’s justices. He was allowed
+to escape with his compurgators’ aid, according to the
+rule then obtaining, by his own oath, supported by the
+oaths of twenty-five knights, that the deed was not
+done with malice aforethought, or in contempt of the
+king, but under the heat of passion and under such<span class="pagenum"><a id="Page_211"></a>[211]</span>
+circumstances as to reduce the offense to simple manslaughter.<a id="FNanchor_493" href="#Footnote_493" class="fnanchor">[66]</a></p>
+
+<p>In the Bedfordshire eyre, of the year 1202, in a
+prosecution under the statute for selling beer under a
+false measure, the defendant when placed upon her
+trial, claimed the right of compurgation and was
+ordered to defend herself “twelve handed” and she
+met the demand of the court by the offer of her compurgators.<a id="FNanchor_494" href="#Footnote_494" class="fnanchor">[67]</a></p>
+
+<p>In April, 1435, Agnes Archer was indicted for the
+alleged murder of Alice Colynbourgh, at Winchelsea,
+whom she was charged with having stabbed five times
+in the throat, with a knife. The defendant, when arraigned
+for this crime entered a plea of not guilty, by
+declaring, as the report of the case records it: “I am
+not guilty of thoo dedys, ne noon of hem, God help me
+so.” And when interrogated by the Judge as to how she
+would acquit herself of this charge, she replied: “By
+God and by my neighbors of this town,” so the charge
+being one which brought the case within the rule of
+the “Great Law,” she was required to acquit herself
+by the oaths of thirty-six compurgators.<a id="FNanchor_495" href="#Footnote_495" class="fnanchor">[68]</a></p>
+
+<p>In 1440, in a suit for board and lodging furnished
+the defendant by the plaintiff, one Counselor, Yelverton,
+for the plaintiff, contended that the defendant was
+not entitled to his wager of law, in this action, but the
+justices held that wager of law would lie in a suit for
+board and lodging.<a id="FNanchor_496" href="#Footnote_496" class="fnanchor">[69]</a></p>
+
+<p><span class="pagenum"><a id="Page_212"></a>[212]</span></p>
+
+<p>During the reign of Henry VI., in the year 1454, quite
+a memorable legal battle was waged concerning the
+right of a defendant, in a real action, to wage his law
+upon a plea of non-summons. The plaintiff demurred
+to this plea and the justices were divided upon the
+propriety of recognizing the plea. Chief Justice Priscot
+and his associates, Danvers and Danby, overruled
+the demurrer to this plea, holding that the defendant
+could urge his wager of law in a real action, while admitting
+that the practice had been otherwise. The
+minority of the court, however, dissented from this
+view, much as the minority frequently dissent in
+modern times and Moile and Ayshton earnestly pressed
+their views upon the majority of the court, for the
+reason that, “All our law is directed by usage or statute;
+it has been used that no one wages his law in
+trespass, and the contrary in debt; so that we should
+adjudge according to the use.”<a id="FNanchor_497" href="#Footnote_497" class="fnanchor">[70]</a></p>
+
+<p>In the year 1492, one Sebastian Giglis complained
+to the Chancellor against Robert Welby, that complainant
+had persuaded a third party to advance a certain
+sum of money to Welby, who promised to repay the
+loan and then when he was sued therefor, by the creditor,
+he had waged his law and the result was that
+complainant had been compelled to pay the loan, so
+advanced, at his instance, to Welby. In his answer to
+this plea, Welby admitted the loan, but set up that he
+had procured the money for King Richard III., who
+had received and used the money and that the receipt
+given was a mere memorandum of the transaction, but
+not under seal, and he attempted to wage his law to<span class="pagenum"><a id="Page_213"></a>[213]</span>
+this debt. The court refused to recognize the wager
+of law in this case, but held that in as much as the plaintiff
+had paid the debt for money had and received by
+the defendant, and since the defendant admitted the
+debt, and the receipt of the money, it was immaterial
+that he had given it to another, and adjudged that he
+should pay the plaintiff, and that no wager of law would
+lie in such a case.<a id="FNanchor_498" href="#Footnote_498" class="fnanchor">[71]</a></p>
+
+<p>In the year 1587 the Star Chamber refused to entertain
+a criminal charge of perjury against a man who
+was charged with having perjured himself in waging
+his law, in a prior proceeding. The Lord Chancellor
+rather dissented from the decision of the majority of
+the judges and asked if the effect of the wager, based
+on perjury was to discharge the debt sued for. The
+judges answered that it was, Manwood, C. B., maintaining
+that it was because of the plaintiff’s folly, in sueing
+for debt, rather than upon an assumpsit, wherein
+wager of law would not lie.<a id="FNanchor_499" href="#Footnote_499" class="fnanchor">[72]</a></p>
+
+<p>In his report of Slade’s case, in 1602, Sir Edward
+Coke remarked that the court would not allow a man
+to wage his law, until the court had admonished both
+the principal and the compurgators and upon due examination
+as to their qualifications and the merits of<span class="pagenum"><a id="Page_214"></a>[214]</span>
+the cause, in order to ascertain if the case was one
+wherein wager of law was allowable.<a id="FNanchor_500" href="#Footnote_500" class="fnanchor">[73]</a></p>
+
+<p>Several cases came before Chief Justice Holt, during
+the latter part of the seventeenth century and some of
+the cases, which have been noted, will be briefly referred
+to.</p>
+
+<p>In the Company of Glazier’s Case, which arose in
+1699, the Company sued in an action of debt and the
+defendant waged his law. Counselor Northey appeared
+for the Company and when the defendant appeared
+with his compurgators, he insisted that if he swore falsely,
+the court did not have to receive his wager of law, but
+to this contention, Chief Justice Holt replied: “We can
+admonish him, but if he will stand by his law, we cannot
+hinder it, seeing it is a method the law allows.”
+Plaintiff’s counsel then insisted that such a holding
+would be a dangerous precedent, because it would have
+the legal effect of compelling litigants sueing in debt,
+to extend the practice of sueing upon an assumpsit
+still further, but the doughty Chief Justice replied to
+this argument that “We will carry them no further,”
+so the wager of law was received, because it was a
+“method the law allows.”<a id="FNanchor_501" href="#Footnote_501" class="fnanchor">[74]</a></p>
+
+<p>The Chief Justice practically reversed his holding in
+the Company of Glazier’s Case, two years later, however,
+for in exactly the same kind of an action of debt,
+arising on a by-law, in London vs. Wood, the court
+refused to entertain the defendant’s plea of wager of
+law, remarking that the plaintiff’s counsel in the Company
+of Glazier’s Case (Northey), had yielded too<span class="pagenum"><a id="Page_215"></a>[215]</span>
+much—although he seemed to do all that an earnest
+counsel can do, to urge his plea and then except to the
+court’s action, when it is overruled—in characterizing
+that decision, the court observing that “It was a
+gudgeon swallowed and so it passed without observation,”
+meaning that a bad precedent had been recorded
+because not strenuously enough objected to.<a id="FNanchor_502" href="#Footnote_502" class="fnanchor">[75]</a></p>
+
+<p>In this case, the action was on a city by-law, for
+the penalty provided for the refusal of the defendant
+to serve as sheriff. According to the custom of London,
+the defendant offered to wage his law, with six good
+and reputable compurgators, but to this plea the plaintiff
+demurred, and in considering the issue of law, on
+the question of the right of the defendant to wage his
+law, in such an action, Baron Hatsell reviewed the older
+decisions bearing upon the defense of wager of law and
+maintained that it would lie in five certain cases only,
+“first, in debt on simple contract, which is the common
+case; secondly, in debt upon an award, upon a parole
+submission; thirdly, in an account against a receiver;
+fourthly, in detinue, and fifthly, in an amercement in a
+court baron, or other inferior court, not of record.”</p>
+
+<p>Lord Holt repudiated the reasoning which limited
+the Wager to any specific classes of actions, but maintained
+that the wager could only be made to depend
+upon other distinctions, growing out of the very nature
+of the cause of action and not the mere class to which
+it might belong.</p>
+
+<p><span class="pagenum"><a id="Page_216"></a>[216]</span></p>
+
+<p>In the course of his opinion in this celebrated case,
+he observed:</p>
+
+<div class="blockquote">
+
+<p>“This is the right difference, and not that which is
+made in the actions, viz., that it lies in one sort of action
+and not in another; but the true difference is when it
+is grounded on the defendant’s wrong; ... for
+if debt be brought, and the foundation of the action
+is the wrong of the defendant, wager of law will not
+lie.... The secrecy of the contract which raises
+the debt is the reason of the wager of law; but if the
+debt arises from a contract that is notorious, there
+shall be no wager of law.”<a id="FNanchor_503" href="#Footnote_503" class="fnanchor">[76]</a></p>
+
+</div>
+
+<p>The great Chief Justice was far too independent to be
+bound by the dictum of some previous case, which did
+not commend itself to him, according to the touchstone
+of reason or logic. He had a naturally inquiring
+mind and sought to go deep into the mysteries of things.
+Refused credence to the absurd or allegiance to an
+arrogant authority and was too broad to be bound
+by mere doctrine, but of course could only judge according
+to the standards of his time.</p>
+
+<p>This decision marks the trend of judicial thought of
+the period to further limit and deny the wager of law,
+because of the fact that it was becoming to be considered
+contrary to the prevalent sense of right of the<span class="pagenum"><a id="Page_217"></a>[217]</span>
+great mass of citizenship, to permit one who was sufficiently
+elastic in his conscience, to swear away the
+debt or obligation of another, just as formerly it had
+come to be regarded as wrong to permit the accused
+in a criminal case, to set aside the public law which he
+had violated, by means of the oaths of compurgators.</p>
+
+<p>During the age of Bracton, the defendant, who was
+incarcerated in jail and attempted to deny the obligation
+for his board and lodging, by the wager of law,
+was held incompetent to wage his law, in such a case,
+because it was counter to reason to permit one to be
+thus defeated of an obligation which he had recognized,
+based upon feelings of common humanity.</p>
+
+<p>In this opinion of Lord Hort, it was counter to his
+idea of right, in the case of London vs. Wood,<a id="FNanchor_504" href="#Footnote_504" class="fnanchor">[77]</a> to permit
+the wager of law, to avoid an obligation which was
+not merely secret, but notorious and where the recognition
+of the right to wage law, would result in a
+wrong upon the other party. The real reason for this
+limitation of the right, however, was that the procedure
+itself was wrong and the common sense of the nation
+was becoming aware of the fact and thus the courts
+for one reason or another, reached the conclusion that
+this or that case was not one wherein the right could
+be recognized, when, as a matter of fact, with the growing
+popularity of the right of trial by jury, this old
+procedure was eternally at war, since the former institution
+was based upon the disinterested judgment of
+impartial men, who were assembled to carefully weigh
+the issues and pass judgment according to the right,
+whereas, in the other procedure interested men, through<span class="pagenum"><a id="Page_218"></a>[218]</span>
+the influence of friendship or other ties, were led to
+approve the course of a neighbor or a friend, however
+wrong his object might be, and assist him by the corroboration
+of his oath.</p>
+
+<p>A century after this leading case of London vs.
+Wood,<a id="FNanchor_505" href="#Footnote_505" class="fnanchor">[78]</a> however, in which Lord Holt and Baron Hatsell
+differed as to the reasons why the right to wage his
+law should be denied to the defendant in that case, the
+right was recognized in England, although not expressly
+enforced by the court. In 1805, the case of Barry vs.
+Robinson,<a id="FNanchor_506" href="#Footnote_506" class="fnanchor">[79]</a> came before the English Court of Common
+Pleas and the Counsel for the plaintiff in his presentation
+of his client’s cause before the court, said: “If a
+man were now to tender his wager of law, the court
+would refuse to allow it,” as the counsel considered
+that this procedure was entirely obsolete at that period.
+But the reporter of this case, however, advises us
+that to this statement of counsel, the court demurred,
+or, in the language of the Reporter, “This was denied
+by the court.”</p>
+
+<p>The last recorded case wherein this old defense was
+attempted in England was in the year 1824, in the case
+of King vs. Williams,<a id="FNanchor_507" href="#Footnote_507" class="fnanchor">[80]</a> but as Professor Thayer observes,
+in his “Older Modes of Trials,”<a id="FNanchor_508" href="#Footnote_508" class="fnanchor">[81]</a> the wager
+of law at this time was “a discredited stranger, ill
+considered.” This was an action of debt, upon a simple
+contract, a case wherein the wager of law clearly applied,
+under the old practice. The defendant pleaded<span class="pagenum"><a id="Page_219"></a>[219]</span>
+“<i>nil debet per legem</i>.” Counselor Langslow appeared
+for the defendant and after filing this plea, asked the
+court to assign the number of compurgators, for the
+reason that “The books leave it doubtful and this
+species of defense is not often heard of now.” This
+requested rule, to assign the number of compurgators
+to the defendant was refused by Abbot, C. J., who observed:
+“The court will not give the defendant any
+assistance in this matter. He must bring such number
+of compurgators as he shall be advised are sufficient.”
+This, upon the theory that everyone is presumed to
+know the law and that the court would not assist a
+litigant in the perpetration of a wrongful act, although
+it might be presented in the robe of regularity, was
+good enough. But according to the ancient report of
+this case, even as Banquo’s ghost dispelled the banqueters,
+when it was apparent to Macbeth’s fervid imagination,
+so this recourse to the old obsolete wager of
+law, which allowed an adversary with his friends to
+swear his opponent out of court, caused the plaintiff
+in this case to abandon his cause, for we are advised
+that: “The defendant prepared to bring eleven compurgators,
+but the plaintiff abandoned the action.”<a id="FNanchor_509" href="#Footnote_509" class="fnanchor">[82]</a></p>
+
+<p>Wager of law was several times invoked in the courts
+of the United States and we find that the Supreme
+Court considered the nature and limitations of the
+practice, as late as the year 1823, in the case of Childress,
+plaintiff in error, vs. Emory and McCleur,<a id="FNanchor_510" href="#Footnote_510" class="fnanchor">[83]</a>
+wherein Mr. Webster, attorney for the plaintiff in error,
+in a suit on a note, urged before the court that</p>
+
+<p><span class="pagenum"><a id="Page_220"></a>[220]</span></p>
+
+<div class="blockquote">
+
+<p>“The wager of law has ceased, but many rules of
+practice and pleading, founded upon it, have survived,
+and have become rules of property, which cannot be
+now safely disturbed.... On the English law, it
+is clear that debt cannot be maintained in this case,
+as the testator might have <i>waged his law</i>, which none
+can do who defend in a representative character; hence
+it is that in the case of simple contracts, debt has been
+superceded by the action of assumpsit, in which, as the
+testator could not have <i>waged his law</i>, his executor is
+not deprived of any defense which might have been
+used by the testator.”</p>
+
+</div>
+
+<p>To this argument, Mr. Hoffman, for the defendant
+in error, argued, <i>contra</i>, that:</p>
+
+<div class="blockquote">
+
+<p>“In an action of debt by a merchant stranger, on any
+species of simple contract, the defendant was not permitted
+to <i>wage his law</i>. Even in those early times, the
+courts were strongly disposed to rescue commercial
+transactions and dealings from this species of trial,
+as may be seen by the intended operation of the
+statute <i>de mercatoribus</i>, and particularly in the case
+of foreign creditors, who, it was presumed, could not
+so easily obtain the requisite evidence, of their claims
+as resident merchants; and this may be seen in Godfrey
+and Dixon’s case.”<a id="FNanchor_511" href="#Footnote_511" class="fnanchor">[84]</a></p>
+
+</div>
+
+<p>And Mr. Justice Story, in disposing of the case, <i>inter
+alia</i> decided:</p>
+
+<div class="blockquote">
+
+<p>“Now, whatever may be said upon the question,
+whether the wager of law was ever introduced into
+the common law of our country by the emigration of
+our ancestors, it is perfectly clear that it cannot, since
+the establishment of the state of Tennessee, have had
+a legal existence in its jurisprudence. The constitution
+of that state has expressly declared, that the trial by
+jury shall remain inviolate; and the constitution of the
+United States has also declared that in suits at common<span class="pagenum"><a id="Page_221"></a>[221]</span>
+law, where the value in controversy shall exceed twenty
+dollars, the right of trial by jury shall be preserved.
+Any attempt to set up the wager of law would be
+utterly inconsistent with this acknowledged right. So
+that the wager of law, if it ever had any legal existence
+in the United States, is now completely abolished. If,
+then, we apply the rule of the common law, to the present
+case, we shall arrive, necessarily, at the conclusion,
+that the action of debt does lie against the executor,
+because the testator could never have waged his law
+in this case.”<a id="FNanchor_512" href="#Footnote_512" class="fnanchor">[85]</a></p>
+
+</div>
+
+<p>And so Mr. Webster’s defense of the <i>wager of law</i>,
+to this action on this note, was held not to obtain, and
+he lost his case and his client was adjudged to pay the
+note of his testator.</p>
+
+<p>If true that but “a hair divides the false and true,”
+it is little wonder that for centuries, in the struggle for
+right, immersed amid the darkness of the dawn of judicial
+procedure, an occasional false note should come
+down to us, through the centuries, from the pathetic
+drama wherein the individual was made to assert his
+right, upon the mere <i>wager of law</i>, instead of more<span class="pagenum"><a id="Page_222"></a>[222]</span>
+accurate human standards to balance the scales of
+justice. Judged by our own environment, it seems that
+the quarrels of the Universe of old were gauged far
+too long by the erroneous standards used in the vain
+pursuit of This and That, about which the citizens of
+the past centuries endeavoured and disputed. And that
+with the institution of trial by jury, brought into existence
+in the middle ages, the <i>wager of law</i> would have
+much sooner become an obsolete form of procedure.</p>
+
+<p>But in the continuance of the drama of human life,
+this prided institution of our twentieth century, may
+seem as crude and barbaric to the spectators viewing
+the show from the vantage of subsequent centuries,
+as this grotesque comedy of errors, known as the <i>wager
+of law</i> now appears to us, when we look back upon the
+judicial farce enacted by our ancestors, in the uncertain
+procedure of Law Wager. They seemed to wander
+“in and out, above, about, below,” yet ever missing
+the door which led to the correct ideal. They labored
+under new and strange conditions, however, and perplexed
+as they were with the many problems of the
+Human and Divine and intermingling the processes
+and procedures of the lay and ecclesiastical courts,
+as they did, it is perhaps to their credit that the old
+tangles of the law were solved as creditably as they
+were.</p>
+
+<p>However this may be, in the <i>Wager of Law</i> we have
+but another “story from of old,” in connection with
+the perpetual struggle for right, which has followed
+man’s course down through the successive generations
+of the past.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_428" href="#FNanchor_428" class="label">[1]</a> Bouvier’s Law Dictionary.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_429" href="#FNanchor_429" class="label">[2]</a> 3 Bl. Comm. 341; Coke, Litt. 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_430" href="#FNanchor_430" class="label">[3]</a> Exodus, XXII., 10.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_431" href="#FNanchor_431" class="label">[4]</a> John’s “Babylonian Laws,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_432" href="#FNanchor_432" class="label">[5]</a> 3 Bl. Comm. 341; Spellman, L. b. 28, c. 13; Stiernh., <i>de jure Sueon</i>,
+1. l. c. 9.</p>
+
+<p>The clergy were no doubt responsible for the establishment of
+the practice in England, as it resembles the canonical purgation of
+the clergy, as well as the <i>sacramentum decisionis</i>, of the civil law.
+(3 Bl. Comm. 342.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_433" href="#FNanchor_433" class="label">[6]</a> 3 Bl. Comm. 343; Cap. &amp; Wilk. LL Anglo-Saxons.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_434" href="#FNanchor_434" class="label">[7]</a> Coke, Litt. 295; 3 Bl. Comm. 343.</p>
+
+<p>As the effect of the compurgators oath was the same as a verdict,
+this is the reason assigned by Coke and Blackstone, why eleven
+compurgators were required, under the old codes. 3 Bl. Comm.
+343; Coke, Litt. 295; Glanville, Lib. l, c, 9x.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_435" href="#FNanchor_435" class="label">[8]</a> I. Pollock and Maitland’s History English Law, p. 140.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_436" href="#FNanchor_436" class="label">[9]</a> II. Pollock and Maitland’s History English Law, 600.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_437" href="#FNanchor_437" class="label">[10]</a> Lea, “Superstition and Force,” (3 ed.) 35.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_438" href="#FNanchor_438" class="label">[11]</a> II. Pollock and Maitland’s History English Law, 600.</p>
+
+<p>It was also a custom for a long time, for the defendant to select
+his compurgators from the nominees of the injured person, and
+a case is recorded, as late as 1277, in Leicester, where this was
+required, but it was soon abolished as too onerous a task for an
+accused person. II. Pollock and Maitland’s History English Law,
+p. 636, note.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_439" href="#FNanchor_439" class="label">[12]</a> Laws Wihtraed, cap. 16, 21; Lea, “Superstition and Force,”
+(3 ed.) 23.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_440" href="#FNanchor_440" class="label">[13]</a> III. Reeve’s History English Law, 294.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_441" href="#FNanchor_441" class="label">[14]</a> Glanville, Book I., chap. IX.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_442" href="#FNanchor_442" class="label">[15]</a> Coke, Litt. 168b.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_443" href="#FNanchor_443" class="label">[16]</a> Coke, Litt. 295a; 2 Inst., 44.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_444" href="#FNanchor_444" class="label">[17]</a> <i>Les Termes de la Ley, ad voc. ley.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_445" href="#FNanchor_445" class="label">[18]</a> Bracton, 410a.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_446" href="#FNanchor_446" class="label">[19]</a> Bracton, 366a; 410a.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_447" href="#FNanchor_447" class="label">[20]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_448" href="#FNanchor_448" class="label">[21]</a> Bracton, fol. 366; Note Book, pl. 7, 1436.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_449" href="#FNanchor_449" class="label">[22]</a> Note Book, pl. 731, 742.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_450" href="#FNanchor_450" class="label">[23]</a> Note Book, pl. 396, 1097.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_451" href="#FNanchor_451" class="label">[24]</a> Bracton, fol. 156; Note Book, pl. 477, 741.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_452" href="#FNanchor_452" class="label">[25]</a> Somersetshire Pleas, pl. 572.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_453" href="#FNanchor_453" class="label">[26]</a> Bracton, fol. 315b; Note Book, pl. 580.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_454" href="#FNanchor_454" class="label">[27]</a> Note Book, pl. 184, 1574.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_455" href="#FNanchor_455" class="label">[28]</a> 38 Edward III. st. l, c. v.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_456" href="#FNanchor_456" class="label">[29]</a> III. Reeve’s History English Law, 184.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_457" href="#FNanchor_457" class="label">[30]</a> 38 Edward III. st. l, c. 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_458" href="#FNanchor_458" class="label">[31]</a> III. Reeve’s History English Law, 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_459" href="#FNanchor_459" class="label">[32]</a> 28 Edward III. 100a; 29 Edward III., 44b; III. Reeve’s History
+English Law, 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_460" href="#FNanchor_460" class="label">[33]</a> 47 Edward III., 18; III. Reeve’s History English Law, 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_461" href="#FNanchor_461" class="label">[34]</a> 38 Edward III., 7a.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_462" href="#FNanchor_462" class="label">[35]</a> Coke, Litt. 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_463" href="#FNanchor_463" class="label">[36]</a> 3 Bl. Comm. 346.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_464" href="#FNanchor_464" class="label">[37]</a> Coke, Litt. 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_465" href="#FNanchor_465" class="label">[38]</a> 3 Bl. Comm. 346.</p>
+
+<p>Wager of law was never required, in England, but was allowed,
+as a privilege to the defendant. Coke, Litt. 295.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_466" href="#FNanchor_466" class="label">[39]</a> Mun. Gild. I., 56, 59, 90, 92; II. Pollock and Maitland’s History
+English Law, p. 635.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_467" href="#FNanchor_467" class="label">[40]</a> Mun. Gild. I., 57; II. Pollock and Maitland’s History English
+Law, <i>supra</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_468" href="#FNanchor_468" class="label">[41]</a> Mun. Gild, ii, 321; II. Pollock and Maitland’s History English
+Law, p. 636.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_469" href="#FNanchor_469" class="label">[42]</a> Palgrave, English Commonwealth, pp. 117. Lyons Dover, ii,
+300, 315.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_470" href="#FNanchor_470" class="label">[43]</a> III. Reeve’s History English Law, 567.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_471" href="#FNanchor_471" class="label">[44]</a> This was by virtue of a statute of the reign of Henry IV. III.
+Reeve’s History English Law, c. xviii.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_472" href="#FNanchor_472" class="label">[45]</a> III. Reeve’s History English Law, p. 568.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_473" href="#FNanchor_473" class="label">[46]</a> 14 Henry VI., 24.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_474" href="#FNanchor_474" class="label">[47]</a> 39 Henry VI., 18.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_475" href="#FNanchor_475" class="label">[48]</a> 28 Henry VI., 4.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_476" href="#FNanchor_476" class="label">[49]</a> <i>Ante idem.</i> III. Reeve’s History English Law, p. 569.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_477" href="#FNanchor_477" class="label">[50]</a> 38 Henry VI., 14, 22.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_478" href="#FNanchor_478" class="label">[51]</a> III. Reeve’s History English Law, 570.</p>
+
+<p>Referring to the fact that wager of law was allowed in actions
+of debt and detinue and the attempt to demonstrate that this was
+because jury trials were inconsistent with the rights of the parties
+in these actions, Pollock and Maitland, in their History of English
+Law, show that the truth is that these actions are older than jury
+trials. (Vol. II., p. 634.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_479" href="#FNanchor_479" class="label">[52]</a> II. Pollock and Maitland’s History English Law, p. 636.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_480" href="#FNanchor_480" class="label">[53]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_481" href="#FNanchor_481" class="label">[54]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_482" href="#FNanchor_482" class="label">[55]</a> 3 and 4 William IV., c. 42, sec. 13.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_483" href="#FNanchor_483" class="label">[56]</a> Jur. Prov. Saxon. Lib. I., Art. 15, 18, 39.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_484" href="#FNanchor_484" class="label">[57]</a> Lea, “Superstition and Force,” (3 ed.) 22, note.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_485" href="#FNanchor_485" class="label">[58]</a> This protest against this procedure was in the Fifteenth century.
+Schilter. Thesaur, II., 291.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_486" href="#FNanchor_486" class="label">[59]</a> Pike, History Crime, i, 130; Thayer, “Older Modes of Trial,”
+II. Essays in Anglo-American Legal History, p. 384.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_487" href="#FNanchor_487" class="label">[60]</a> Jacob’s Review of the Statutes (2 ed.), 532.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_488" href="#FNanchor_488" class="label">[61]</a> Anastas Biblioth. No. LXII.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_489" href="#FNanchor_489" class="label">[62]</a> Gregor. Turon. Hist. Lib. V., cap. XLIX. The custom of acquitting
+oneself by swearing on different altars, was an old Anglo-Saxon
+practice, the plaintiff being allowed to substantiate his claim
+by oaths upon four altars, while the defendant could rebut the
+charge by oaths upon twelve altars. Dooms of Alfred, Cap. 33;
+Fleta, Lib. II., cap. lxiii, sec., 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_490" href="#FNanchor_490" class="label">[63]</a> Spelman, Concil. I., 335.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_491" href="#FNanchor_491" class="label">[64]</a> Lea, “Superstition and Force,” (3 ed.) 57.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_492" href="#FNanchor_492" class="label">[65]</a> <i>Ante idem.</i>, p. 61.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_493" href="#FNanchor_493" class="label">[66]</a> Ann. Wint. 109; Wykes, 234; II. Pollock and Maitland’s History
+English Law, 636.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_494" href="#FNanchor_494" class="label">[67]</a> Maitland’s Pl. Cr. i, case, 61; Palgrave’s Com. ii, cxix, note.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_495" href="#FNanchor_495" class="label">[68]</a> Lyon’s History Dover, ii, 265; II. Essays in Anglo-American
+Legal History, 385.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_496" href="#FNanchor_496" class="label">[69]</a> Year Book, 19 Henry VI., 10, 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_497" href="#FNanchor_497" class="label">[70]</a> Year Book, 33 Henry VI., 7, 23.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_498" href="#FNanchor_498" class="label">[71]</a> Cal. Proc. in Chan, i, ccxx-ccxxii. In Spence’s Equity Jurisprudence,
+this case is cited as one of the notable cases which
+finally helped to bring about the repeal of the law wager.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_499" href="#FNanchor_499" class="label">[72]</a> Goldsborough, 51, pl. 13; Doctor and Student, ii, c. 24; Thayer’s
+“Older Modes of Trial,” II. Anglo-American Legal History, p. 388.</p>
+
+<p>In the persecution of the reformers, in 1527, under Henry VIII.,
+Margaret Cowbridge and Margery Bowgas were allowed to acquit
+themselves by the oaths of compurgators, although there were several
+witnesses against them, and the compurgators comprised several
+women in the test.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_500" href="#FNanchor_500" class="label">[73]</a> Slade’s Case, 4 Rep. p. 95.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_501" href="#FNanchor_501" class="label">[74]</a> Company of Glaziers’ Case, 2 Salk. 682.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_502" href="#FNanchor_502" class="label">[75]</a> 12 Mod. 669, 684.</p>
+
+<p>In Gunner’s case, in 1708, the plaintiff took a non-suit when the
+defendant was ready to wage his law. Jacob’s Review of the Statutes,
+(2 ed.) 532.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_503" href="#FNanchor_503" class="label">[76]</a> London vs. Wood, 12 Mod. 669, 679. This opinion of Lord Holt,
+that wager of law would not lie, unless the debt was a secret debt,
+is based upon the law, as stated by Sir Edward Coke, for he says:
+“The reason wherefore, in an action of debt upon a simple contract,
+the defendant may wage his law, is for that the defendant may
+satisfy the party in secret, or before witnesses and all the witnesses
+may die.” (II. Inst, 45.) But of course this same plea of payment
+would be good, whether the debt arose on contract or in parole, and
+the same reason would obtain for perpetuating the testimony, and
+this illustrates how an erroneous custom will live upon irrational
+doctrines.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_504" href="#FNanchor_504" class="label">[77]</a> 12 Mod. 669.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_505" href="#FNanchor_505" class="label">[78]</a> 12 Mod. 669.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_506" href="#FNanchor_506" class="label">[79]</a> I. B. &amp; P. (N. P.) 297.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_507" href="#FNanchor_507" class="label">[80]</a> 2 Barnew &amp; C. 538; 4 D. &amp; R. 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_508" href="#FNanchor_508" class="label">[81]</a> V. Harvard Law Review; II. Essays in Anglo-American Legal
+History, 391.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_509" href="#FNanchor_509" class="label">[82]</a> King vs. Williams, 2 Barnew. &amp; C. 538; 4 D. &amp; R. 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_510" href="#FNanchor_510" class="label">[83]</a> 8 Wheaton, 642; 21 L. Ed. 705.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_511" href="#FNanchor_511" class="label">[84]</a> Palmer’s Rep. 14; Fleta, 136.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_512" href="#FNanchor_512" class="label">[85]</a> 8 Wheaton, 675; 21 L. Ed. 713.</p>
+
+<p>Compurgation was allowed in a charge of usury, by statute in
+Massachusetts, in 1783. (St. Mass. 1783, c. 55.) But in Little vs.
+Rogers, (1 Met. 108) Shaw, C. J., observes that the trial by jury has
+been “substituted for the old trial by oath.”</p>
+
+<p>Mr. Lea, in his excellent work, “Superstition and Force” (3 ed.)
+mentions the fact that in South Carolina, an act of the Legislature
+of 1712 mentions specific English laws as still in force and enumerates
+the law of compurgation, or wager of law, and that in Maryland,
+as late as 1811, Chancellor Kilty mentions the fact that wager
+of law has gone into disuse, because contrary to our spirit of law,
+but does not contend that it had then been specifically abolished,
+in Maryland. (Cooper’s Stat. at L. of So. Car. Columbia, 1837, II.,
+403; Kilty’s Report on English Statutes, Annapolis, 1811, p. 140;
+Lea, “Superstition and Force,” p. 81.)</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_223"></a>[223]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_VIII">CHAPTER VIII.<br>
+<span class="smcap">Benefit of Clergy.</span></h2>
+
+</div>
+
+<p>Engrossed as the profession is today with the agitation
+for the betterment of our remedial procedure, it
+will sometimes prove profitable to turn aside from the
+progress of our twentieth century procedure and entering
+the musty lumber-room of the law, brush aside the
+cob-webs and take a cursory view of some of the pleas
+that occupied the time of courts and lawyers of past
+centuries. Nothing is calculated to encourage more
+respect for the modern procedure of American and
+English courts, than reading the history of some of
+the unequal and unjust privileges and exemptions which
+obtained in the administration of the English law, until
+a comparatively recent date. The contrast is indeed
+striking, when we turn from the just ideals of equality
+and justice that characterize the remedial procedure
+of our day, to contemplate some of the customs and
+pleas that were followed and enforced by our own
+courts, before the evolution of our civilization had made
+the present ideals possible.</p>
+
+<p>There is no doubt but that the English common law
+is the outgrowth of the most enlightened system of
+jurisprudence that the world has ever seen, for it
+represents the best thought of the brightest minds of
+civilization’s most progressive people. Its rules and
+doctrines were formed, however, during the middle
+ages, and although it was generally consistent with
+the scholastic methods of thought that dominated the<span class="pagenum"><a id="Page_224"></a>[224]</span>
+thinking world of that period and for the most part,
+it was in thorough accord with proper and just ideals,
+yet, at the same time, the general doctrines and principles
+were applied along with many of the unequal proceedings
+and special pleas and privileges existing in
+favor of the higher classes and together with the extremely
+technical standards, that frequently were
+nothing but mere fantastic quibbles.</p>
+
+<p>The benefit of clergy is an illustration of the engraftment
+upon this enlightened system of jurisprudence,
+of one of the old special privileges of a favored class,
+who, as an incident and high prerogative of their office,
+claimed exemption from punishment for crimes. Of
+course such an exemption of a favored class was inconsistent
+with the object of distributive justice, to visit
+equal punishment upon all alike who are similarly situated
+and with the elevation of the standards of justice
+and equality, the plea was finally abolished by the
+legislative and judicial branches of Government in
+England and the United States.</p>
+
+<p>The benefit of clergy, or <i>privilegium clericale</i>, was
+the exemption of the clergy from all responsibility to
+the temporal courts and laws from the punishment
+imposed for various criminal offenses. Originally the
+persons of clergymen alone were held to be exempt
+from criminal process before a secular judge, but the
+privilege was later extended by the law to all who
+could read, as all such were held to be <i>clerica</i>, or clerks.</p>
+
+<p>For many centuries this plea was an important part
+of the criminal procedure of the continental countries
+of Europe and still furnishes a curious and instructive
+part of the history of the laws of England.</p>
+
+<p><span class="pagenum"><a id="Page_225"></a>[225]</span></p>
+
+<p>The privilege had its origin in a claim made by the
+ecclesiastics, at a very early period, for the entire exemption
+of their order from the jurisdiction of the
+common law courts of England. The growth and development
+of the privilege is an interesting chapter
+in the history of the controversy between the secular
+and spiritual power, during the middle ages and the
+limitation or expansion of the authority of the State
+or the Church, over matters temporal, depended largely
+upon the public sentiment that shaped the policies of
+the government and the weakness or strength of the
+individuals holding the reigns of government.</p>
+
+<p>Benefit of clergy was the immediate outgrowth of
+conditions contributing to the growth of the English
+common law. Before the Norman conquest and afterwards,
+for many centuries, the clergy took a very active
+part in the legislation and judicial branches of
+government and they shaped the policies of the government,
+in many important respects. The educated class
+belonged to this profession and we owe it largely to
+them that the Anglo-Saxon law has left us any evidences
+at all. During the Saxon period of superstition
+and ignorance, the ecclesiastical power had the ascendency,
+but it gradually declined, as intellect and education
+became the common property of the masses.
+Bishops were then the principal members of the courts
+of law and they instructed the judges in both the spiritual
+and secular laws and the respective limits upon
+each.<a id="FNanchor_513" href="#Footnote_513" class="fnanchor">[1]</a> The question of ecclesiastical or lay jurisdiction
+gave rise to the most intense jealousies and contests
+between sovereigns and archbishops and lawyers,<span class="pagenum"><a id="Page_226"></a>[226]</span>
+but the superior learning of the clergy resulted in a
+gradual encroachment by the Church upon the powers
+of the State.<a id="FNanchor_514" href="#Footnote_514" class="fnanchor">[2]</a> During the reign of Henry II., the jurisdiction
+of the king’s court over criminal clerks was the
+subject of a memorable quarrel, between king Henry
+and Thomas a’ Becket.<a id="FNanchor_515" href="#Footnote_515" class="fnanchor">[3]</a> Boniface, Archbishop of
+Canterbury, as the successor of Becket, waged a continuous
+fight, during the reign of Henry III., to establish
+and enlarge the power of the Church, over matters
+secular, when clerks or churchmen were brought before
+the secular courts. He ordained, under the authority
+of a convocation, in 1261, that archbishops,
+bishops and other inferior churchmen should ignore
+the letters of the king, calling them for trial before
+secular courts,<a id="FNanchor_516" href="#Footnote_516" class="fnanchor">[4]</a> and before this, in 1253, with other
+bishops, he pronounced a sentence of excommunication
+against all those who had violated similar provisions
+of the canonical laws, while enforcing secular
+power.<a id="FNanchor_517" href="#Footnote_517" class="fnanchor">[5]</a></p>
+
+<p>In this civilized age, it seems strange that the Church
+would so dominate the State, since the State must have
+consented to such a power, or it could not have existed;
+but the Church, in this superstitious period of mankind,
+held the terror of excommunication over the
+heads of the temporal authorities and the State was
+thus coerced into the gradual consent to the domination
+of the spiritual authorities. The Church always claimed<span class="pagenum"><a id="Page_227"></a>[227]</span>
+exclusive jurisdiction over all spiritual offenses, and
+as it held the unfettered power of excommunication,
+even though its degrees were opposed to secular laws,
+those around whom the Church threw its protecting
+arms were really held to be above and beyond the power
+of the secular courts.</p>
+
+<p>The power of the Church was based upon a theory of
+Divine Right and it was claimed to be far nobler than
+that of the State, because, whereas, the power of the
+Pope extended to the soul, itself, the power of Princes
+was limited to the body alone. The power of the Church,
+being thus <i>jure divino</i>, ought to have been limited, at
+all times, to matters spiritual, but by a gradual encroachment
+and by compact with the powers of the
+State, the Church also assumed to exercise authority
+over bodies by the aid of the State. But notwithstanding
+the firmness with which the clergy claimed the
+exemption from all secular interference for the persons
+of clerks, and the general indulgence that the laity gave
+to this claim, confirmed, as it was by solemn declarations
+and acts of Parliament, the privilege was always
+viewed with more or less jealousy and considered as
+a usurpation that was generously tolerated rather than
+as a part and parcel of the established common law of
+England.<a id="FNanchor_518" href="#Footnote_518" class="fnanchor">[6]</a></p>
+
+<p>Under the terms of the canonical decree, “No power
+was given to laymen to judge God’s anointed,”<a id="FNanchor_519" href="#Footnote_519" class="fnanchor">[7]</a> because
+laymen, instead of possessing power to command, were
+under the Divine injunction to obey the Church and
+Churchmen. The clergy was not without a notable<span class="pagenum"><a id="Page_228"></a>[228]</span>
+precedent for this position, for it was recorded that
+king Alfred had a judge hanged who had executed a
+clerk, because as a secular judge, he must have known
+that he had no power over clerks.<a id="FNanchor_520" href="#Footnote_520" class="fnanchor">[8]</a></p>
+
+<p>Churchmen also found many Bible references as authority
+for the privilege. In King David’s psalm of
+praise, he cautioned his subjects:</p>
+
+<div class="blockquote">
+
+<p>“Be ye mindful always of his covenant, and the word
+which he commanded to a thousand generations;</p>
+
+<p>Even of the covenant which he made with Abraham
+and of his oath unto Isaac;</p>
+
+<p>And hath confirmed the same to Jacob for a law, and
+to Israel for an everlasting covenant:</p>
+
+<p>He suffered no man to do them wrong; yea, he reproved
+kings for their sakes,</p>
+
+<p>Saying, <i>Touch not mine anointed, and do my prophets
+no harm</i>.”<a id="FNanchor_521" href="#Footnote_521" class="fnanchor">[9]</a></p>
+
+</div>
+
+<p>One guilty of the crime of high treason was not
+entitled to clergy and the exemption was not granted
+to those convicted of ordinary misdemeanors.<a id="FNanchor_522" href="#Footnote_522" class="fnanchor">[10]</a> A clergyman
+was exempted from capital punishment <i>toties
+quoties</i>, as often as he repeated the same offense; for
+a second, although it might be a wholly different offense,
+he was hanged. But of the laity, peers and
+peeresses were discharged for the first offense, without
+reading, while commoners, of the male sex, who could
+read, were branded in the hand and women commoners
+were held not entitled to clergy.<a id="FNanchor_523" href="#Footnote_523" class="fnanchor">[11]</a> Nuns, however, were
+held entitled to their clergy, at an early day, the same<span class="pagenum"><a id="Page_229"></a>[229]</span>
+as the monks and other churchmen, but the privilege,
+in contemplation of the law, enured for the benefit of
+the church and not for the nun.<a id="FNanchor_524" href="#Footnote_524" class="fnanchor">[12]</a></p>
+
+<p>As the privilege was enforced in more recent times,
+after conviction and any time before the execution
+of the sentence, when the clerk claimed his clergy, a
+priest or ordinary would present him with a “psalter,”
+and if he could read his “neck-verse,” he was burned
+in the hand and discharged. The first verse of the 51’
+Psalm was the verse most generally read to test the
+learning of the prisoner and this verse was therefore
+called a “neck-verse,” because it decided the fate of
+the person claiming clergy, and the neck of the unfortunate
+called upon to read this verse depended upon
+his ability to read it.<a id="FNanchor_525" href="#Footnote_525" class="fnanchor">[13]</a> The rule of law governing the
+ordained clerk was that he could not be tried in the lay
+courts at all, but only in an ecclesiastical court and
+his punishment was governed entirely by that court.
+In Bracton’s time, even before conviction in the secular
+court, the clerk was delivered when demanded by the
+bishop’s court.<a id="FNanchor_526" href="#Footnote_526" class="fnanchor">[14]</a> But before the end of the reign of
+Henry III. the accused was not delivered until after
+his conviction.<a id="FNanchor_527" href="#Footnote_527" class="fnanchor">[15]</a></p>
+
+<p>In the time of Edward III., the recognition and enjoyment
+of the benefit of clergy, depended entirely upon
+the ordinary demanding the felon as a clerk from the<span class="pagenum"><a id="Page_230"></a>[230]</span>
+secular authorities.<a id="FNanchor_528" href="#Footnote_528" class="fnanchor">[16]</a> In the reign of Edward IV.,
+if the ordinary refused a man his clergy, where he
+was able to read, the cause was certified to the King’s
+Bench, and the ordinary was fined, on the theory that
+he was only a minister of the secular court and not a
+judge in the cause.<a id="FNanchor_529" href="#Footnote_529" class="fnanchor">[17]</a> And during the same reign, if the
+ordinary granted clergy to a felon who could not read,
+the ordinary was fined and the convict hanged and the
+secular courts assumed the right to judge of the ability
+of the prisoner to read, for they made the record, “<i>quod
+legit ut clericus, ideo tradator ordinario</i>” and if the
+ordinary granted clergy to one who could not read,
+or refused it to one qualified, he was fined.</p>
+
+<p>But the qualification as to reading was not strictly
+applied at this period, for if the prisoner could spell
+and thus put syllables together, he was held, by Fortescue,
+to be entitled to his clergy. Littleton said that
+if the clerk refused generally to read, he was denied
+his clergy; but if a cause were stated which could not
+be allowed by the law of the land, as where he had not
+the <i>tonsura clericalis</i> or <i>ornamentum clericale</i>, if clergy
+were refused, the ordinary was fined and enjoined to
+receive the felon.<a id="FNanchor_530" href="#Footnote_530" class="fnanchor">[18]</a></p>
+
+<p>During the reign of Edward IV. the prisoner claimed
+his clergy, upon his arraignment, but this was deemed<span class="pagenum"><a id="Page_231"></a>[231]</span>
+prejudicial to the prisoner, for he thus had no challenges
+and was denied the right to a trial on the merits
+and even if innocent of the crime, if he could not read,
+was hanged, and his estate was forfeited. Sir John
+Priscott, Chief Justice of the Common Pleas Court,
+during the reign of Henry VI. changed the practice
+and when the felon claimed his clergy, on arraignment,
+he was required to plead to the merits and then, if
+convicted, the crown took his estate by forfeiture and
+he was then allowed his clergy. This practice served
+the double purpose of giving the prisoner the benefit
+of a trial on the merits and giving the crown a chance
+at his estate, which the other practice denied to the
+crown and hence, it was afterwards generally followed.<a id="FNanchor_531" href="#Footnote_531" class="fnanchor">[19]</a></p>
+
+<p>It was customary to keep a register of clerks-convict
+and persons attainted, so that such persons might not
+have their privilege more than once.<a id="FNanchor_532" href="#Footnote_532" class="fnanchor">[20]</a></p>
+
+<p>The burning in the hand, which was a necessary part
+of the procedure of the privilege of clergy, was not ordained
+by the statute (IV. Henry VII.) as a punishment,
+but merely to enable the court, on a subsequent
+arraignment of the offender, to ascertain if the defendant
+had been accorded his clergy. By statute, during
+the reign of Elizabeth (18 Elizabeth), it was enacted
+that the prisoner should not be delivered until he had
+been burned in the hand, and in Biggen’s case, near the
+end of the reign of Queen Elizabeth, it was decided,
+notwithstanding the statute referred to, that the Queen
+could pardon the burning in the hand, but unless she
+had done so, the prisoner could not be discharged until<span class="pagenum"><a id="Page_232"></a>[232]</span>
+he had been burned in the hand, and must remain perpetually
+in prison.<a id="FNanchor_533" href="#Footnote_533" class="fnanchor">[21]</a></p>
+
+<p>The case of one Stone, originating during the fourth
+year of the reign of Queen Elizabeth, is interesting as
+showing the effect of clergy upon crimes committed
+preceding the granting of clergy to the criminal. Stone
+had committed two felonies in one day, one of which
+was clergyable and the other not. He was first indicted
+upon the crime which was clergyable and being found
+guilty, was admitted to clergy and the judgment was
+recorded. Having been adjudged guilty at a subsequent
+session upon the non-clergyable felony, the conviction
+on the clergyable offense was set up in bar and was
+held to be good, by a divided court, seven of the thirteen
+deciding that since he had been once placed in jeopardy,
+it should not be presumed that the felony for which
+clergy was not admissible was committed before the
+other and <i>in favorem vitae</i>, the most merciful side
+should be taken and though the felony upon which he
+was convicted last was committed after the other one,
+yet since the felon had suffered judgment upon the
+former conviction, as a clerk convict, he should not be
+arraigned upon the second indictment, because the
+effect of the discharge on the conviction was to acquit
+him of all felonies committed before the conviction,
+as he should have been arraigned for all his offenses
+before his clergy was allowed and the court would be
+presumed to have had them in mind, as this was the
+duty of the court, and the effect of his clergy was to
+discharge him of all preceding felonies.<a id="FNanchor_534" href="#Footnote_534" class="fnanchor">[22]</a></p>
+
+<p><span class="pagenum"><a id="Page_233"></a>[233]</span></p>
+
+<p>The judgment of the court, in Stone’s case, as to
+the effect of clergy upon a preceding crime, was followed
+in an early North Carolina case,<a id="FNanchor_535" href="#Footnote_535" class="fnanchor">[23]</a> where the
+court held that if the defendant claimed clergy for an
+offense committed before clergy was granted to him,
+this claim should be urged the same as a pardon, when
+the prisoner was brought up for judgment on the latter
+conviction.</p>
+
+<p>The distinction between “clergyable” and “unclergyable”
+crimes was not so clearly defined during the
+thirteenth century, as at a later period. At this time
+the benefit of clergy was but the privilege of “ordained
+clerks” and the legislation of king John’s reign shows
+that the exemption was slowly and by degrees ordained
+as not applicable to the crime of high treason.<a id="FNanchor_536" href="#Footnote_536" class="fnanchor">[24]</a> While
+the exemption to the clerks of the twelfth century was
+much broader than later, during the thirteenth century
+clerks could be tried for all minor offenses and in Bracton’s
+day clerks were answerable to civil process the
+same as the laity.<a id="FNanchor_537" href="#Footnote_537" class="fnanchor">[25]</a> The clergy had so far established
+the exemption of their persons from corporal pains,
+that during the reign of Henry III. it was enacted that
+a clerk, taken for the death of a man, or for any other
+crime, if demanded by the ordinary, was to be immediately
+delivered, without inquisition, to the court
+Christian, to make canonical purgation and to establish
+his innocence or stand convicted.<a id="FNanchor_538" href="#Footnote_538" class="fnanchor">[26]</a></p>
+
+<p>During the reign of Edward I., the practice established<span class="pagenum"><a id="Page_234"></a>[234]</span>
+during the reign of Henry III., that a clerk, convicted
+of felony, could be delivered to the ordinary, was
+recognized by act of Parliament (Statute Westminster),
+and this statute recited this privilege and simply admonished
+the prelates not to liberate those so delivered
+to them, without putting them to their canonical purgation.<a id="FNanchor_539" href="#Footnote_539" class="fnanchor">[27]</a>
+In the 25’ year of Edward III. the clergy
+complained to Parliament that a certain knight, entitled
+to clergy, had been hanged and quartered, on a
+judgment of treason and that a priest had been hanged
+for killing his master. These complaints led to the
+enactment of the statute <i>De Clero</i> (25 Edward III.
+st. 3) by the terms of which it was provided that
+henceforth all manner of clerks, as well secular as religious,
+convicted before any secular justice, for treason
+or felony, touching other persons than the king himself
+or his royal majesty, should freely have and enjoy
+the privilege of the holy church and should, without
+any impeachment or delay, be delivered to the ordinary
+demanding them.<a id="FNanchor_540" href="#Footnote_540" class="fnanchor">[28]</a></p>
+
+<p>During the reign of Henry VII. (7 Henry VII., c. 1),
+the benefit of clergy was taken away from persons convicted
+of desertion while under enlistment as soldiers
+of the crown and the privilege was likewise taken away
+from those convicted of petit treason. The exemption
+of the clergy from punishment for crimes was given
+a most decided set-back by the statute 4’ Henry VIII.,
+c. 2, which provided that:</p>
+
+<div class="blockquote">
+
+<p>“All persons committing murder or felony, in any
+church, chapel, or hallowed place; or who, of malice
+prepens, rob or murder any person in the king’s highway,<span class="pagenum"><a id="Page_235"></a>[235]</span>
+or rob or murder any person in his house, the
+owner or dweller of the house, his wife, child or servant
+being then therein, and put in fear or dread, shall
+not be admitted to clergy.”</p>
+
+</div>
+
+<p>This statute contained no exception of those actually
+engaged in the holy orders and this led to the most
+determined resistence on the part of the clergy of the
+kingdom.<a id="FNanchor_541" href="#Footnote_541" class="fnanchor">[29]</a> Henry VIII. stood firm, however, and
+during the same reign another statute was passed
+(23 Henry VIII., c. 1), taking away the benefit of
+clergy from persons convicted of petit treason, wilful,
+malicious murder, robbery, wilful burning of a dwelling
+house, or barn, where grain or corn was stored, and
+the like privilege was denied to the abettors, helpers,
+maintainers or counselors of such felons, except only
+such as were within the holy orders. It was also made
+a felony, without clergy, for a clerk convict to break
+prison and escape, and this was a serious blow to the
+exemption, for though the lives of the clergy were
+spared, after conviction of the offenses named, yet they
+were to be condemned to imprisonment and even to
+death, if the ordinary so directed.<a id="FNanchor_542" href="#Footnote_542" class="fnanchor">[30]</a></p>
+
+<p>By 27 Henry VIII., c. 17, clergy was also taken away
+from servants who embezzled their master’s goods or
+property, and by 28 Henry VIII., c. 1, persons under
+holy orders were to be judged the same as those not
+under holy orders, so that real clerks were subjected
+to capital punishment for felony, the same as nominal
+clerks.<a id="FNanchor_543" href="#Footnote_543" class="fnanchor">[31]</a> During the same reign, by statute 33 Henry<span class="pagenum"><a id="Page_236"></a>[236]</span>
+VIII., c. 1 to 14, clergy was denied to persons practicing
+witchcraft or enchantment and to those making prophesies
+upon coates of arms, badges, etc.<a id="FNanchor_544" href="#Footnote_544" class="fnanchor">[32]</a> Before the
+reign of Elizabeth, the granting or recording clergy
+had been reduced to a mere formality, but by 18’ Elizabeth,
+it was provided that the temporal courts should
+not deliver the prisoner, until he had been burned in
+the hand.<a id="FNanchor_545" href="#Footnote_545" class="fnanchor">[33]</a></p>
+
+<p>Benefit of clergy was not abolished, in England,
+until the year 1825, when, by statute, 7 George IV., c.
+28, sec. 6, this ancient privilege of the middle ages
+was abolished, in that country.</p>
+
+<p>In the United States, by Act of Congress, April 30’,
+1790, it was provided that the benefit of clergy should
+not be allowed upon conviction for any crime where,
+by statute, the punishment was death. In North Carolina,
+in 1816, the punishment by burning in the hand
+was abrogated, and, in Kentucky, the benefit of clergy
+was abolished, by statute, in 1847.<a id="FNanchor_546" href="#Footnote_546" class="fnanchor">[34]</a></p>
+
+<p>The celebrated case of Doctor Horsey, Chancellor
+to the Bishop of London, who, during the reign of
+Henry VIII., was prosecuted and adjudged guilty of
+the murder of John Hunne, is one of the most interesting
+that has come to the writer’s attention. On
+account of the well known position of Doctor Standish,
+as an advocate of the temporal power, the clergy concluded
+not to wait upon the procedure of the temporal
+courts, in Doctor Horsey’s case, but they caused a
+charge of heresy to be lodged against Doctor Standish,<span class="pagenum"><a id="Page_237"></a>[237]</span>
+because of his advocacy of the power of the temporal
+courts over the persons and punishment of clerks. The
+clergy and the justices of the King’s Courts had a notable
+dispute concerning the power of the temporal courts
+over the persons of clerks, the clergy contending that
+the benefit of clergy was established by the express
+command of Jesus Christ, in the words, <i>nolite tangere
+Christos meos</i>, while the temporal justices argued that
+these were the words of King David, not of the Saviour
+at all, and that the “anointed,” referred to the believers,
+to distinguish them from the unbelievers, then
+abroad in Palestine. Those who had proceeded against
+Doctor Standish were adjudged guilty of a <i>praemunire</i>,
+when Cardinal Wolsey threw himself at the king’s feet
+and beseeched him to withhold his decision until the
+Pope could be heard from. King Henry, however,
+decided that the arguments of the supporters of Doctor
+Standish had not been answered by the clergy and
+concluded with all of his accustomed firmness:</p>
+
+<div class="blockquote">
+
+<p>“By the order and sufferance of God, we are king of
+England; and the kings of England who have gone
+before us never had any superior but God alone; and,
+therefore, know that we will maintain the right of our
+crown and temporal jurisdiction, as well in this point
+as in others, in as ample a manner as our predecessors
+have done before us.”<a id="FNanchor_547" href="#Footnote_547" class="fnanchor">[35]</a></p>
+
+</div>
+
+<p>This decisive stand of the King concluded the agitation
+concerning the conflict of authority over the case
+of Doctor Horsey. Doctor Standish was discharged
+from the charge of heresy. Doctor Horsey was so far
+rescued from temporal power, however, that he enjoyed<span class="pagenum"><a id="Page_238"></a>[238]</span>
+the free custody of the house of the Archbishop
+of Canterbury, until the popular clamor had subsided,
+when he was privately surrendered to the court of
+King’s Bench and having entered a plea of not guilty,
+it was confessed and the defendant was discharged.<a id="FNanchor_548" href="#Footnote_548" class="fnanchor">[36]</a></p>
+
+<p>Although the clergy thus failed to convince Henry
+VIII. of the true foundation of its power, in the case
+of Doctor Standish, it lost none of its authority against
+the temporal courts, in the case of Doctor Horsey, but
+its jurisdiction and the benefit of clergy was practically
+conceded by the judges of the king’s court and the
+privilege continued to be recognized until the 23’ year
+of this king’s reign, when he waged war against the
+whole papal authority and passed an act taking away
+the benefit of clergy from murder and robbery, in certain
+cases.<a id="FNanchor_549" href="#Footnote_549" class="fnanchor">[37]</a></p>
+
+<p>One of the most distinguished men known to have
+been accorded the benefit of clergy, in England, was
+the gifted Ben Jonson, the friend of “gentle Shakespeare”
+and the scholarly Lord Bacon. He was arraigned
+at the Old Bailey, in October, 1598, for the
+manslaughter of Gabriel Spencer, in a duel. The indictment
+charged that the defendant, at Shordiche, had,</p>
+
+<div class="blockquote">
+
+<p class="noindent">“with a certain sword of iron and steel called a rapiour,
+of the price of 3s., which he then and there had in his
+right hand and held drawn, feloniously and wilfully
+struck the same Gabriel then and there with the aforesaid
+sword, giving to the same Gabriel Spencer, in and
+upon the same Gabriel’s right side a mortal wound, of
+the depth of six inches and of the bredth of one inch,<span class="pagenum"><a id="Page_239"></a>[239]</span>
+of which mortal wound the same Gabriel then and
+there died instantly.”<a id="FNanchor_550" href="#Footnote_550" class="fnanchor">[38]</a></p>
+
+</div>
+
+<p>The record in this same case further shows that the
+prisoner when arraigned,</p>
+
+<div class="blockquote">
+
+<p>“Confessed the indictment, asked for the book, read
+like a clerk, was marked with the letter T, and delivered
+according to the form of the statute,”</p>
+
+</div>
+
+<p class="noindent">which meant that the author of “Every Man in His
+Humor” had claimed and been accorded the benefit
+of clergy; that he had been branded on the left thumb
+with a T, generally known as the Tyburn T, and discharged.<a id="FNanchor_551" href="#Footnote_551" class="fnanchor">[39]</a></p>
+
+<p>The benefit of clergy was set up and recognized in
+many criminal cases in the United States, during the
+Colonial period and the great patriot, James Otis, successfully
+urged the exemption in favor of Massachusetts
+soldiers, convicted of murder for their participation
+in the Boston massacre.<a id="FNanchor_552" href="#Footnote_552" class="fnanchor">[40]</a> The Federal Court
+decided, in the year 1817, in the case of United States
+vs. Lambert,<a id="FNanchor_553" href="#Footnote_553" class="fnanchor">[41]</a> that a person convicted of bigamy, in
+Alexandria, was entitled to clergy, and, if able to read,
+should be burned in the hand and recognized for good
+subsequent behaviour. In the year 1830, the Federal
+Court held, in the case of United States vs. Jernegan<a id="FNanchor_554" href="#Footnote_554" class="fnanchor">[42]</a><span class="pagenum"><a id="Page_240"></a>[240]</span>
+that on a conviction for bigamy, in granting the benefit
+of clergy, it was discretionary with the trial court to
+dispense with the burning in the hand.</p>
+
+<p>In the year 1806 the Supreme Court of North Carolina
+held that females could claim the benefit of clergy,
+the same as males.<a id="FNanchor_555" href="#Footnote_555" class="fnanchor">[43]</a> The Legislature of North Carolina,
+having, in 1816 passed a statute abolishing the
+punishment of “burning in the hand” for clergyable
+felonies, the Supreme Court of that state, construing
+this statute, in 1825, in the case of State vs. Yeater,<a id="FNanchor_556" href="#Footnote_556" class="fnanchor">[44]</a>
+held that corporal punishment and imprisonment could
+not both be inflicted upon a person found guilty of the
+crime of manslaughter.</p>
+
+<p>In 1837, however, in the same state the same court
+held that one found guilty of manslaughter could be
+burned in the hand and also imprisoned for one year.
+And in the year 1855, the Supreme Court of North
+Carolina held that when a new felony was created by
+statute, the privilege of clergy was an incident thereto,
+unless it was expressly taken away by the statute
+creating the offense.<a id="FNanchor_557" href="#Footnote_557" class="fnanchor">[45]</a> And in State vs. Carroll,<a id="FNanchor_558" href="#Footnote_558" class="fnanchor">[46]</a> the
+same court held that when the defendant prayed the
+benefit of clergy, for a clergyable offense, if the State
+objected because the defendant had before had clergy,
+this objection must be set up by a plea in writing.</p>
+
+<p>In State vs. Sutcliff,<a id="FNanchor_559" href="#Footnote_559" class="fnanchor">[47]</a> decided in South Carolina, in
+1855, a defendant, convicted of burning a dwelling<span class="pagenum"><a id="Page_241"></a>[241]</span>
+house, was held entitled to the benefit of clergy, and in
+the same state, the same year, another person convicted
+of arson in the nighttime, was held entitled to clergy.<a id="FNanchor_560" href="#Footnote_560" class="fnanchor">[48]</a></p>
+
+<p>In Indiana, in 1820, and in Minnesota, in 1859, the
+Supreme Courts of those states held that the benefit
+of clergy did not and never had existed in those commonwealths,<a id="FNanchor_561" href="#Footnote_561" class="fnanchor">[49]</a>
+and in the year 1787 the Supreme Court
+of Virginia held that the crime of arson was not a
+clergyable offense in the courts of that state.<a id="FNanchor_562" href="#Footnote_562" class="fnanchor">[50]</a> But
+in the same state, in 1795, two persons were convicted
+for stealing a horse, in 1793, and before the <i>sentence of
+death</i> was pronounced, they both prayed the benefit
+of clergy and the Supreme Court held that they were
+entitled to clergy.<a id="FNanchor_563" href="#Footnote_563" class="fnanchor">[51]</a></p>
+
+<p>One of the last cases where clergy was recognized, in
+the United States, was in a Kentucky case.<a id="FNanchor_564" href="#Footnote_564" class="fnanchor">[52]</a> A negro
+was convicted of rape upon a white woman, after a
+trial had before Judge Buckner, in Bonner County,
+at Glasgow. Under the statute, the punishment to be
+assessed was death and the judge believed the defendant
+innocent of the crime for which he had been
+convicted. The defendant’s counsel claimed the benefit<span class="pagenum"><a id="Page_242"></a>[242]</span>
+of clergy for him and the defendant was found able
+to read the Constitution of the United States and he
+was accordingly burned in the hand and discharged.</p>
+
+<p>These instances are not nearly all that could be
+found in England or the United States to illustrate
+the application of this exemption from crime, at common
+law, but the random cases mentioned will show
+the general recognition of the privilege until comparatively
+recent times.</p>
+
+<p>There is no doubt but what the benefit of clergy bred
+much crime and operated, for centuries, as a great
+impediment in the impartial enforcement of the criminal
+laws of England and the United States. Like the
+right of sanctuary, established by the early Saxon
+kings, the benefit of clergy owed its existence to the fact
+that the law’s redress of wrongs was, at an early period
+in the history of the world, inadequate to protect the
+educated class from the ambition and cupidity of the
+race and in the dangerous games for place and power
+then waged, these privileges were very dear to Englishmen
+and on the whole, were strictly respected.</p>
+
+<p>Judged by modern standards, the exemption of the
+clergy, enlarged to include all those who could read,
+from the punishment that others, similarly situated,
+were subjected to, who were not so fortunate as to
+be able to read, seems an anomaly in the administration
+of any system of justice; but it must be accepted as
+a mere incident of the barbarous period when the privilege
+was applied.</p>
+
+<p>As a doctrine of the common law, it illustrates the
+fallibility of all institutions of man, both in and out
+of the holy orders. The privilege had neither justice nor<span class="pagenum"><a id="Page_243"></a>[243]</span>
+reason for its foundation, but, like the practice of witchcraft,
+enchantment and the belief in ghosts, so prevalent
+during the same period, it owed its existence to the
+ignorance and superstition of that civilization. Because
+of such an unjust practice the common law is not to
+be condemned, any more than is the literature of the
+same period of English history, because of the introduction
+of ghosts, witchcraft and enchantment, into
+the literary masterpieces of the past centuries, for
+these beliefs were prevalent at that time.</p>
+
+<p>The Benefit of Clergy was an institution of the
+“myriads who, before us, pass’d the door of darkness
+through.” No doubt some of our institutions and
+procedure, to the jurists of succeeding ages, that come
+and go, “upon this chequer-board of nights and days,”
+will seem equally as unjust and ridiculous as this institution
+of the past now appears to us. We should
+congratulate ourselves, that with our own liberal constitution,
+founded upon a more exact idea of distributive
+justice, we are able to “grasp this sorry scheme
+of things,” which existed until the present century.
+But that this institution continued until the past century,
+ought to prevent our entire satisfaction with our
+own procedure, and urge us to the improvement of our
+present laws.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_513" href="#FNanchor_513" class="label">[1]</a> Bracton, Ch. XII., fol. 409.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_514" href="#FNanchor_514" class="label">[2]</a> Glanville, lib. V. c. VIII., IX.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_515" href="#FNanchor_515" class="label">[3]</a> Maitland, Henry II. and Criminous Clerks, E. H. B. vii 224;
+I. Pollock and Maitland’s History Eng. Law, p. 447.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_516" href="#FNanchor_516" class="label">[4]</a> II. Reeve’s History English Law, p. 341.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_517" href="#FNanchor_517" class="label">[5]</a> Bracton, De Legibus, lib. V. c. XI., XII.; II. Reeve’s History
+English Law, p. 344.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_518" href="#FNanchor_518" class="label">[6]</a> III. Reeve’s History English Law, p. 196.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_519" href="#FNanchor_519" class="label">[7]</a> Decret, lib., 1, tit. 10; III. Reeve’s History English Law, p. 348.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_520" href="#FNanchor_520" class="label">[8]</a> Mirror, c. V.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_521" href="#FNanchor_521" class="label">[9]</a> 1 Chronicles, XVI. 15, 22; Also, 1 Kings, XXVI. 9; 2 Kings,
+I. 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_522" href="#FNanchor_522" class="label">[10]</a> 1 Chitty, Criminal Law, 667, 668; 1 Bishop’s Criminal Law,
+Secs. 622, 624; 4 Bl. Comm. ch. 28.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_523" href="#FNanchor_523" class="label">[11]</a> Bouvier’s Dictionary, tit. Benefit of Clergy.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_524" href="#FNanchor_524" class="label">[12]</a> II. Hale’s Pleas of Crown, 328, 371; I. Pollock and Maitland’s
+History English Law, p. 445. By a curious combination of terms,
+some of the old cases refer to the exemptions women in pregnancy
+enjoyed in the law, as “Clergy of the belly.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_525" href="#FNanchor_525" class="label">[13]</a> Webster’s New Int. Dict; Murray’s English Dict., “Neck-verse.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_526" href="#FNanchor_526" class="label">[14]</a> Bracton f, 123b; I. Pollock and Maitland’s History English Law,
+p. 442.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_527" href="#FNanchor_527" class="label">[15]</a> Coke, 2 Inst. 164.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_528" href="#FNanchor_528" class="label">[16]</a> III. Reeve’s History English Law, pp. 197, 198.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_529" href="#FNanchor_529" class="label">[17]</a> IV. Reeve’s History English Law, p. 59.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_530" href="#FNanchor_530" class="label">[18]</a> 9 Edward IV. 28.</p>
+
+<p>Kelying reports a case, where at the Lent Assizes, for Winchester,
+the clerk appointed by the bishop to give clergy for the prisoners,
+charged with larceny, delivered the book to the prisoner and the
+prisoner did not look at the book at all, but when asked, “<i>legit</i> or
+<i>non-legit</i>,” the clerk replied “<i>legit</i>.” The court then bid the clerk
+of assizes not to record that the prisoner read, and fined the bishop’s
+clerk for so finding. (18 Car. II.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_531" href="#FNanchor_531" class="label">[19]</a> Littleton, 2 Inst. 164; IV. Reeve’s History English Law, p. 60.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_532" href="#FNanchor_532" class="label">[20]</a> IV. Reeve’s History English Law, p. 466.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_533" href="#FNanchor_533" class="label">[21]</a> 5 Eliz. Dyer, 50; V. Reeve’s History English Law, p. 346.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_534" href="#FNanchor_534" class="label">[22]</a> V. Reeve’s History English Law, p. 345.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_535" href="#FNanchor_535" class="label">[23]</a> State vs. Carroll, 27 N. C. (5 Ired.) 139.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_536" href="#FNanchor_536" class="label">[24]</a> II. Pollock and Maitland’s History English Law, p. 501.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_537" href="#FNanchor_537" class="label">[25]</a> Bracton, f. 401b; I. Pollock and Maitland’s History English Law,
+p. 130.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_538" href="#FNanchor_538" class="label">[26]</a> II. Reeve’s History English Law, pp. 421, 422.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_539" href="#FNanchor_539" class="label">[27]</a> II. Reeve’s History English Law, p. 573.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_540" href="#FNanchor_540" class="label">[28]</a> III. Reeve’s History English Law, p. 197.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_541" href="#FNanchor_541" class="label">[29]</a> IV. Reeve’s History English Law, pp. 458, 463.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_542" href="#FNanchor_542" class="label">[30]</a> IV. Reeve’s History English Law, p. 466.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_543" href="#FNanchor_543" class="label">[31]</a> IV. Reeve’s History English Law, p. 468.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_544" href="#FNanchor_544" class="label">[32]</a> IV. Reeve’s History English Law, p. 468.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_545" href="#FNanchor_545" class="label">[33]</a> V. Reeve’s History English Law, p. 346.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_546" href="#FNanchor_546" class="label">[34]</a> American Com. Kentucky, p. 407.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_547" href="#FNanchor_547" class="label">[35]</a> IV. Reeve’s History English Law, pp. 458, 462; Keilw. 180b, to
+185b.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_548" href="#FNanchor_548" class="label">[36]</a> Keilw. 180b, to 185b; IV. Reeve’s History English Law, pp.
+458, 462.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_549" href="#FNanchor_549" class="label">[37]</a> IV. Reeve’s History English Law, p. 463.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_550" href="#FNanchor_550" class="label">[38]</a> This original old musty indictment was recently unearthed at
+the old Sessions House, in London, by a representative of the
+London Globe and was delivered to the Council of Middlesex county
+for preservation.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_551" href="#FNanchor_551" class="label">[39]</a> It is reported that the wily Ben really bribed the jailer to use
+cold steel in branding him, as no marks were found on his hand
+after his death. (London Globe, April, 1910.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_552" href="#FNanchor_552" class="label">[40]</a> American Commonwealth, Massachusetts; Knapp’s “Sketches of
+Eminent Lawyers,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_553" href="#FNanchor_553" class="label">[41]</a> 2 Cranch, C. C. 137.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_554" href="#FNanchor_554" class="label">[42]</a> 4 Cranch, C. C. 118.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_555" href="#FNanchor_555" class="label">[43]</a> State vs. Gray, 5 No. Car. (1 Murph.) 147.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_556" href="#FNanchor_556" class="label">[44]</a> 11 No. Car. 4 Hawks. 187. And see, also, State vs. Kearney,
+8 No. Car. 1 Hawks. 53.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_557" href="#FNanchor_557" class="label">[45]</a> State vs. Bosse, 8 Rich. Law. 276.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_558" href="#FNanchor_558" class="label">[46]</a> 24 No. Car. 2 Ired. 257.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_559" href="#FNanchor_559" class="label">[47]</a> Suab. 372.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_560" href="#FNanchor_560" class="label">[48]</a> State vs. Bosse, 8 Rich. Law. 276.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_561" href="#FNanchor_561" class="label">[49]</a> Fuller vs. State. 1 Blatchf. 63; State vs. Bilansky, 3 Minn. 246;
+1 Gil. 169.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_562" href="#FNanchor_562" class="label">[50]</a> Commonwealth vs. Posey, 4 Coll. 109; 2 Am. Dec. 560.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_563" href="#FNanchor_563" class="label">[51]</a> Commonwealth vs. Stewart, 1 Va. Cas. 114.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_564" href="#FNanchor_564" class="label">[52]</a> American Com. Ky. p. 407. Ch. 21.</p>
+
+<p>That Thackeray was thoroughly familiar with the law governing
+the Benefit of Clergy and the nature of the punishment
+inflicted on the culprit pleading guilty of an offense clergyable at
+common law, is evidenced by his presentation of the plea in favor
+of Lord Mohun, the Earl of Warwick, Col. Westbury and Henry
+Esmond, in his interesting plot, in “Henry Esmond.”</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_244"></a>[244]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_IX">CHAPTER IX.<br>
+<span class="smcap">Privilege of Sanctuary.</span></h2>
+
+</div>
+
+<p>The privilege of sanctuary, sometimes called the privilege
+of asylum, was the exemption afforded criminals,
+taking refuge in certain consecrated places, from the
+ordinary operation of the law of arrest.</p>
+
+<p>The institution is no doubt older than the time of
+Moses and we find frequent references to it in the early
+books of the Bible.</p>
+
+<p>In the book of Exodus the old Mosaic law was stated
+to be: “He that smiteth a man, so that he die, shall
+be surely put to death,” but in the same book, it is
+written: “And if a man lie not in wait, but God deliver
+him into his hand; then I will appoint thee a place
+whither he shall flee.”</p>
+
+<p>Moses’ law thus distinguished between murder on
+malice aforethought and mere manslaughter, as we
+call it and according to the ancient law of the Israelites,
+there were cities of refuge to which a felon might
+flee, who killed a man unawares.</p>
+
+<p>Moses appointed six cities of refuge, three “on this
+side of Jordan” and three “in the land of Canaan,”
+in order that the slayer might flee thither which should
+kill his neighbour unawares, and hated him not in times
+past; and that fleeing to one of these cities, he might
+live.<a id="FNanchor_565" href="#Footnote_565" class="fnanchor">[1]</a></p>
+
+<p><span class="pagenum"><a id="Page_245"></a>[245]</span></p>
+
+<p>Deuteronomy refers to the case of “the slayer which
+shall flee thither that he may live”; distinguishing the
+man who lies in wait, from the man who “killeth his
+neighbour innocently, whom he hated not in times
+past.”<a id="FNanchor_566" href="#Footnote_566" class="fnanchor">[2]</a></p>
+
+<p>In the book of Joshua it is provided that “When he
+that doth flee to one of those cities shall stand at the
+entering of the gate of the city, and shall declare his
+cause in the ears of the elders of that city, they shall
+take him into the city unto them and give him a place,
+that he may dwell among them. And if the avenger of
+blood pursue after him, then they shall not deliver the
+slayer up into his hand; because he smote his neighbour
+unwittingly and hated him not beforetime.”<a id="FNanchor_567" href="#Footnote_567" class="fnanchor">[3]</a></p>
+
+<p>Over a thousand years before Christ we find Adonijah
+claiming the privilege of sanctuary to protect him
+from the wrath of Solomon, for it is recorded in the
+first book of Kings:<a id="FNanchor_568" href="#Footnote_568" class="fnanchor">[4]</a></p>
+
+<div class="blockquote">
+
+<p>“And Adonijah feared because of Solomon, and
+arose, and went and caught hold on the horns of the
+altar. And it was told Solomon, saying, Behold, Adonijah
+feareth king Solomon, for, lo, he hath caught hold
+on the horns of the altar, saying: Let king Solomon
+swear unto me today that he will not slay his servant
+with the sword. And Solomon said: If he will shew
+himself a worthy man, there shall not an hair of him
+fall to the earth; but if wickedness shall be found in
+him, he shall die.”</p>
+
+</div>
+
+<p><span class="pagenum"><a id="Page_246"></a>[246]</span></p>
+
+<p>This case of Adonijah taking refuge in the temple,
+at the altar, as a protection against the supposed wrath
+of Solomon, is nothing more nor less than a claim of
+sanctuary, for even the hand of Solomon was stayed at
+the threshold of such a consecrated place and the sinner
+taking refuge at the altar was supposed to be surrounded
+by the protecting mantle of the Great Jehovah.
+This is only one of many thousand similar concrete
+cases that could be mentioned, no doubt, if the unwritten
+history of the unnoticed millions of patriarchial
+days could be known, for the right of sanctuary obtained
+generally in those ancient days. The ever-flowing
+flood of time has swept away all records of the ordinary
+mortals, however, and only the great peer out
+through the darkness of the past.</p>
+
+<p>The conditions upon which sanctuary was bestowed,
+in the ancient days of the patriarchs was that the refugee
+should not quit the city of refuge until the death
+of the High Priest, for on this solemn occasion, the
+great public grief was supposed to over-shadow all
+merely private affairs. As recorded in the book of
+Joshua, one claiming sanctuary must stand at the gate
+of the city and “declare his cause in the ears of the
+elders”<a id="FNanchor_569" href="#Footnote_569" class="fnanchor">[5]</a>; the elders tried his case, to ascertain if he
+were guilty of malicious murder, or mere manslaughter,
+and if the case of murder was established by the
+“avenger of blood,” who acted as prosecutor, the criminal
+was given up, even though he clung to the altar,<a id="FNanchor_570" href="#Footnote_570" class="fnanchor">[6]</a><span class="pagenum"><a id="Page_247"></a>[247]</span>
+but if the elders found that he was not guilty of wilful
+murder, he was retained as “a prisoner at large” in
+the city of refuge, until the demise of the High Priest,
+when he was allowed to return to his home, duly purged
+of the crime for which he had fled. If he departed from
+the “city of refuge” before the death of the High
+Priest, however, he was regarded as an outlaw and
+could be slain by any man, as such.<a id="FNanchor_571" href="#Footnote_571" class="fnanchor">[7]</a></p>
+
+<p>According to Plutarch and Dr. Pegge, the right of
+sanctuary was recognized among the ancient Greeks
+and the Oratory of Theseus was one of the places of
+refuge for persons of lowly station, who fled to avoid
+the oppression of the great and powerful “avengers of
+blood.” The privilege afforded these lowly ones soon
+became a license for the protection of criminals, however,
+and the most notorious criminals were protected
+from the civil authorities and the holy places and
+temples came to be used as asylums and resorts for
+the most notorious criminals.<a id="FNanchor_572" href="#Footnote_572" class="fnanchor">[8]</a></p>
+
+<p>From Greece, the right of sanctuary spread to Rome,
+and although, by the Roman law, murderers, escaped
+slaves, robbers, and public debtors were excluded from
+sanctuary privileges,<a id="FNanchor_573" href="#Footnote_573" class="fnanchor">[9]</a> in the course of time, the priests
+refused to deliver up the slaves to their masters, the
+debtors to their creditors, or the murderers to the
+magistrates, and the temples and churches became regular
+dens for thieves, murderers and criminals of the
+worst kind.<a id="FNanchor_574" href="#Footnote_574" class="fnanchor">[10]</a></p>
+
+<p>Long after the civilizations of the ancient Jews and<span class="pagenum"><a id="Page_248"></a>[248]</span>
+Grecians had passed away, the privilege of sanctuary,
+which they recognized, was perpetuated in various
+forms, and in most of the later civilizations we find
+evidences of similar customs obtaining.</p>
+
+<p>Before the privilege of sanctuary was guaranteed by
+written statute law, the right was recognized by the
+general usage of the Christian church, in accordance
+with the early Mosaic law and in all the countries whose
+civilization borrowed from the ancient Israelites, there
+is evidence of such a custom.</p>
+
+<p>The Emperor Constantine, as early as the year 324
+caused laws to be enacted, extending and recognizing
+the privilege of sanctuary; Theodosus, in the year 392,
+made a law regulating the exemption to criminals of
+his day and Theodosus II. extended the freedom of
+sanctuary, from the altar and body of the church itself,
+to which it was previously confined, to all the buildings
+and places contained within the outer walls of the
+consecrated places, set apart for purposes of sanctuary.<a id="FNanchor_575" href="#Footnote_575" class="fnanchor">[11]</a></p>
+
+<p>Although the fact is not established by competent
+authority, it has been stated that the privilege of sanctuary
+obtained in England, as early as the close of
+the second century after Christ.<a id="FNanchor_576" href="#Footnote_576" class="fnanchor">[12]</a> The right may have
+been recognized as early as this date, but the history
+of the period does not give us any very authentic record
+to sustain that it did. Soon after the conversion of
+the Saxons to Christianity, however, all places of public
+worship were looked upon as so consecrated that<span class="pagenum"><a id="Page_249"></a>[249]</span>
+criminals taking refuge in any of them were temporarily
+protected from the process of the civil authorities.<a id="FNanchor_577" href="#Footnote_577" class="fnanchor">[13]</a></p>
+
+<p>Unlike the ancient Jews, the early Saxons received
+even the felons guilty of wilful murder, for a period
+of thirty days, if they paid the <i>Wehrgeld</i>, fixed by the
+officers of the church, according to the standing of the
+person killed; he was protected from the civil authorities
+for a period of thirty days, on payment of the
+<i>Wehrgeld</i>, if he provided his own sustenance, after
+which he was delivered to his friends.<a id="FNanchor_578" href="#Footnote_578" class="fnanchor">[14]</a></p>
+
+<p>As sanctuary was only extended to those, under the
+Mosaic law, who “declared their cause in the ears of
+the elders of the city,” so, under the Anglo-Saxon
+law, the criminal claiming sanctuary was required to
+confess his crime and declare that he sought the safety
+of the church to preserve his life.<a id="FNanchor_579" href="#Footnote_579" class="fnanchor">[15]</a></p>
+
+<p>Under the old Saxon law, however, the privilege was
+not extended for a longer period than forty days and
+at the end of that time, if the prisoner did not <i>abjure
+the realm</i>, he was delivered to his friends, or to the civil
+authorities. Under the practice known as <i>abjuration
+of the realm</i> if the sanctuary felon, within forty days
+after taking sanctuary, went, in sackcloth, before the
+coroner and confessed his guilt and took an oath to quit
+the realm and not to return, without the king’s license,
+he was then attainted of the felony, but was given an
+additional period of forty days to prepare for his<span class="pagenum"><a id="Page_250"></a>[250]</span>
+journey and to keep the privilege alive, he was compelled,
+within this period, to repair, with a cross in his
+hand, as an indicia of his crime, but an emblem of the
+protection afforded him by the church, to the port assigned
+him, and to there take his journey for some
+foreign shore.<a id="FNanchor_580" href="#Footnote_580" class="fnanchor">[16]</a></p>
+
+<p>Large numbers of the English felons, at an early day,
+by this practice known as <i>abjuration of the realm</i>, were
+induced to leave England and annually many such “undesirable
+citizens” took passage from Dover, to France
+or Flanders, under the threat of delivery to the civil authorities,
+to answer for their crime, if they did not voluntarily
+assume this perpetual banishment and suffer
+the forfeiture of their estate to the crown.<a id="FNanchor_581" href="#Footnote_581" class="fnanchor">[17]</a></p>
+
+<p>After <i>abjuration of the realm</i>, if the prisoner afterwards
+returned to England, without the license of the
+king, so to do, he was regarded as an outlaw and, when
+caught, was condemned to be hanged, unless he was a
+clerk, in which event, he was allowed to claim the
+<i>benefit of clergy</i>, and to be discharged, after the usual
+preliminaries and the punishment inflicted upon those
+claiming clergy for such a crime as the sanctuary criminal
+had committed.<a id="FNanchor_582" href="#Footnote_582" class="fnanchor">[18]</a></p>
+
+<p><span class="pagenum"><a id="Page_251"></a>[251]</span></p>
+
+<p>During the period of the forty days, while the criminal
+was enjoying his privilege of sanctuary, the <i>villata</i>
+where the crime was committed was required to watch
+the sanctuary, to prevent his escape, without <i>abjuration
+of the realm</i>; if the coroner did not come for the period
+of forty days, the township was required to watch the
+church for this full period and if the criminal escaped,
+because of the failure to do so, the township was
+amerced accordingly.<a id="FNanchor_583" href="#Footnote_583" class="fnanchor">[19]</a></p>
+
+<p>The privilege of sanctuary was recognized by the code
+of Ina, King of West Saxony, in 693, and the fifth section
+of the code provides that if a felon, who had been
+convicted of a capital offense fled to a church, or sanctuary,
+his life should be spared and if any criminal adjudged
+to be flogged, sought refuge in such consecrated
+place, the stripes, that he would otherwise receive,
+should be withheld from him.<a id="FNanchor_584" href="#Footnote_584" class="fnanchor">[20]</a></p>
+
+<p>In the year 887, under a statute of Alfred the
+Great, the privilege of three nights was allowed the
+criminal seeking the protection of the church, to enable
+him to prepare for his safety, and by this same provision
+of the law, if anyone violated the privilege of
+sanctuary, during the period named, by inflicting blows,
+wounds, or bonds, upon the sanctuary criminal, he was
+obliged to pay the sum of One hundred and twenty shillings<span class="pagenum"><a id="Page_252"></a>[252]</span>
+to the ministers of the church, whose precincts had
+been invaded.<a id="FNanchor_585" href="#Footnote_585" class="fnanchor">[21]</a></p>
+
+<p>The Mirror of Justice, reports that King Alfred
+caused a judge to be hanged, who had invaded the jurisdiction
+of the holy orders and removed, by civil process,
+a criminal who had sought the protection of
+sanctuary<a id="FNanchor_586" href="#Footnote_586" class="fnanchor">[22]</a> and it is certain that the right was not only
+safe-guarded by the law, in the time of Alfred, but that
+Ethelred and all subsequent Saxon kings expressly
+sanctioned the privilege.<a id="FNanchor_587" href="#Footnote_587" class="fnanchor">[23]</a></p>
+
+<p>With the advent of William the Conqueror, the law
+of sanctuary, with the other Saxon laws that he did not
+repeal, became more fixed and definite, but the extent
+of the privilege was more or less varied, by the laws
+or practices of the different subsequent kings.</p>
+
+<p>After the conquest the practice obtained of erecting
+a stone seat, beside the altar and several of these seats
+were erected in the English churches, and criminals
+fleeing to these seats were protected by the peace of
+the church, <i>pax ecclesiae</i>, and guarded by all its sanctity.
+To violate the protection afforded by this seat,
+or of the shrine of relics, was an offense too grave to be
+compensated by the payment of a mere money fine.
+One of these seats of stone still remains at Beverly and
+another at Hexham.</p>
+
+<p>The privilege at Beverley was granted by Athelstan
+and extended for a radius of a mile around St. John’s
+as the center. The outward and next outer boundaries
+of this circle were designated by crosses of rich carving.<span class="pagenum"><a id="Page_253"></a>[253]</span>
+The third boundary began at the entrance to the church
+and the sixth embraced the high altar and the “fridstool.”<a id="FNanchor_588" href="#Footnote_588" class="fnanchor">[24]</a></p>
+
+<p>In the four roads leading to the monastery of Hexham,
+in Northumberland, the boundary stones were
+rude crosses, around which, in Saxon characters and
+letters was the word “Sanctuarium,” which meant so
+much to the criminals of early times, seeking the protection
+of the “Chair of Peace.”</p>
+
+<p>The “fridstool” at Hexham has been carefully preserved
+and is much more extensive and handsome than
+that at Beverly, as it has interlaced Saxon and Norman
+ornaments on the top of the chair and a moulding extends
+below and around the seat.<a id="FNanchor_589" href="#Footnote_589" class="fnanchor">[25]</a></p>
+
+<p><span class="pagenum"><a id="Page_254"></a>[254]</span></p>
+
+<p>At Durham, the privilege extended to the church, the
+churchyard and the circuit. All who came within this
+solemn circle were protected, for the church was supposed
+to throw around them its protecting arms and the
+penalties for intruding upon this “charmed circle,” increased
+in proportion as the degree of holiness was desecrated.<a id="FNanchor_590" href="#Footnote_590" class="fnanchor">[26]</a></p>
+
+<p>William the Conqueror granted the charter to St.
+Martin’s le Grand and by the charter the privilege extended
+not only to the church, but to the college of St.
+Martin and the precincts thereof.<a id="FNanchor_591" href="#Footnote_591" class="fnanchor">[27]</a></p>
+
+<p>Westminster, perhaps the most famous sanctuary in
+England, received its charters from two of the kings of
+the Heptarchy and Edward the Confessor attempted to
+forever establish it as one of the perpetual sanctuaries
+of England, for all classes of criminals, in the following
+broad grant:</p>
+
+<div class="blockquote">
+
+<p>“I order and establish, forever, that what person, of
+what condition or estate soever he be, from whence soever
+he come, or for what offence or cause it be, either
+for his refuge in the said holy place, he be assured of
+his life, liberty and limbs. And over this, I forbid, under
+the pain of everlasting damnation, that no minister
+of mine, or of my successors, intermeddle with any the
+goods, lands, or possessions of the said persons taking
+the said sanctuary.... And whomsoever presumes
+or doth contrary to this my graunt I will he lose
+his name, worship, dignity and power and that with the
+great traitor Judas, that betrayed our Saviour, he be
+in everlasting fire of hell; and I will and ordain that<span class="pagenum"><a id="Page_255"></a>[255]</span>
+this my graunt endure as long as there remaineth in
+England, either love or dread of Christian name.”<a id="FNanchor_592" href="#Footnote_592" class="fnanchor">[28]</a></p>
+
+</div>
+
+<p>So essential was it then regarded to maintain, at all
+hazards, the <i>pax ecclesiae</i>, that the red handed murderer,
+even, when he once reached the sacred precincts
+of the church’s domain, was to be protected from the
+mere temporal powers of the earth, because he thus
+placed his faith in a higher law and the mundane
+officers of the law, for attempting to preserve the peace
+of the realm, if they transgressed upon the sacred soil
+consecrated to the Lord and used also for the protection
+of criminals, were classed along with traitors to
+the Lord and a dire curse proclaimed against them. It
+is well for the race that such delusions have passed
+away, along with the delusions of witchcraft and other
+fanaticisms of that age.</p>
+
+<p>The Whitefriars, or Alsatia, an establishment of the
+Carmelites, was founded by Sir Patrick Grey, in the
+year 1241, upon a plot of ground, granted by Edward I.,
+on Fleet street, located between what is now Salisbury
+street and the Temple, and Fleet street and the river
+Thames.<a id="FNanchor_593" href="#Footnote_593" class="fnanchor">[29]</a></p>
+
+<p>According to the law, as it finally developed, if a
+man fled to any one of the many sanctuaries, <i>chartered
+by the Crown</i>, and claimed protection from the civil authorities
+for a crime he had committed, regardless of
+the enormity of his crime, he could remain there undisturbed,
+for life and was not obliged to make his
+<i>abjuration of the realm</i>, as he was required to do in case
+the asylum was not such a chartered institution. Many<span class="pagenum"><a id="Page_256"></a>[256]</span>
+of these chartered asylums were established, and aside
+from those mentioned, there were sanctuaries so chartered
+at Wells, Norwich, York, Manchester, Derby,
+Lancaster and Northampton.<a id="FNanchor_594" href="#Footnote_594" class="fnanchor">[30]</a></p>
+
+<p>In the absence of a special charter, however, the
+crime of treason was not a sanctuary crime and traitors
+were not protected, even though they sought the portals
+of such consecrated places.<a id="FNanchor_595" href="#Footnote_595" class="fnanchor">[31]</a></p>
+
+<p>During the reign of Edward I., about the year 1262,
+the Abbot of Westminster attempted to extend the privilege
+of sanctuary, to those guilty of treason, to debtors
+and other classes of criminals than those who had formerly
+enjoyed the right and he also contended that the
+civil officers were not allowed, under the conditions of
+the charter of that institution, to enter upon any places,
+however remote, that belonged to the abbey. A law suit
+resulted and notwithstanding the broad terms of the
+charter above quoted, it was decided by all the justices
+that sanctuary was confined to felons alone and that
+the sheriffs of London had a right to enter the town
+of Westminster and to proceed to the very gates of the
+abbey and to enter the houses of the abbey elsewhere
+in the county, to arrest felons.<a id="FNanchor_596" href="#Footnote_596" class="fnanchor">[32]</a></p>
+
+<p><span class="pagenum"><a id="Page_257"></a>[257]</span></p>
+
+<p>The class of criminals who sought protection under
+the right of sanctuary, included the whole gamut of
+crimes known to English law, murder or homicide, debt,
+horse and cattle stealing, housebreaking, or burglary,
+escaping from prison, rape, harbouring a thief, treason,
+receiving stolen goods, counterfeiting, larceny and the
+other crimes common in the realm and made so by
+statute, or existing at common law.</p>
+
+<p>During the reign of Henry VII., it was decreed that
+when an offender fled to sanctuary, it was not enough
+for him to declare that he came there to save his life, but
+he must add that he had committed a felony; though
+he need not specify the felony, before the coroner
+came.<a id="FNanchor_597" href="#Footnote_597" class="fnanchor">[33]</a> But if he failed to make such a general declaration,
+he could be dragged from the sanctuary and
+was not exempt from civil process.<a id="FNanchor_598" href="#Footnote_598" class="fnanchor">[34]</a></p>
+
+<p><span class="pagenum"><a id="Page_258"></a>[258]</span></p>
+
+<p>The system whereby the felon fled to sanctuary and
+was accorded the privilege is described in the literature
+of the period descriptive of the manner of enjoying
+this right.</p>
+
+<p>A knocker was usually provided at the outer door of
+the abbey and one or two janitors roomed above the
+door, to admit such nocturnal visitors as called at different
+hours to claim their sanctuary. After the refugee
+was admitted to the sanctuary, the Galilee Bell
+was tolled, to announce to the outer world that another
+sanctuary criminal had been admitted. A gown of
+black cloth, with a yellow cross, was given to the culprit
+to wear and he was disarmed and assigned to his quarters.<a id="FNanchor_599" href="#Footnote_599" class="fnanchor">[35]</a></p>
+
+<p>The oath administered to the refugee has been preserved
+by the Harleian Manuscripts<a id="FNanchor_600" href="#Footnote_600" class="fnanchor">[36]</a> and a form of<span class="pagenum"><a id="Page_259"></a>[259]</span>
+confession and abjuration, administered by Sir William
+Rastall, Chief Justice of the Court of Common Pleas
+during the reign of Queen Mary, has been handed down
+to us.<a id="FNanchor_601" href="#Footnote_601" class="fnanchor">[37]</a></p>
+
+<p>While the right was held not to extend to cases of
+treason, generally, in different reigns, we find that it
+was extended to include treason, as well as the lesser
+felonies.</p>
+
+<p>Henry IV. wrote a letter to Cardinal Langley, which
+is preserved in the Treasury,<a id="FNanchor_602" href="#Footnote_602" class="fnanchor">[38]</a> wherein that monarch
+respected the privilege of sanctuary, even in a case of
+treason, and asked the protection of St. Cuthbert for
+the person of Robert Marshall, “late comitted to prison
+for treason, now escaped and broken into the same into<span class="pagenum"><a id="Page_260"></a>[260]</span>
+youre church of Duresme; we having tender zele and
+devocion to the honour of God and St. Cuthbert, ...
+wol that for that occasion nothyng be attempted that
+shal be contrarie to the liberties and immunitie of our
+church. We therefor wol and charge you that he be
+surely kept there, as ye wol answere unto us for him.—Yeven
+under our signet at our towne of Stanford, the
+xxvii day of July.”</p>
+
+<p>There was flagrant breach of the ancient privilege of
+sanctuary, in England, in 1378, in the case of Sir
+Robert Haule and Sir John Shackle. Having escaped
+from the Tower, these gentlemen took refuge in Westminster.
+Boxhall, the constable of the Tower, with fifty
+armed men pursued them and although the celebration
+of mass was in progress, when they entered the abbey,
+they pursued the prisoners and although Sir John
+Shackle escaped, they killed Sir Robert Haule, by hacking
+him, with their swords, while he ran around the
+choir, until he fell dead, with twelve serious wounds,
+near the prior’s cell.<a id="FNanchor_603" href="#Footnote_603" class="fnanchor">[39]</a></p>
+
+<p>Owen Tudor, the father of Henry VII. took refuge at
+Westminster and Queen Elizabeth, the widow of Edward
+IV., with her son, also took sanctuary there to
+escape the ferocity of her inhuman brother-in-law,
+Richard III.</p>
+
+<p>Sir Thomas More gives a graphic account of the
+sanctuary of Elizabeth:</p>
+
+<div class="blockquote">
+
+<p>“Therefore now she (Queen Elizabeth Woodville)
+toke her younger sonne the Duke of Yorke and her
+daughters, and went out of the Palays of Westminster,<span class="pagenum"><a id="Page_261"></a>[261]</span>
+into the Sanctuary and there lodged in the Abbote’s
+Hac and she and all her children and campaignie were
+registered for Sanctuary persons. Whereupon, the
+Bishop (Lord Chancellor Rotheram, Archbishop of
+Yorke) called up all his servants and took with him the
+great seal and came before day to the Queen, about
+whom he found much heavyness, rumble, haste, businesse,
+conveighaunce, and carriage of her stuffe into
+Sanctuary. Every man was busy to carry, bear, conveigh,
+stuffe, chestes, and fardelles, no man was unoccupied,
+and some carried more than they were commanded
+to another place. The Queene sat belowe on
+the rushes, all desolate and dismayed.”<a id="FNanchor_604" href="#Footnote_604" class="fnanchor">[40]</a></p>
+
+</div>
+
+<p>A pathetic picture, of this poor widowed Queen, sitting
+all alone, amid the green rushes, a refugee from
+the ferocity of her wolfish brother-in-law. One devoid
+of chivalry and possessing only common human instincts
+of pity would have offered protection to a lady
+in such sad plight, but history does not record it of
+“Crookbacked Richard,” for he determined early to
+prove a villain and, to clothe his naked villany “with
+old odd ends stol’n forth of holy writ”; he seemed a
+saint, when most he played the devil and was not only
+devoid of pity for others, but found, in himself, no pity
+for himself.<a id="FNanchor_605" href="#Footnote_605" class="fnanchor">[41]</a></p>
+
+<p>An instance of the temporary violation of the royal
+charter privileges granted to St. Martin’s le Grand, occurred
+in September, 1442, when an officer was conducting
+a prisoner from Newgate to Guildhall. When
+they reached Panyer Alley five of the prisoner’s friends
+rushed out and rescued him from the officer and took
+him to St. Martin’s claiming sanctuary. The sheriffs<span class="pagenum"><a id="Page_262"></a>[262]</span>
+of London went to the Church and not only took the
+prisoner, but all five of his friends, with chains round
+their necks to Newgate. The matter was brought before
+the King’s Star Chamber, by the Dean and Chapter
+of St. Martin’s le Grand and the claim advanced
+that the ancient charter privileges of the Church had
+been violated by the Sheriffs and the King ordered the
+men to be sent back to St. Martin’s “there to abide
+freely, as in a place having franchises, whiles them
+liked.”<a id="FNanchor_606" href="#Footnote_606" class="fnanchor">[42]</a></p>
+
+<p>During the reign of Henry VII., the interesting case
+of Humphrey Stafford, was decided, wherein the right
+of sanctuary, in treason, was expressly denied. Stafford
+had been attainted of treason and claimed sanctuary
+but was taken from the sanctuary and imprisoned
+in the Tower. When brought to the Bar of the King’s
+Bench, he pleaded his right of sanctuary, but after
+solemn discussion and reflection, the judges gave a
+unanimous decision that treason was such an exalted
+crime against the prerogatives of the King, that it
+could not be included within the crimes for which
+sanctuary would be allowed, and they disregarded the<span class="pagenum"><a id="Page_263"></a>[263]</span>
+ancient charters to the contrary and gave judgment that
+Stafford should be executed.<a id="FNanchor_607" href="#Footnote_607" class="fnanchor">[43]</a></p>
+
+<p>It was attempted to have this holding reviewed the
+year following the decision, when the Abbot of Abingdon
+appeared before the judges and produced his
+ancient charters, upon which he claimed his privileges
+were founded and the whole issue was gone into in
+exchequer chamber, before the judges. The Abbot
+claimed that the judges should confer with the prelates
+before pronouncing judgment, but one of the
+judges replied that:</p>
+
+<div class="blockquote">
+
+<p>“There can be no franchise without grant from the
+king. For the king can grant that any person who
+enters such a place, having committed treason, shall
+not be taken therefrom. And this shows that it can be
+done without the assent of Pope or Bishop, and that
+the Pope cannot do it within this realm. For to pardon
+or dispense with treason, pertains exclusively to the
+king. And a place of safety, is as a <i>privilege</i>, not as
+sanctuary. But when the Pope has consecrated the
+place, then it is sanctuary, not before.... But
+the principle of protection arises by our law, of which
+the cognizance belongs to us.”</p>
+
+</div>
+
+<p>And this view obtaining, the Abbot was denied his suit
+and it was finally held that no right of sanctuary existed
+in case of a charge of treason.<a id="FNanchor_608" href="#Footnote_608" class="fnanchor">[44]</a></p>
+
+<p>Illustrating the growing tendency to limit the privilege
+of sanctuary during the reign of Henry VII.,
+another significant case, will not be studied in vain.<span class="pagenum"><a id="Page_264"></a>[264]</span>
+Two felons were taken out of sanctuary, at Southwark
+and when arraigned for their crimes before Sir
+Thomas Frowike, Chief Justice, they pleaded their
+sanctuary and prayed to be restored. They were commanded
+to plead to the felonies with which they were
+charged, on the merits, but refused, claiming that as
+they were wrongfully taken out of sanctuary they were
+bound to plead to the indictment; the court, however,
+found that they had not been taken out of sanctuary and
+then, without arraigning them again, ordered that they
+be subjected to the terrible <i>peine forte et dure</i>, for
+standing mute and refusing to plead. So final judgment
+was entered, notwithstanding their right to sanctuary,
+that they be taken to the jail, from whence they
+came, and laid upon the bare ground, and that so much
+weight be laid upon them as they could suffer and more,
+and that they should have nothing to eat but bread and
+water; and that so they should be kept, continually,
+until they died.<a id="FNanchor_609" href="#Footnote_609" class="fnanchor">[45]</a></p>
+
+<p>As indicative of the cruelty and barbarism then obtaining,
+this judgment is an important index and that
+such a judgment should have been rendered against
+men claiming the privilege of sanctuary, was not only
+contrary to the law of <i>peine forte et dure</i>, which punishment
+was only assessed upon those standing mute and
+refusing to plead at all, and not to those claiming an
+exemption given them by such a well settled custom
+approved by the laws and decisions of the courts for
+many centuries, but it was certainly contrary to the
+spirit and intent of the law and condemns the judges<span class="pagenum"><a id="Page_265"></a>[265]</span>
+pronouncing such a harsh judgment, even unto this
+late day.</p>
+
+<p>In Scotland, by the ancient canons of the Scottish
+Councils, much more sacredness was attached to the
+plea of sanctuary, than obtained during this period of
+English history. Excommunication was there incurred
+for the offense of taking criminals from sanctuaries
+and depriving them of the protection of the church.
+Scottish kings granted charters recognizing broader
+privileges in certain churches than in others, and many
+particular ecclesiastical asylums were established in
+Scotland, by special charters.</p>
+
+<p>One of the most celebrated sanctuaries in Scotland
+was the church of Wedale, now called Stow, for in this
+church there was an image of the blessed Virgin, believed
+to have been brought by King Arthur, from
+Jerusalem. David I., of Scotland, granted the “king’s
+peace,” in addition to the church’s protection, to those
+refugees taking sanctuary at the church of Lesmahagow,
+and it was, for centuries, one of the most prominent
+sanctuaries of Scotland.</p>
+
+<p>One of the most remarkable features of the custom of
+sanctuary, obtaining in Scotland, was that of the <i>Clan
+Macduff</i>, alleged to have been granted by Malcolm
+Canmore, on recovering the throne of his ancestors.
+Any person related within the ninth degree to the Chief
+of the Clan Macduff, who committed manslaughter, was
+entitled, when he fled to Macduff’s cross, in Fife, to
+have his punishment remitted to a fine, or at least to
+be repledged and exempted from trial in any other
+jurisdiction, by the Earl of Fife. History records that
+this privilege of sanctuary, saved the life of Hugh de<span class="pagenum"><a id="Page_266"></a>[266]</span>
+Arbuthnot and his accomplices, from trial for the
+murder of John de Melvil of Glenbervie, in the year
+1421.</p>
+
+<p>The Scotch law of sanctuary was more guarded than
+the English, in the middle ages, in affording too easy
+an immunity for crime, but in this country, there existed
+in most recent times, a sanctuary for debtors in
+the abbey and palace of Holyrood, with its precincts,
+including the hill of Arthur’s Seat and the Queen’s
+Park.<a id="FNanchor_610" href="#Footnote_610" class="fnanchor">[46]</a></p>
+
+<p>The privilege of sanctuary, while it obtained in England
+and Scotland gave rise to considerable legislation
+and litigation, to restrain the right within the proper
+limits and to interpret the laws governing the privilege
+as it had previously been enjoyed.</p>
+
+<p>In 1378 it was ordained that debtors claiming sanctuary
+with the intent of defrauding their creditors
+should have their goods and lands levied upon to discharge
+their debts.<a id="FNanchor_611" href="#Footnote_611" class="fnanchor">[47]</a></p>
+
+<p>In 1487 Pope Innocent VIII. authorized the arrest of
+persons who left the sanctuary, to commit murder, robbery
+or other felony, though they sought the sanctuary,
+the second time, for protection and he ordered at the
+same time that those inmates of sanctuaries who were
+guilty of treason should be prevented from leaving the
+realm.<a id="FNanchor_612" href="#Footnote_612" class="fnanchor">[48]</a></p>
+
+<p><span class="pagenum"><a id="Page_267"></a>[267]</span></p>
+
+<p>Statutes of the time of Henry VIII. greatly curtailed
+the privilege of sanctuary. By act of Parliament,
+passed in the twenty-first year of his reign,<a id="FNanchor_613" href="#Footnote_613" class="fnanchor">[49]</a> it was
+provided that the culprit:</p>
+
+<div class="blockquote">
+
+<p>“Immediately after his confession, and before his abjuration,
+was to be branded by the coroner with a hot
+iron upon the brawn of the thumb of the right hand,
+with the sign of the letter A, to the intent he might be
+the better known among the king’s subjects to have
+abjured.”</p>
+
+</div>
+
+<p>It was found that the citizenship of the realm was
+becoming weakened by sanctuary men <i>abjuring the
+realm</i>, so Henry VIII., by statute provided,<a id="FNanchor_614" href="#Footnote_614" class="fnanchor">[50]</a> That</p>
+
+<div class="blockquote">
+
+<p class="noindent">“every person abjuring was to repair to some sanctuary
+within the reign which himself should choose, and
+there remain during his natural life; and to be sworn
+before the coroner upon his abjuration so to do. But
+if he went out of that sanctuary, unless discharged by
+the king’s pardon, and committed murder or felony, he
+was liable to be brought to trial for that offense, and
+was excluded from the right of sanctuary.”</p>
+
+</div>
+
+<p>In the twenty-sixth year of the reign of this monarch,
+sanctuary was taken away where the crime was treason,<a id="FNanchor_615" href="#Footnote_615" class="fnanchor">[51]</a>
+and in the thirty-second year of his reign it was
+enacted that “all sanctuary persons were to wear a
+badge or cognisance to be assigned and appointed by
+the governour of every sanctuary, openly upon their
+outer garment, of the compass, in length and breadth of
+ten inches under the pain of forfeiting the privilege of
+sanctuary.” They were also prevented from carrying
+knives or swords or other weapons and were not to<span class="pagenum"><a id="Page_268"></a>[268]</span>
+leave their lodging except between sunrise and sunset,
+and the right of sanctuary was also confined, by Henry
+VIII., to parish churches, churchyards, cathedrals, hospitals
+and college churches and all dedicated chapels.</p>
+
+<p>One of the first acts of James I., when he began to
+rule over England, was to further abridge the right of
+sanctuary and twenty years afterward in 1624, the
+same monarch finally abolished the right of sanctuary
+for all kinds of crime, in England.<a id="FNanchor_616" href="#Footnote_616" class="fnanchor">[52]</a></p>
+
+<p>Various precincts continued to afford shelter for
+criminals, in and about London, however, long after the
+enactment of this statute of James I., intended to finally
+abolish the practice and it was not until the later act
+of 1697 that the custom was finally abrogated for good,
+in England.<a id="FNanchor_617" href="#Footnote_617" class="fnanchor">[53]</a></p>
+
+<p>Both while the practice of sanctuary obtained and
+years after it passed away, however, the institution
+furnished a theme for popular authors to weave
+romances around and Shakespeare, Shadwell, Sir
+Walter Scott, and other writers, whose names commence
+with other letters of the alphabet, have found
+the ancient law of sanctuary, an attractive source of
+legal reference.</p>
+
+<p>In describing the argument before the Council, as to
+the right of Queen Elizabeth, the widow of Edward IV.
+and her son, to claim sanctuary, when they had committed
+no crimes and the son had done nothing to entitle
+him to sanctuary, Shakespeare makes Buckingham
+say, in Richard III.:</p>
+
+<p><span class="pagenum"><a id="Page_269"></a>[269]</span></p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Buck.</i> ... You break not sanctuary in seizing him.</div>
+ <div class="verse indent0">The benefit thereof is always granted</div>
+ <div class="verse indent0">To those whose dealings have deserv’d the place,</div>
+ <div class="verse indent0">And those who have the wit to claim the place;</div>
+ <div class="verse indent0">This prince hath neither claimed it, nor deserv’d it;</div>
+ <div class="verse indent0">And therefore, in mine opinion, cannot have it;</div>
+ <div class="verse indent0">Then, taking him from thence, that is not there,</div>
+ <div class="verse indent0">You break no privilege nor charter there.</div>
+ <div class="verse indent0">Oft have I heard of sanctuary men;</div>
+ <div class="verse indent0">But sanctuary children, ne’er till now.”<a id="FNanchor_618" href="#Footnote_618" class="fnanchor">[54]</a></div>
+ </div>
+</div>
+</div>
+
+<p>Cardinal Wolsey sought the benefit of sanctuary,
+after his disgrace, at the Abbey of Leicester, in King
+Henry VIII., in the following touching plea:<a id="FNanchor_619" href="#Footnote_619" class="fnanchor">[55]</a></p>
+
+<div class="blockquote">
+
+<p>“O father Abbot, an old man, broken with the storms of State,
+Is come to lay his weary bones among ye; Give him a little earth,
+for charity.”</p>
+
+</div>
+
+<p>The poor, desolate widow of Edward IV., after the
+death of her husband, whose plea of sanctuary we have
+already described, is thus made to reflect upon the protection
+in sanctuary, in 3’ Henry VI.:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Queen Elizab.</i> I’ll hence, forthwith, unto the sanctuary,</div>
+ <div class="verse indent0">To save at least the heir of Edward’s right.</div>
+ <div class="verse indent0">There shall I rest secure from force and fraud.”<a id="FNanchor_620" href="#Footnote_620" class="fnanchor">[56]</a></div>
+ </div>
+</div>
+</div>
+
+<p>And in Coriolanus, as if realizing that sanctuary was
+an institution that had out lived its usefulness, Shakespeare
+thus refers to it as a “rotten privilege”; when
+Aufidius is made to say:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“<i>Auf.</i> ... nor sleep nor sanctuary, being naked, sick; nor fane nor capital;</div>
+ <div class="verse indent0">The prayers of priests, nor times of sacrifice,</div>
+ <div class="verse indent0">Embarquements all of fury, shall lift up</div>
+ <div class="verse indent0">Their rotten privilege and custom ’gainst</div>
+ <div class="verse indent0">My hate to Marcius.”<a id="FNanchor_621" href="#Footnote_621" class="fnanchor">[57]</a></div>
+ </div>
+</div>
+</div>
+
+<p><span class="pagenum"><a id="Page_270"></a>[270]</span></p>
+
+<p>Already the trend of public thought was against the
+custom which afforded exemption to the criminal seeking
+refuge in the sacred places of the kingdom, and the
+ancient law of sanctuary, since the reign of Henry VII.
+had been gradually amended and so many different
+limitations were imposed upon the ancient privilege
+during the reign of Henry VIII., that the public were
+about ready for the final repeal of the law, by King
+James, so the gifted Shakespeare, ever alive to the
+popular views of his audiences, in referring to sanctuary,
+in Coriolanus, speaks of it as a “rotten privilege”
+that could not stay the hatred of Aufidius for Marcius.</p>
+
+<p>This old institution has passed away forever, in the
+ever flowing flood of time, carried away by the current
+of the centuries. The necessity for such a custom has
+long ceased to exist, but in the dim past, when the
+“avenger of blood” was abroad in the land and men,
+fed upon the delusions that were rampant, clamored,
+like wolves, for the life blood of the criminal, the old
+knockers on the sanctuary doors were most welcome
+sights to the fearful criminal, pursued by the howling
+mob. In our imagination we can see the cringing murderer,
+bent and fearful, as he hurries through the black
+browed night, followed by his blood-thirsty pursuers,
+like a hunted stag, fleeing for the blessed portals of the
+sacred places. What a sigh of relief he must have
+felt, when he reached the ancient altar of some of the
+old sanctuaries of the middle ages and with what exultation
+his heart must have throbbed, as he clung to
+the ancient “frith-stool” that for untold centuries had
+afforded protection to criminals from the vengeance of
+the pursuer.</p>
+
+<p><span class="pagenum"><a id="Page_271"></a>[271]</span></p>
+
+<p>This obsolete custom of the inhabitants of the lost
+world of the past had for its recommendation the charitable
+and philanthropic object of saving men from the
+many “crimes against criminals,” then obtaining.
+Many instances, no doubt, existed, where the practice
+was used to prevent the civil authorities from enforcing
+the law and it was used as an instrument whereby
+“crimes went unwhipt by justice.” But in the harsh
+days when the extremes, in that regard, prevailed, it
+is as well that Mercy was thus used to temper Justice,
+and, upon the beneficent theory that “it is better for
+a thousand guilty men to go free than for one innocent
+man to suffer,” it was an institution accompanied with
+most benevolent results.</p>
+
+<p>The hands of the officers of the law were held up
+when they came to the charmed portals of the sacred
+sanctuary. The old Mosaic law and the time honored
+charters of the Crown decreed it. And while the officer
+was thus thwarted and Justice cheated, the “boys of
+Westminster Knoll”; “the birds of St. Martin’s”; the
+“Bravoes of Alsatia” and “Freemen of the Borough,”
+flourished and lived. Many of them, perhaps, belonged
+to the large class of the “predestined lost” and if their
+inner lives had been scanned, there were no doubt
+mitigating circumstances why they happened to be as
+they were. It may have been decreed, from the beginning
+that they should be criminals, instead of honest men.
+However this may be, they contributed to the quota
+of the crime of the world and with the right and wrong
+then obtaining, have past away forever. Let us be
+thankful that as many of them as did successfully embrace
+the privileges of sanctuary were spared through<span class="pagenum"><a id="Page_272"></a>[272]</span>
+this merciful custom, for, in the end, it will make no
+difference whether this or that criminal suffered death
+just at this or that particular time, or a little later.
+He paid the penalty of the flesh certainly, without much
+delay and that he was allowed to consort with holy men,
+free from the war of the outside world, and feel the influence
+of their altruism for a time, and listen to the
+service of the sacred altar, with its superstitious chant,
+could but have had a softening and leavening influence
+upon his life.</p>
+
+<p>So while inconsistent with a proper administration of
+justice, which contemplates the visitation of equal
+punishment upon all alike, under similar conditions,
+for the same crimes, amid the rapine and murder of
+the middle ages it was often a shield for innocence, as
+well as a protection for crime and we can hardly regret
+that there was such an oasis in the desert, where
+the persecuted could find rest from the wild beasts of
+the desert domains—“wilder than wildest wolf or
+bear.” They all have gone, who suffered then—gone,
+“with the snows of yesterday”—the way the Mammoth
+went his way. So whether it was good or ill, since sanctuary
+gave to those who lived and suffered here below,
+“one little glimpse of Paradise, to ope the eyes and
+ears of men,” we would not have it otherwise.</p>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_565" href="#FNanchor_565" class="label">[1]</a> The six cities appointed in the book of Numbers were only for
+those who “killeth any person unawares.” (xxxv.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_566" href="#FNanchor_566" class="label">[2]</a> Chapter XIX. 4.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_567" href="#FNanchor_567" class="label">[3]</a> Joshua, XX. 4, 5.</p>
+
+<p>“These were the cities appointed for all the children of Israel,
+and for the avenger that sojourneth among them, that whomsoever
+killeth any person unawares, might flee thither, and not die by the
+hand of the avenger of blood, until he stood before the congregation.”
+<i>idem.</i> 9.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_568" href="#FNanchor_568" class="label">[4]</a> Chapter I., 50, 52.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_569" href="#FNanchor_569" class="label">[5]</a> Joshua, XX., 4, 5.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_570" href="#FNanchor_570" class="label">[6]</a> I. Kings, 1, 50, 51.</p>
+
+<p>Nimrod, on the death of his eldest son, erected a golden statue
+of him in his palace and ordained that all criminals fleeing thither
+should be protected and this was a species of sanctuary. The
+Green Bag, vol. VIII., 1896, p. 422.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_571" href="#FNanchor_571" class="label">[7]</a> Chambers Journal, vol. 44, Jan.-June, 1867, p. 170.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_572" href="#FNanchor_572" class="label">[8]</a> The Green Bag, vol. 8, 1896, p. 423.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_573" href="#FNanchor_573" class="label">[9]</a> Chambers Journal, vol. 64, p. 513.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_574" href="#FNanchor_574" class="label">[10]</a> Plutarch, Dr. Pegge; Green Bag, vol. 8, 1896, p. 423.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_575" href="#FNanchor_575" class="label">[11]</a> Chambers Journal, vol. 64, p. 513. Papal sanction was expressly
+given in the year 620. <i>ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_576" href="#FNanchor_576" class="label">[12]</a> Chambers Journal, Vol. 64, August, 1887, p. 512.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_577" href="#FNanchor_577" class="label">[13]</a> Chambers Journal, Vol. 44, June, 1867, p. 170.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_578" href="#FNanchor_578" class="label">[14]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_579" href="#FNanchor_579" class="label">[15]</a> I. Reeve’s History English Law, p. 198.</p>
+
+<p>Reeves shows that at this early day the <i>pax ecclesiae</i> was more
+sacred, before the law, than the <i>pax regis</i>, <i>ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_580" href="#FNanchor_580" class="label">[16]</a> Reville, L’Abjuratio regni, Revue historique, vol. 50, p. 1; M.
+Reville contends that the law of abjuration is purely an English
+institution and was adopted by the Normans, from the early Anglo-Saxons.
+See Pl. Cr. pi. 48, 49, 89; Britton, i, 63; Leg. Edw. Conf.
+c, 5.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_581" href="#FNanchor_581" class="label">[17]</a> II. Pollock and Maitland’s History English Law, p. 590.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_582" href="#FNanchor_582" class="label">[18]</a> <i>Ante idem.</i></p>
+
+<p>Speaking of the practice known as <i>adjuration of the realm</i>,
+Pollock and Maitland, in their excellent history of English Law,
+say: “The coroner came and parleyed with the refugee, who had
+his choice between submitting to trial and abjuring the realm.
+If he chose the latter course, he hurried, dressed in pilgrim’s guise,
+to the port that was assigned to him, and left England, being bound
+by his oath, never to return. His lands escheated; his chattels
+were forfeited, and if he ever came back, his fate was that of an
+outlaw.” (Vol. II., p. 590.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_583" href="#FNanchor_583" class="label">[19]</a> I. Pollock and Maitland’s History English Law, pp. 565, 566;
+R. H. 1, 308; Maddox, Hist. Exch. i, 541, 568.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_584" href="#FNanchor_584" class="label">[20]</a> Chamber’s Journal, Vol. 64, 1887, p. 513; Green Bag, vol. 8, p. 423.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_585" href="#FNanchor_585" class="label">[21]</a> <i>Ante idem.</i> I. Reeve’s History English Law, p. 198.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_586" href="#FNanchor_586" class="label">[22]</a> Mirror of Justice, c. 5.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_587" href="#FNanchor_587" class="label">[23]</a> I. Reeve’s History English Law, pp. 198, 199, note, Finlason’s
+edition.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_588" href="#FNanchor_588" class="label">[24]</a> This term is composed of the words “frith” and “stol,” meaning
+“the seat of peace.” It was a heavy stone chair, or seat and that
+at Beverly was devoid of decoration, but perfectly plain, in every
+particular. It has been broken and repaired with clamps of iron
+and we are informed that it formerly bore a Latin inscription, which
+stated that: “This stone chair is called Fridstool—that is, the Chair
+of Peace, to which what criminal soever flies to it hath full protection.”
+Chamber’s Journal, Vol. 64, 1887, p. 513.</p>
+
+<p>Littell’s Living Age, of July-Sept., 1907, Vol. 254, p. 700, produces
+a transcript of the register at Beverley, when one John Spret was
+entered as a sanctuary criminal, as follows: “John Spret, gentleman.
+Memorandum. That John Spret, of Barton, upon Umber, in the
+counte of Lyncoln, com to Beverlay, the first day of October, the
+vii year of the reen of Keing Henry the VII., and asked the lybertes
+of Saint John of Beverlay, for the death of John Welton, husbondman
+of the same town, and knawlig hymself to be at the kylling of
+the same John with a degart, the 15’ day of August.” And thus,
+this tragedy, which resulted in the death of husbandman John
+Welton, at the point of a dagger, in the hand of Mr. John Spret,
+has caused both of these gentlemen to be known in history after
+a period of many centuries, and this sad circumstance of their
+lives is quoted long centuries later, to illustrate the manner of an
+obsolete custom.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_589" href="#FNanchor_589" class="label">[25]</a> Chamber’s Journal, Vol. 64, p. 514.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_590" href="#FNanchor_590" class="label">[26]</a> Violators of the first and second boundary were punished by
+a fine of eight pounds; the third space by double that sum; and
+so on, but if a person penetrated into the charmed circle of the
+altar, no fine could save him, but he was regarded as a “botelas”
+man. <i>ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_591" href="#FNanchor_591" class="label">[27]</a> Chamber’s Journal, 1867, Vol. 44, p. 171.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_592" href="#FNanchor_592" class="label">[28]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_593" href="#FNanchor_593" class="label">[29]</a> Chamber’s Journal, Vol. 44, p. 171.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_594" href="#FNanchor_594" class="label">[30]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_595" href="#FNanchor_595" class="label">[31]</a> III. Reeve’s History English Law, p. 331.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_596" href="#FNanchor_596" class="label">[32]</a> 29 Ass. 34; II. Reeve’s History English Law, p. 81; Chamber’s
+Journal, Vol. 44, p. 171.</p>
+
+<p>Reeve says, speaking of the sanctuary at Westminster: “The
+resort of felons to this place, being in the metropolis of the kingdom,
+must have been very great and productive of great disorders.”
+<i>ante idem.</i></p>
+
+<p>The sanctuaries to which special charters had been granted,
+were known during the period of Henry VII., as private sanctuaries,
+while those that had not received special charters were called
+general sanctuaries and in distinguishing the two, a historian of
+that period has said:</p>
+
+<p>“If a man fled to such a sanctuary as Westminster Knoll, he
+might remain undisturbed for life; but if he chose to abjure within
+the forty days, the coroner was to appoint him a day to do it.
+The law of sanctuary is laid down in a reading of this period in
+the following manner: None shall take sanctuary but <i>in periculo
+vitae</i>, as for treason, felony, or the like and not for debt; for a grant
+or prescription to have sanctuary for debt was against law and void.
+But the reading lays down a strange quibble to evade this; for it
+admits, that if a man’s body was in execution, and he escaped, and
+came to a sanctuary, ordained as a refuge, and safeguard for a man’s
+life, he should have benefit thereof, <i>because by long imprisonment his
+life might be in jeopardy</i>. If a church was suspended for bloodshed,
+he who took it for sanctuary should still enjoy it for forty days and
+abjuration for felony, discharged all felonies done before the abjuration.
+A man could not abjure for petit larceny, however, but
+only for such felonies as induced the pain of death.” IV. Reeve’s
+History English Law, p. 255.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_597" href="#FNanchor_597" class="label">[33]</a> 3’ Henry VII., 12; IV. Reeve’s History English Law, 253.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_598" href="#FNanchor_598" class="label">[34]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_599" href="#FNanchor_599" class="label">[35]</a> Preface of Rev. James Raine’s to the Fifth Volume of the
+Surtees Society, gives the following description of the manner of
+claiming sanctuary at Beverley and Durham:</p>
+
+<p>“Persons who took refuge fled to the north door and knocked for
+admission.... As soon as anyone was so admitted the galilee
+bell was immediately tolled, to give notice that some one had taken
+sanctuary. The offender was required, before the shrine of the
+patron saint, and certain credible witnesses, to tell the nature of his
+offense, and to toll a bell, in token of his demanding the privilege
+of sanctuary.... Everyone who had the privilege of sanctuary
+was provided with a black gown and a yellow cross, called St. Cuthbert’s
+Cross, upon the left shoulder.... If one’s life was saved
+the third time, by the privilege of sanctuary, he became permanently
+a servant of the church.” Chamber’s Journal, Vol. 64, p. 514.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_600" href="#FNanchor_600" class="label">[36]</a> This is the oath administered by the Archbishop of York, at
+Beverley, as same is preserved in the register, according to the
+Harleian Manuscript: “Ye shal be trew and feythful to my Lord
+Archbishop of York, lord of this towne; to the Provost of the same;
+to the Chanons of this chirch, and all other ministers thereof.
+Also, ye shal here gude hert to the Baillie and Governors of this
+towne, to al burges and comyners of the same. Also, ye shal bere
+no poynted wapen, dagger, knyfe, nor no other wapen agenst the
+kyng’s pece. And ye shal be redy at all your power if there be any
+debate or stryf, or oder sotham case of fyre within the towne, to
+help to surcess it.... So help you God, and this holy Evangelistes.”
+Chamber’s Journal, Vol. 64, p. 514.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_601" href="#FNanchor_601" class="label">[37]</a> As reproduced, in Chamber’s Journal (Vol. 64, p. 514), this
+oath is as follows: “This hear thou, Sir Coroner, that I M of H.
+am a robber of sheep or of any other beast, or a murderer of one or
+mo, and a felon of our lord, the king of England; and because I
+have done many such evils or robberies, in his land, I abjure the
+land of our lord the king of England and I shall haste me toward
+the port of such a place which thou hast given me; and that I
+shall not go out of the highway; and if I do, I will that I be taken
+as a robber and a felon, of our lord the king; and that at such a
+place I will diligently seek for passage and that I will not tarry
+there but one flood and ebb, if I can have passage; and unless I can
+have it at such a place, I will go every day into the sea up to
+my knees, assaying to pass over; and unless I can do this within
+forty days, I will put myself again into the church as a robber and
+a felon of our lord the king; so God help me and his holy judgment.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_602" href="#FNanchor_602" class="label">[38]</a> Chamber’s Journal, Vol. 64, p. 515.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_603" href="#FNanchor_603" class="label">[39]</a> The Green Bag, Vol. 8, p. 425. He was buried as a martyr, in
+the south transept of this abbey and was followed by Chaucer, a
+few years later, who was buried at his feet. <i>ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_604" href="#FNanchor_604" class="label">[40]</a> Littell’s Living Age, Vol. 254, July-Sept., 1907, 701.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_605" href="#FNanchor_605" class="label">[41]</a> Richard III., Act V., Scene III.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_606" href="#FNanchor_606" class="label">[42]</a> Chamber’s Journal, Vol. 44, p. 171.</p>
+
+<p>The debate at the Council Board, over the right to take refugees
+from the sanctuary, occasioned by Queen Elizabeth’s refuge to
+Westminster, is not without interest, in showing the views then
+obtaining on this custom. It was contended that no right of sanctuary
+existed, since no crime had been committed, as the right was
+only extended to criminals, in fear of their lives; that the little
+son had no right to sanctuary at all and that it was a flagrant abuse
+of the privilege for the Queen to claim it. Those who advocated
+roughly taking them away, were overcome by the mild persuasion
+urged by the Archbishop of York, who counseled that the child be
+obtained without force, if possible. See, Chamber’s Journal, Vol.
+44, p. 171, Speed; Sir Thomas More.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_607" href="#FNanchor_607" class="label">[43]</a> Year Book, I. Henry VII., fol. 24; IV. Reeve’s History English
+Law, p. 253.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_608" href="#FNanchor_608" class="label">[44]</a> IV. Reeve’s History English Law, p. 254, Finlason’s note.</p>
+
+<p>This is one of the many instances of the struggle going on for
+centuries between the civil authority, in its attempt to narrow the
+right of sanctuary and the church, to enlarge or preserve it.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_609" href="#FNanchor_609" class="label">[45]</a> 21 Henry VII., Keilway, 70; IV. Reeve’s History English Law,
+Finlason’s note, p. 254.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_610" href="#FNanchor_610" class="label">[46]</a> Chamber’s Journal, Vol. 44, p. 170, 171; <i>idem.</i>, Vol. 64, 515.</p>
+
+<p>Imprisonment for debt was abolished in Scotland, in 1880, and
+while the privilege still exists in form, at the places noted, in fact
+it has ceased to be a necessary legal exemption, since the repeal
+of this law.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_611" href="#FNanchor_611" class="label">[47]</a> Chamber’s Journal, Vol. 64, p. 515.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_612" href="#FNanchor_612" class="label">[48]</a> This bull was confirmed by Alexander VI., and Julius II., in
+1493, and 1504. <i>ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_613" href="#FNanchor_613" class="label">[49]</a> 21 Henry VIII., c. 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_614" href="#FNanchor_614" class="label">[50]</a> 64 Chamber’s Journal, p. 515.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_615" href="#FNanchor_615" class="label">[51]</a> 26 Henry VIII.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_616" href="#FNanchor_616" class="label">[52]</a> 21 James I., c. 28.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_617" href="#FNanchor_617" class="label">[53]</a> 8 &amp; 9 William IV., c. 26.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_618" href="#FNanchor_618" class="label">[54]</a> Richard III., Act III., Scene I. For discussion of this and
+other references in Shakespeare, to the Law of Sanctuary, see
+White’s “Law in Shakespeare,” Sec. 324, p. 354.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_619" href="#FNanchor_619" class="label">[55]</a> Act IV., Scene I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_620" href="#FNanchor_620" class="label">[56]</a> 3’ Henry VI., Act IV., Scene IV.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_621" href="#FNanchor_621" class="label">[57]</a> Act I., Scene X.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_273"></a>[273]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_X">CHAPTER X.<br>
+<span class="smcap">Ancient Punishments.</span></h2>
+
+</div>
+
+<p>In the broader sense, punishment includes any pain
+or detriment suffered in consequence of wrong-doing,
+but as treated of in this chapter, it means the pain or
+other penalty imposed by an authority to which the
+offender is subject, for a crime or offense committed.</p>
+
+<p>The term punishment is properly restricted to the
+penalties imposed by competent authority, for violations
+of law; but as the subject of the following pages
+will bear evidence, it has been frequently imposed upon
+the weak and the innocent, as well as upon the guilty,
+and instead of being always confined to the authority
+acting only in pursuance of the fixed rules of law, it
+has too often resulted from the arbitrary will of someone
+in superior authority.</p>
+
+<p>“Man’s inhumanity to man” seems ever to have
+been a peculiar trait of the species and human cruelty
+exceeds that of all other animals, in the same proportion
+that man excels the lower species. In following
+the bent of his cruel impulses, man has never rect’ with
+good or ill, but like a ravenous beast of prey, far
+fiercer “than the wolf or bear, he slays his kind in
+cruel glee and sorrows he can slay no more.”</p>
+
+<p>When we read the history of the punishments of antiquity,
+we can but wonder that the people suffered so
+long and so continuously as a result of laws which had
+for their foundation the passions or wickedness of only
+a small per cent of the people, instead of the beneficent<span class="pagenum"><a id="Page_274"></a>[274]</span>
+rules of conduct formulated by the “cool examiner of
+human nature,” familiar with the actions of the multitude
+and prompted by altruistic motives, to legislate
+for the greatest happiness of the greater number.</p>
+
+<p>Every just punishment should be limited to the necessity
+of defending and preserving the liberty of the
+masses of society from the usurpations and wrongs of
+individuals, hence, every punishment which does not
+arise from such necessity is tyranny.<a id="FNanchor_622" href="#Footnote_622" class="fnanchor">[1]</a></p>
+
+<p>Since the time of Beccaria men have realized that the
+groans of a tortured wretch cannot recall the time past,
+or reverse the crime once committed,<a id="FNanchor_623" href="#Footnote_623" class="fnanchor">[2]</a> so punishments
+are now provided for, not to torment a sensible being,
+nor to attempt to undo the crime committed, but to prevent
+the criminal from doing further injury to society<span class="pagenum"><a id="Page_275"></a>[275]</span>
+and to deter others from committing similar offenses.
+But it was not always thus. Torture, of the worst kind,
+in the handling of criminals, has been consecrated as a
+time honored custom by most of the older nations of
+the world. Mankind, for centuries, seemed to forget
+that all men were brothers; that a man, after he is dead
+is good for nothing and since punishments were invented
+for the good of society, that they ought to be
+useful and not destructive, still they universally persecuted
+each other, even to the death.</p>
+
+<p>All mankind have ever detested the violence of which
+they may themselves possibly be the victim, but the
+criminal is so far regarded as an enemy to society, that
+they universally desire the punishment inflicted upon
+another which they would never want inflicted upon
+themselves. Viewing all other men as inconsequential
+in the sum total of the universe, but each individual
+believing himself the center of the social unit, men
+have been ever ready to play the tiger and make the
+alleged criminal the lamb, because it was the other
+individual whose life was sacrificed.</p>
+
+<p>Viewing the whole plan of society by the standards
+of the past, in the punishment of criminals, it is difficulty
+to determine whether the crimes against society
+or those of society against the alleged criminal, have
+been the greater. But with the idea of reforming the
+criminal, the barbarous tortures of the past have been
+eliminated and the trend of modern criminologists is
+to further limit all punishments, not in themselves
+wholly reformatory in their nature.</p>
+
+<p>Excessive punishments have always increased, rather
+than diminished crime, yet authority to inflict punishment<span class="pagenum"><a id="Page_276"></a>[276]</span>
+has never been much concerned about the welfare
+of the race or of society, as a whole, and the humane
+law of the philosophers has been disregarded far too
+long to curb the ingenious cruelty that has inflicted
+penalties and pains upon alleged criminals, frequently
+wholly innocent of any crime.</p>
+
+<p>The object of this chapter, however, is not to moralize
+about crimes and punishments, but to contribute
+something to the vast fund of historical information
+upon the subject of ancient punishments, with a few
+illustrations of the pains and penalties inflicted during
+the past ages, in the name of law, upon the unfortunate
+victims falling into the vortex of the current of a past
+civilization and hopelessly borne on to their destruction.</p>
+
+<p><i>Capital punishment, by beheading</i> was not practiced
+by the ancient Israelites, but was a custom of the Egyptians,
+Assyrians, Persians, Greeks and Romans,<a id="FNanchor_624" href="#Footnote_624" class="fnanchor">[3]</a> and
+the French. We find that the “chief baker,” who incurred
+Pharoah’s ill-will, was accordingly decapitated;<a id="FNanchor_625" href="#Footnote_625" class="fnanchor">[4]</a>
+John the Baptist lost his head on the order of
+Herod;<a id="FNanchor_626" href="#Footnote_626" class="fnanchor">[5]</a> James the Apostle suffered a similar fate,<a id="FNanchor_627" href="#Footnote_627" class="fnanchor">[6]</a>
+and many other of the early martyrs were beheaded.<a id="FNanchor_628" href="#Footnote_628" class="fnanchor">[7]</a></p>
+
+<p><i>Burning</i> to death was of pre-Mosaic authority, for
+we find that when it was reported to Judah that his
+daughter-in-law Tamar, was with child and had played
+the harlot, Judah said, “Bring her forth and let her be<span class="pagenum"><a id="Page_277"></a>[277]</span>
+burnt.”<a id="FNanchor_629" href="#Footnote_629" class="fnanchor">[8]</a> This was the punishment inflicted upon a
+priest’s daughter, under the Sinaitic law, for fornication,<a id="FNanchor_630" href="#Footnote_630" class="fnanchor">[9]</a>
+and was also the form of punishment for incest
+with a wife’s mother.<a id="FNanchor_631" href="#Footnote_631" class="fnanchor">[10]</a></p>
+
+<p><i>Drowning</i> was a form of capital punishment in vogue
+among the ancient Babylonians, the Jews and the Romans
+and more recently among the French, English
+and Americans, during the witch craze in the seventeenth
+century.<a id="FNanchor_632" href="#Footnote_632" class="fnanchor">[11]</a></p>
+
+<p>Even before the witch craze, in England, in which
+death by burning and drowning was the usual mode of
+ending the lives of the poor unfortunates, accused of
+this hated and unprovable crime, there were precedents
+for the use of drowning, as a punishment, in that
+country.</p>
+
+<p><span class="pagenum"><a id="Page_278"></a>[278]</span></p>
+
+<p>During the reign of Edward II. felons were put to
+death by drowning, for we find that in the sixth year
+of the reign of that monarch, the jury for the hundred
+of Cornylo, in Kent, exhibited a presentment to Hervi
+de Stanton, and his associate justices itinerant, sitting
+at Canterbury, in the Octaves of St. John the Baptist,
+importing, that the Prior of the Christ-church in Canterbury,
+did, about eleven years then past, divert the
+course of a certain stream, called Cestling, in which
+such felons as were condemned, to death, within the
+before-mentioned hundred, ought to suffer judgment
+by drowning.<a id="FNanchor_633" href="#Footnote_633" class="fnanchor">[12]</a></p>
+
+<p>Drowning was regarded as an especially appropriate
+punishment for women in Scotland, at an early day and
+according to Dr. Hill Burton, in 1624, eleven gipsy
+women were sentenced to be drowned in the North
+Loch, of Edinburgh, in the hollow where the Princess
+street Garden is now located.<a id="FNanchor_634" href="#Footnote_634" class="fnanchor">[13]</a></p>
+
+<p>In 1685 two women, Margaret M’Lauchlan, a widow,
+and Margaret Wilson, a young girl, of eighteen, were
+drowned at Wigtownshire, for their religious belief.
+They were bound to stakes where the swift tide of the
+Solway overflows twice a day. After a partial unconsciousness,
+the young girl was revived and was urged
+by her friends to say “God save the King.” She refused
+and as the waters closed over her for the last
+time, she gasped: “I am Christ’s.” And thus she
+gained a place in history, as a martyr to her belief,
+and her young life was forfeited as a penalty for having<span class="pagenum"><a id="Page_279"></a>[279]</span>
+incurred the religious and political bigotry of a
+despotic monarch.<a id="FNanchor_635" href="#Footnote_635" class="fnanchor">[14]</a></p>
+
+<p><i>Exposure to wild beasts</i>, was a common punishment
+of the Israelites, and Romans, for wickedness or unfaithfulness.
+Darius caused Daniel to be brought and
+cast into the den of lions,<a id="FNanchor_636" href="#Footnote_636" class="fnanchor">[15]</a> for this was the law of the
+Persians, and the King had entered a decree that it
+should be so, and another ancient authority,<a id="FNanchor_637" href="#Footnote_637" class="fnanchor">[16]</a> advises
+us that a disobedient prophet, named Jadon, met death
+from God, by being cast before the lions.</p>
+
+<p><i>Hanging</i> is one of the forms of capital punishment
+that has survived for thousands of years, for we find
+that it was in general use among the ancient patriarchs,<a id="FNanchor_638" href="#Footnote_638" class="fnanchor">[17]</a>
+the Persians<a id="FNanchor_639" href="#Footnote_639" class="fnanchor">[18]</a> and the Greeks<a id="FNanchor_640" href="#Footnote_640" class="fnanchor">[19]</a> and has continued
+as a mode of capital punishment ever since, in
+other civilized, or rated civilized, countries.<a id="FNanchor_641" href="#Footnote_641" class="fnanchor">[20]</a></p>
+
+<p><i>Precipitation, sawing asunder, slaying by spear or
+sword, stoning to death, strangling and suffocation</i>,
+were all different modes of inflicting the death penalty,
+practiced among the ancient Israelites and other ancient
+peoples, from the earliest time.</p>
+
+<p>The children of Judah cast 10,000 Edomites from a
+rock to their death, according to the second book of
+Chronicles;<a id="FNanchor_642" href="#Footnote_642" class="fnanchor">[21]</a> even the valiant David, painful to relate,
+when he took the cities of the children of Ammon,<span class="pagenum"><a id="Page_280"></a>[280]</span>
+brought forth all the people and “cut them with saws,
+and with harrows of iron, and with axes”;<a id="FNanchor_643" href="#Footnote_643" class="fnanchor">[22]</a> the spear,
+javelin or dart, was to be used on trespassers, at the
+foot of Sinai;<a id="FNanchor_644" href="#Footnote_644" class="fnanchor">[23]</a> the sword was taken by the Levites
+against the worshipers of the golden-calf;<a id="FNanchor_645" href="#Footnote_645" class="fnanchor">[24]</a> Samuel
+hewed Agag to pieces with the sword;<a id="FNanchor_646" href="#Footnote_646" class="fnanchor">[25]</a> stoning to
+death was the penalty for adultery, blasphemy, idolatry,
+for false prophesy and Sabbath breaking;<a id="FNanchor_647" href="#Footnote_647" class="fnanchor">[26]</a> strangling
+was the proposed punishment for the Syrians, before
+Israel<a id="FNanchor_648" href="#Footnote_648" class="fnanchor">[27]</a> and suffocation was used both by the ancient
+Jews and the Macedonians.<a id="FNanchor_649" href="#Footnote_649" class="fnanchor">[28]</a></p>
+
+<p><i>Crucifixion</i>, was a refined mode of punishment used
+by the Jews and Romans, in the time of the Saviour.
+It was borrowed by the Romans and Grecians from the
+Phoenicians, Persians, Egyptians and Numidians,
+among whom it was in general vogue. Alexander is
+reported to have crucified two thousand Tyrians at one
+time, and the same number of rioters were crucified
+by Varos at one time, after the death of Herod.<a id="FNanchor_650" href="#Footnote_650" class="fnanchor">[29]</a></p>
+
+<p>Under Claudius and Nero, various Roman governors
+crucified large numbers of robbers, thieves, and
+political and religious criminals.<a id="FNanchor_651" href="#Footnote_651" class="fnanchor">[30]</a></p>
+
+<p><span class="pagenum"><a id="Page_281"></a>[281]</span></p>
+
+<p>The method of crucifixion is accurately described in
+the New Testament.<a id="FNanchor_652" href="#Footnote_652" class="fnanchor">[31]</a></p>
+
+<p>After conviction, the victim was scourged with the
+<i>flagellum</i>, which was such a severe punishment that the
+afflicted one frequently died before the crucifixion occurred.
+In Jesus’ case, the scourging seems to have
+taken place before the crucifixion, as was the custom.</p>
+
+<p>The cross-bar was bound upon the back of the victim,
+or his head was placed in the <i>patibulum</i>, and he was
+then led through the city, accompanied by the centurions
+and soldiers having his execution in hand,
+amid the gibes and insults of the cruel crowd. The
+title, a piece of wood, covered with white gipsum,
+labeled with the crime for which he was to suffer, in
+letters of black, was usually carried before the condemned
+person, so that the curious might be advised
+of the cause of his death.</p>
+
+<p>At the place of crucifixion, the prisoner was stripped
+and his clothes given to the soldiers; he was then
+bound to the <i>patibulum</i> and thus raised on ladders,
+until the notch was reached in the upright piece, to
+receive it, or the cross-piece was fastened to the upright
+post upon the ground and then raised into an
+upright position, with the afflicted one bound to the
+cross, with his hands nailed to the ends, there to suffer
+the slow agonies of a lingering death, which might last
+for hours or perhaps for days.</p>
+
+<p>The shame of this torture to which the Saviour was
+subjected has become not only the symbol of salvation,
+but the true type of that absolute renunciation of the
+world which characterizes the true Christian, for did<span class="pagenum"><a id="Page_282"></a>[282]</span>
+not Christ Himself say: “If any man would come after
+me, let him deny himself, and take up his cross and
+follow me”?<a id="FNanchor_653" href="#Footnote_653" class="fnanchor">[32]</a></p>
+
+<p><i>Burying alive</i>, was a form of capital punishment
+applied in Rome as a punishment to the vestal virgins,
+violating their oaths of chastity and it was also in
+vogue in France during the middle ages.</p>
+
+<p>According to the law of Numa, the unchaste Vestal
+was simply stoned to death,<a id="FNanchor_654" href="#Footnote_654" class="fnanchor">[33]</a> but the cruel torture of
+burying her alive was devised by Tarquinius Priscus
+and inflicted from his time forward.<a id="FNanchor_655" href="#Footnote_655" class="fnanchor">[34]</a></p>
+
+<p>On her conviction, the poor creature was stripped
+of her <i>vittae</i> and other indicia of office and after being
+scourged, was attired like a corpse and placed in a
+closed litter, and then borne through the Forum, attended
+by her weeping relatives and friends, with all
+the ceremonies of a real funeral, to the <i>Campus Sceleratus</i>,
+within the walls of the city, near the Colline gate.
+The vault, underground, was furnished with a couch,
+a lamp, and a table, with a little food. The pontifex
+maximus offered up a prayer to Heaven for the culprit
+and having thus performed his sacred office, delivered
+her to the executioner, who led her down into the subterranean
+cell and drew up the ladder and filled the pit<span class="pagenum"><a id="Page_283"></a>[283]</span>
+with earth even with the ground,<a id="FNanchor_656" href="#Footnote_656" class="fnanchor">[35]</a> thus forever consigning
+to mother earth the body of her wayward
+daughter, who, in pursuance of her God-given instincts,
+had violated the unnatural law of the barbarous pagan
+days of ancient Rome.</p>
+
+<p>The gallant French gentlemen also reserved this
+horrible punishment for women and we read that during
+the year 1302 by order of the Bailli of Sainte-Genevieve,
+a woman was buried alive for some petty thefts
+which she had committed.<a id="FNanchor_657" href="#Footnote_657" class="fnanchor">[36]</a> Philip Augustus is said
+to have put a French provost to death in this cruel
+fashion, because of the crime of perjury, regarding
+a transaction in connection with a vineyard<a id="FNanchor_658" href="#Footnote_658" class="fnanchor">[37]</a> and in
+the thirteenth century in Bigorre, this punishment was
+inflicted for murder, the murdered and his murderer
+being interred in the same grave.<a id="FNanchor_659" href="#Footnote_659" class="fnanchor">[38]</a> One performing
+the unnatural crime was also buried alive, in England,
+at an early day, according to Fleta.<a id="FNanchor_660" href="#Footnote_660" class="fnanchor">[39]</a></p>
+
+<p><i>Drawing and quartering</i>, is of Egyptian and Roman
+origin, for we find that it existed at Rome five hundred
+years before Christ and is mentioned in the Twelve
+Tables.<a id="FNanchor_661" href="#Footnote_661" class="fnanchor">[40]</a></p>
+
+<p>Hanging, drawing and quartering is said to have
+been first introduced in England in the case of William<span class="pagenum"><a id="Page_284"></a>[284]</span>
+Maurice, a pirate, in 1241,<a id="FNanchor_662" href="#Footnote_662" class="fnanchor">[41]</a> although it afterwards became
+quite common, as a punishment for treason.</p>
+
+<p>According to the terms of a sentence imposed by
+Lord Ellenborough, the criminal convicted of treason
+to be thus punished was addressed as follows: “You
+are to be drawn on hurdles to the place of execution,
+where you are to be hanged, but not until you are dead;
+for, while still living, your body is to be taken down,
+your bowels torn out and burnt before your face;
+your head is then to be cut off and your body divided
+into four quarters.”<a id="FNanchor_663" href="#Footnote_663" class="fnanchor">[42]</a></p>
+
+<p>Hugh Spenser, the favorite of King Edward II., was
+put to death at Bristol, in 1326, and his body was quartered,
+as was the custom of the period, in similar cases,
+and his head was sent to London, while each quarter
+of his body was sent to each of the four principal towns
+of the kingdom.<a id="FNanchor_664" href="#Footnote_664" class="fnanchor">[43]</a></p>
+
+<p>On the execution of the Jesuit, Garnet, in England,
+in 1606, James I., who was more compassionate in this
+case than he was in the cases of witchcraft, where no
+punishment could be found too severe, gave orders
+that he should not be cut down until he was dead, so
+that he might be spared the tortures of drawing and
+quartering.<a id="FNanchor_665" href="#Footnote_665" class="fnanchor">[44]</a> But no such mercy was shown to Guy
+Fawkes, who was tortured and drawn and quartered,
+the same year, after he was taken with the burning
+match in his hand, in his attempt to blow up the king
+and his parliament, in what was known as the gunpowder
+plot.<a id="FNanchor_666" href="#Footnote_666" class="fnanchor">[45]</a></p>
+
+<p><span class="pagenum"><a id="Page_285"></a>[285]</span></p>
+
+<p>During the thirteenth century, in England, the usual
+punishment for petty treason was hanging and drawing
+for a man and burning for a woman.<a id="FNanchor_667" href="#Footnote_667" class="fnanchor">[46]</a></p>
+
+<p><i>Boiling in oil</i> during the reign of Henry VIII.,<a id="FNanchor_668" href="#Footnote_668" class="fnanchor">[47]</a> was
+a punishment provided for poisoners.</p>
+
+<p>Under the reign of this monarch, the power of the
+Crown was extended to cover powers not before recognized
+and while it is difficult to concede how citizens
+reared under the broad influence of the common law,
+could be brought to consent to such unusual and cruel
+punishment for any crime, the inhuman crime which
+brought about this harsh statute was such as to call
+for unusual handling, if not for such barbarous punishment
+as this act provided.</p>
+
+<p>One Richard Roose had placed poison in a vessel
+of yeast in the Bishop of Rochester’s kitchen and as
+a result of eating bread in which this yeast was used,
+seventeen persons in the family of the Bishop and
+others of his friends were poisoned. The enormity of
+the crime caused wide-spread indignation and such
+crimes were made treason and the offender subject
+to attainder. Roose was ordered to be boiled to death
+and in order to deter others similarly situated from
+perpetrating such a cruel crime, it was also provided
+by the act that henceforth, every wilful murder by
+poisoning, should be high treason and that all such
+offenders should be boiled to death.<a id="FNanchor_669" href="#Footnote_669" class="fnanchor">[48]</a></p>
+
+<p>Shakespeare makes the indignant Paulina, refer to
+this statute, in her reproachful speech to the Lords,<span class="pagenum"><a id="Page_286"></a>[286]</span>
+after the good Hermione’s incarceration, in Winter’s
+Tale, when she asks:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“What studied torments, tyrant, hast for me?</div>
+ <div class="verse indent0">What wheels? racks? fires? what flaying? boiling</div>
+ <div class="verse indent0">In leads or oils? What old or new torture</div>
+ <div class="verse indent0">Must I receive, whose every word deserves</div>
+ <div class="verse indent0">To taste of thy most worst?”<a id="FNanchor_670" href="#Footnote_670" class="fnanchor">[49]</a></div>
+ </div>
+</div>
+</div>
+
+<p>Margaret Davy, a young woman, convicted of murder
+by poisoning was also boiled to death, as provided
+by this statute, in 1542,<a id="FNanchor_671" href="#Footnote_671" class="fnanchor">[50]</a> but this was the last victim
+to suffer such inhuman punishment and the act was
+soon afterward repealed.</p>
+
+<p>The misguided efforts of the Church of Rome to
+punish heresy by use of the <i>Inquisition</i>, brought about
+untold suffering and misery in the world.</p>
+
+<p><i>The Inquisition</i>, was a tribunal of the Roman Catholic
+Church, for the discovery, repression, and punishment
+of heresy, unbelief and other offenses against
+religion. The emperors, Theodosius and Justinian, appointed
+officials known as Inquisitors, to look out and
+punish such offenders. They proceeded however in the
+name of the Emperors, in the secular courts, and no
+regular tribunal for the handling of this kind of alleged
+criminals, existed until the year 1248, after the
+fourth Lateran Council, held in the reign of Innocent
+III., when Innocent IV., established a permanent court
+for the prosecution and punishment of this class of
+offenders.</p>
+
+<p><span class="pagenum"><a id="Page_287"></a>[287]</span></p>
+
+<p>The prosecutions under this constitution were purely
+in the ecclesiastical courts, and for the next century,
+in France, Italy, Spain and Germany, the Pope, by
+appeal, regulated the severity of the punishments inflicted
+by the local authorities and the punishments
+were not so severe as they afterwards became.</p>
+
+<p>In Spain, during the reign of Ferdinand and Isabella,
+on account of an alleged plot to overthrow the monarchy,
+by the Jews and Heretics, in the year 1478, on
+application to Pope Sixtus IV., they were permitted to
+take over, as it were, the whole tribunal formerly
+handled as a Church affair, into the hands of the State,
+and with this new regime, the Spanish Inquisition had
+its origin.</p>
+
+<p>Inquisitors were now appointed by the Crown,
+instead of the Church and under the career of Thomas
+de Torquemada, in 1483, the reign of terror commenced
+in Spain. Llorente, the historian of the Inquisition,
+places the number of persons burned to death, during
+Torquemada’s tenure of office, in sixteen years, in
+Spain, at 9,000, and during the term of office of the
+second head of the Inquisition, Diego Deza, in eight
+years, 1,600 met a similar death, by fire, as this was
+the customary punishment inflicted upon this hated
+class of innocents who opposed the ruling powers in
+Church and State.<a id="FNanchor_672" href="#Footnote_672" class="fnanchor">[51]</a></p>
+
+<p>The procedure of the Inquisition is not without interest.
+The person suspected of heresy or unbelief,
+was arrested and thrown into prison, to be brought to
+trial when it suited the pleasure of his judges. The proceedings
+of the trial when the unfortunate one was<span class="pagenum"><a id="Page_288"></a>[288]</span>
+brought into court, were secret; he was not faced with
+his accusers, nor were their names disclosed. The evidence
+of a guilty accomplice, without corroboration,
+was received against the accused and the person undergoing
+trial was liable to be put to torture, in order to
+extort a confession from him. When convicted, the
+punishment was death by fire, or on the scaffold, imprisonment
+in the galleys for life, or for a term of
+years, with forfeiture of his property, and civil infamy,
+if the offense was deemed not of sufficient gravity to
+justify burning to death.<a id="FNanchor_673" href="#Footnote_673" class="fnanchor">[52]</a></p>
+
+<p>After confession, under torture, the prisoner was
+customarily remanded to prison and when brought
+before the judge, if he persisted in his profession, he
+was condemned. If the confession was withdrawn, he
+was tortured again and if he recanted a second time,
+he was tortured a third time, for while the theory was
+that he could not be convicted, unless he let his confession
+stand, he was tortured until he confessed and
+was not allowed to voluntarily retract it, oftentimes.<a id="FNanchor_674" href="#Footnote_674" class="fnanchor">[53]</a></p>
+
+<p>Three judges were necessary to approve the infliction
+of torture to extract evidence from a person accused,
+in the reign of Ferdinand and Isabella,<a id="FNanchor_675" href="#Footnote_675" class="fnanchor">[54]</a> but this law
+was often violated and the strappado, the scourge,
+hanging the accused by the arms, while his back and
+legs were loaded with heavy weights, fire, applied to
+the soles of the feet and pouring water down the throat
+were a few of the many tortures applied<a id="FNanchor_676" href="#Footnote_676" class="fnanchor">[55]</a> to extort
+confessions from the poor unfortunates who fell into<span class="pagenum"><a id="Page_289"></a>[289]</span>
+the hands of these religious zealots, imbued with a
+superhuman inclination to torture their fellow-men.</p>
+
+<p>Of course the subject of the Inquisition is too large
+a field to attempt to do more than refer to its influence
+upon secular law in these pages, for while it continued
+unabated for centuries in countries subject to the
+Church of Rome and was not abolished in Spain, until
+the reign of Joseph Bonaparte in 1808,<a id="FNanchor_677" href="#Footnote_677" class="fnanchor">[56]</a> in inaugurating
+a system of punishment for extracting evidence
+from the accused, its influence was wide-spread in all
+other countries, where the same system of punishment
+was carried and with time the same vile procedure was
+used in most other countries of Europe, in one form or
+another,<a id="FNanchor_678" href="#Footnote_678" class="fnanchor">[57]</a> and with its examples of torture, which were
+gradually adopted in other countries, the equally baleful
+influence of the secret procedure, which was exemplified
+in the Star Chamber in England and the <i>Chatelet</i>
+of Paris, with the accompanying inquisitorial process,
+followed in the wake of this hateful institution of the
+middle ages.<a id="FNanchor_679" href="#Footnote_679" class="fnanchor">[58]</a></p>
+
+<p><i>The Grand Chatelet of Paris</i>, as the seat of the criminal
+tribunal of the realm, has a record second to no
+other criminal court of the same age for atrocious
+punishments inflicted upon the poor unfortunates who
+were brought before the court, seeking justice.<a id="FNanchor_680" href="#Footnote_680" class="fnanchor">[59]</a></p>
+
+<p>It was the custom to torture all malefactors, or alleged
+criminals, brought before the criminal division
+of the <i>Chatelet</i> of Paris, in the fourteenth century. The<span class="pagenum"><a id="Page_290"></a>[290]</span>
+customary procedure was accordingly divided into two
+classes of cases, those known as <i>ordinaire</i> and those
+called <i>extraordinaire</i>. In the former class of cases inquests
+were held to determine the guilt of the accused
+and in the latter inquisition was had, in which torture
+was habitually employed to secure a conviction.<a id="FNanchor_681" href="#Footnote_681" class="fnanchor">[60]</a></p>
+
+<p>The procedure was left entirely to the discretion of
+the criminal judge and in a short time the judge rarely
+found a case for inquest, but all cases were treated as
+within the rule <i>proces extraordinaire</i> and a merry
+chronicle of crime against criminals was here inaugurated,
+for long and tedious years.<a id="FNanchor_682" href="#Footnote_682" class="fnanchor">[61]</a></p>
+
+<p>The only redeeming feature of the procedure of
+this court, was the universality of its punishments, for
+noble blood was made to flow equally with the plebeian,
+and none were exempt from the torture, who were
+brought before this court. If the culprit denied the
+alleged crime, he was tortured at once, to secure a confession
+and if he confessed he was tortured for confessing.
+On the other hand, if he failed to confess,<span class="pagenum"><a id="Page_291"></a>[291]</span>
+there was no limit to the torture inflicted to extract
+a confession from him, so frequently it happened that
+in the effort to find out if a crime were really committed
+the poor unfortunate was killed by the torture to which
+he was subjected.<a id="FNanchor_683" href="#Footnote_683" class="fnanchor">[62]</a></p>
+
+<p>In 1338 one Jehannin Maci, was arrested and brought
+before this cruel court for stealing a brass pot, found
+in his possession. After torture, he confessed the crime
+and was drawn on a hurdle and hanged.<a id="FNanchor_684" href="#Footnote_684" class="fnanchor">[63]</a></p>
+
+<p>Gervaise Caussois—peace to his ashes—was brought
+before this august tribunal for stealing some iron tools
+and to induce him to confess he was tortured and
+promptly confessed. Thinking he might be guilty of
+other offenses, he was tortured again and then under
+the strain of the pain he suffered, he confessed to other
+petty crimes, when he was again tortured by use of
+the <i>tresteau</i>, when he again confessed to another petty
+misdemeanor when the judges mercifully caused him
+to be hanged, without more ado, thus ending his
+misery.<a id="FNanchor_685" href="#Footnote_685" class="fnanchor">[64]</a></p>
+
+<p>In 1390 poor Fleurant de Saint-Leu, was arraigned
+before this heartless tribunal for the awful crime of
+stealing a silver buckle. He denied the crime and was
+twice tortured, with increasing severity, when he
+finally confessed, but protested that it was his first
+offense. The merciful judges, out of the goodness of
+their hearts, decided this offense, being the first, did
+not merit death, so on the same day he was tortured
+thrice, to ascertain if he was not guilty of some other<span class="pagenum"><a id="Page_292"></a>[292]</span>
+offense for which he could be killed; this failing to
+bring the desired result, he was again twice tortured,
+when he admitted that three years before he had unwittingly
+married a prostitute, when he was afterwards
+hanged, as this was found to be a sufficient offense, together
+with the stealing of the buckle, to justify the
+death penalty.<a id="FNanchor_686" href="#Footnote_686" class="fnanchor">[65]</a></p>
+
+<p>Poor Marguerite de la Penele, accused of stealing a
+ring, was tortured until she confessed and as she could
+not satisfy the human hyenas who were trying her, for
+some money found upon her person, she was again
+severely tortured and although no further confession
+was extracted from her she was buried alive.<a id="FNanchor_687" href="#Footnote_687" class="fnanchor">[66]</a></p>
+
+<p>The question <i>ordinaire</i> and <i>extra-ordinaire</i>, as put
+to the wretches brought before this criminal court at
+Paris, was to be answered by the accused while fastened
+to the wall, on a trestle or sliding table, with his
+wrists fastened in two rings; his mouth was forced
+open with a horn and water was poured down his throat,
+until he answered the question whether or not he was
+guilty of the offense charged against him.<a id="FNanchor_688" href="#Footnote_688" class="fnanchor">[67]</a></p>
+
+<p>Another form of torture used in the <i>Chatelet</i> at
+Paris, was what was called the “boots,” being solid
+boards, pierced with holes, encasing the legs, up to the
+knees. Ropes were inserted through the holes and
+drawn so tight, by means by pegs of wood, driven into
+the holes, as to almost break the bones and twist the
+flesh off the legs, if the accused persisted in refusing<span class="pagenum"><a id="Page_293"></a>[293]</span>
+to confess the crime charged against him.<a id="FNanchor_689" href="#Footnote_689" class="fnanchor">[68]</a> This horrible
+and barbarous practice was not completely abolished
+in France, until the year 1788, when the monarchy
+repealed the law authorizing such cruelty, for the alleged
+reason that under such stress of punishment
+men would confess to anything.<a id="FNanchor_690" href="#Footnote_690" class="fnanchor">[69]</a></p>
+
+<p><i>The Guillotine</i> was not a French invention, as generally
+supposed, but was imported from Italy, where
+a similar instrument, known as the <i>Mannaya</i>, had been
+used for centuries before it was used either in France
+or England.<a id="FNanchor_691" href="#Footnote_691" class="fnanchor">[70]</a> It had been used in England long before
+it was used in France and was known as the <i>Halifax
+Maiden</i>, because of the special charter, giving this
+town a right to use it for petty larceny of any article
+exceeding thirteen halfpenny.<a id="FNanchor_692" href="#Footnote_692" class="fnanchor">[71]</a> It was used in France
+in the sixteenth century and at Toulouse, in 1632, it
+was the engine which accomplished the execution of
+the Duc de Montmorency.<a id="FNanchor_693" href="#Footnote_693" class="fnanchor">[72]</a> Doctor Joseph Guillotin
+brought the same engine of death before the National
+Assembly, in December, 1789 and he is generally recognized
+as the inventor of this terrible machine, which
+was used to decapitate so many of the nobility during
+the terrible French Revolution,<a id="FNanchor_694" href="#Footnote_694" class="fnanchor">[73]</a> but a similar instrument
+had executed thousands in Italy centuries before
+it was known or used in France.<a id="FNanchor_695" href="#Footnote_695" class="fnanchor">[74]</a></p>
+
+<p><i>The Massola</i> was used in Italy, at an early date,<span class="pagenum"><a id="Page_294"></a>[294]</span>
+along with the <i>Mannaya</i> or guillotine, as it was afterwards
+called, in France, and by use of the former
+machine, the criminal was stunned with a blow from
+a mace, much as the butcher slaughters the ox or hog
+by striking him on the head and then while stunned,
+his throat was pierced with a long knife and his chest
+was ripped open.<a id="FNanchor_696" href="#Footnote_696" class="fnanchor">[75]</a></p>
+
+<p>But let us turn from the contemplation of other instruments
+used to accomplish the death of the criminals
+of the middle ages, and examine some of the milder
+forms of punishments in vogue.</p>
+
+<p>These were only some of the most prominent methods
+of inflicting capital punishment upon alleged criminals,
+among the old Israelites, Persians, Greeks and Romans,
+and other lesser punishments, such as mutilation consisting
+in blinding,<a id="FNanchor_697" href="#Footnote_697" class="fnanchor">[76]</a> cutting off the hands or ears,<a id="FNanchor_698" href="#Footnote_698" class="fnanchor">[77]</a>
+branding,<a id="FNanchor_699" href="#Footnote_699" class="fnanchor">[78]</a> plucking off the hair,<a id="FNanchor_700" href="#Footnote_700" class="fnanchor">[79]</a>
+ flaying,<a id="FNanchor_701" href="#Footnote_701" class="fnanchor">[80]</a> scourging
+with thorns,<a id="FNanchor_702" href="#Footnote_702" class="fnanchor">[81]</a> the stocks, stripes,<a id="FNanchor_703" href="#Footnote_703" class="fnanchor">[82]</a> the wheel, the rack,
+the comb with sharp teeth, the burning tile, the low
+vault in which the culprit was bent double, the heavy
+hog-skin whip, and the injection of vinegar into the
+nostrils, were a few of the lesser punishments inflicted
+by these and other peoples for many long and tortuous
+years, upon all classes of criminals and accused persons.<a id="FNanchor_704" href="#Footnote_704" class="fnanchor">[83]</a>.</p>
+
+<p><span class="pagenum"><a id="Page_295"></a>[295]</span></p>
+
+<p><i>Blinding</i>, under the Mosaic dispensation, was claimed
+to have been authorized under the law of retaliation,
+“an eye for an eye,”<a id="FNanchor_705" href="#Footnote_705" class="fnanchor">[84]</a> etc., but it was seldom used
+among the patriarchs in old Israel.</p>
+
+<p>The Assyrians and Babylonians used this means of
+torturing the criminals convicted of rebellion or revolt,
+in order to prevent them from doing further harm and
+to furnish an example to others of the enormity of the
+punishment for such an offense against the government.<a id="FNanchor_706" href="#Footnote_706" class="fnanchor">[85]</a>
+We read in the book of Esther that such criminals
+were not permitted to look upon the king,<a id="FNanchor_707" href="#Footnote_707" class="fnanchor">[86]</a> and
+in Persia this method of punishment was inflicted for
+rascality, thieving and rebellion.<a id="FNanchor_708" href="#Footnote_708" class="fnanchor">[87]</a></p>
+
+<p>According to the Code of Hammurabi, adopted some
+2,500 years before Christ’s time, a surgeon of Babylon
+who performed an unsuccessful operation, lost the hand
+that operated upon the patient and for other offenses,
+mutilation and blindness was provided for by this
+ancient code of laws.<a id="FNanchor_709" href="#Footnote_709" class="fnanchor">[88]</a></p>
+
+<p>William the Conqueror prohibited his nobles from
+inflicting the death penalty upon criminals who formerly
+suffered death by hanging, but in lieu of this
+more humane punishment, he authorized that criminals
+convicted of certain felonies should be blinded, by
+having their eyes pulled out; they were subjected to
+castration and to mutilation, by having their <i>hands and
+feet cut off</i>, according to the greatness of the offense,<span class="pagenum"><a id="Page_296"></a>[296]</span>
+to the end that they might live and furnish a horrible
+example to others committing such crimes.<a id="FNanchor_710" href="#Footnote_710" class="fnanchor">[89]</a></p>
+
+<p>According to Wigorn, in his annals, certain Welchmen,
+convicted of treason, in the eleventh century, had
+all these several kinds of punishment inflicted upon
+them.<a id="FNanchor_711" href="#Footnote_711" class="fnanchor">[90]</a></p>
+
+<p>Fox, in his work on Martyrology, reports a miracle
+in the case of Elivard, of Weston Regis, in Bedfordshire,
+who, being convicted of stealing a pair of hedging
+gloves and a whetstone, in the reign of Henry II.,
+lost his eyes and genitals, and through his devout
+prayers, at the shrine of St. Thomas of Canterbury,
+they were restored to him again.<a id="FNanchor_712" href="#Footnote_712" class="fnanchor">[91]</a></p>
+
+<p>This punishment by blinding and mutilation continued
+but a short time, in England, however, for King
+Henry I., in the year 1108, in the ninth year of his
+reign repealed this law and provided hanging for felons
+convicted of theft or robbery,<a id="FNanchor_713" href="#Footnote_713" class="fnanchor">[92]</a> who had formerly been
+subject to the punishment of blinding or mutilation,
+by this harsh law of William the Conqueror.</p>
+
+<p>In Switzerland, at an early day, blasphemers were
+subject to having their <i>lips and tongue cut off</i><a id="FNanchor_714" href="#Footnote_714" class="fnanchor">[93]</a> and
+under the custom of Avignon, in 1243, a perjurer was
+liable to punishment by having his lips and nose removed.<a id="FNanchor_715" href="#Footnote_715" class="fnanchor">[94]</a></p>
+
+<p><i>Cutting off the ears</i> was a punishment inflicted upon
+religious and political criminals in England, as late as<span class="pagenum"><a id="Page_297"></a>[297]</span>
+the seventeenth century and the notable case of Bastwick,
+Burton and Prynne, who had their ears removed
+all at one time, in the Palace Yard, in London, in the
+year 1637, illustrates the barbarous cruelty then obtaining
+as to this class of criminals.</p>
+
+<p>The prisoners were all favorites with the crowd, who
+strewed flowers and nose-gays around them, at the
+place of execution. The sheriff commenced with Burton,
+who was an especial favorite with the by-standers
+and when he removed each ear the people wept and
+groaned and roared as if each one in the assembly had
+his own ears removed. Bastwick loaned his own knife to
+the officer and made use of his professional information
+to advise him just how to remove his ears, so as to injure
+him the least and asked him to lop them close, that
+it might not be necessary for him “to come there
+again.” Prynne had had his ears roughly cropped off
+three years before and when the officer again attempted
+to remove what remained, it gave him great pain, but
+the stern old Puritan endured it without a groan, such
+was the religious zeal with which they were all three
+sustained in this act of martyrdom. After the fearful
+ordeal was completed they were all three returned by
+the officer to the prison,<a id="FNanchor_716" href="#Footnote_716" class="fnanchor">[95]</a> and thus ended another fearful
+example of misguided authority and religious
+bigotry, in thus pillorying and torturing three patriotic
+citizens who violated no law and who had committed
+no other offense than to speak plainly and then dared
+to refuse to bow the knee to an authority they did not
+recognize.</p>
+
+<p><i>Branding with a hot iron</i>, was a punishment inflicted<span class="pagenum"><a id="Page_298"></a>[298]</span>
+by the Persians, upon the class of criminals who were
+deported, in order that they could subsequently be
+identified and to furnish an example to others of the
+fact that they had paid the penalty of the law as a
+result of their misdeed.<a id="FNanchor_717" href="#Footnote_717" class="fnanchor">[96]</a> In Biblical days, when burning
+was inflicted as a punishment for adultery or fornication,
+branding on the forehead was also used, as a
+mark of shame.<a id="FNanchor_718" href="#Footnote_718" class="fnanchor">[97]</a> Slaves were sometimes branded on
+the hand, by the ancient Jews,<a id="FNanchor_719" href="#Footnote_719" class="fnanchor">[98]</a> much as horses are
+branded by the owner, in the western country, to identify
+the animal, but this was not in accordance with the
+Mosaic law, for such disfigurement was forbidden by
+the code of the old Israelites.<a id="FNanchor_720" href="#Footnote_720" class="fnanchor">[99]</a></p>
+
+<p>Formerly, in England, branding was used in the case
+of all clergyable crimes, by burning in the hand, but
+this law was repealed in 1829. In the middle ages, in
+England, branding with a hot iron, was a mode of
+punishment used for various offenses. The iron used
+had the form which it was desired to leave on the culprit’s
+skin. It has not been in use for years, except in
+desertions from the army or navy, and this form of
+branding is regulated by statute and of late years ink,
+or other material is used, instead of a hot iron. By
+the Mutiny Act, of 1858,<a id="FNanchor_721" href="#Footnote_721" class="fnanchor">[100]</a> it was provided “On the<span class="pagenum"><a id="Page_299"></a>[299]</span>
+first and on every subsequent conviction, for desertion,
+the court-martial, in addition to any other punishment,
+may order the offender to be marked, on the left side,
+two inches below the arm-pit, with the letter D, such
+letter not to be less than an inch long, and to be marked
+upon the skin with some ink or gun-powder, or other
+preparation, so as to be visible and conspicuous, and
+not liable to be obliterated.” This, in old England, as
+late as the Victorian age, shows the early training of the
+English upon the custom of punishment by branding.</p>
+
+<p><i>Plucking off the hair</i>, or scalping, was not always
+confined to the American Indians, but according to the
+inspired word of the Jews, it was a form of punishment,
+in ancient Israel, inflicted upon Jews who had indulged
+in mixed marriages.<a id="FNanchor_722" href="#Footnote_722" class="fnanchor">[101]</a></p>
+
+<p>According to the prophet, in Isaiah, scalping, as a
+judicial practice was common in his time, for he says:
+“I gave my back to the smiters and my cheeks to them
+that <i>plucked off the hair</i>: I hid not my face from shame
+and spitting.”<a id="FNanchor_723" href="#Footnote_723" class="fnanchor">[102]</a></p>
+
+<p>And according to the Biblical account of this ancient
+and severe punishment, inflicted upon criminals in old
+Israel, they were not as compassionate as the American
+Indians, who first killed their man, then removed the
+scalp with a knife, but they tore off the hair in such
+a brutal and barbarous manner, as to remove the skin
+by main force, with the hair, without the use of a knife<span class="pagenum"><a id="Page_300"></a>[300]</span>
+or other instrument to augment or ameliorate the suffering
+of the criminal.<a id="FNanchor_724" href="#Footnote_724" class="fnanchor">[103]</a></p>
+
+<p><i>Flaying</i>, was a punishment in vogue among the Persians
+and Assyrians, and according to Rawlinson, the
+Assyrians would flay the victim, even after life was
+extinct<a id="FNanchor_725" href="#Footnote_725" class="fnanchor">[104]</a> and the Persians were accustomed to flay
+and then crucify the criminals and Herodotus states
+that they used the skins of human beings thus obtained.<a id="FNanchor_726" href="#Footnote_726" class="fnanchor">[105]</a></p>
+
+<p>Along with this atrocious punishment of flaying, the
+Persians also seem to have been addicted to the recall
+of judges,<a id="FNanchor_727" href="#Footnote_727" class="fnanchor">[106]</a> for Herodotus tells how King Cambyses
+not only recalled an unpopular judge, known as Sisamnes
+but actually flayed him alive, and covered the
+judgment-seat with his skin, as a warning to the next
+judge to be more careful in his judgments and decrees.<a id="FNanchor_728" href="#Footnote_728" class="fnanchor">[107]</a></p>
+
+<p>Manes is said to have been flayed alive, by Behram,
+king of Persia, in the year 277 and his skin was afterwards
+stuffed with straw, much as modern taxidermists
+stuff the skins of wild animals, and in this shape it
+was posted at one of the gates of Djondischaour.<a id="FNanchor_729" href="#Footnote_729" class="fnanchor">[108]</a></p>
+
+<p>In the sixth century Chosroes punished Nacoragan,
+one of his generals by flaying him alive, on account of
+his cowardice and his skin, when torn backward off his
+body, from his head to his heels, retained the form of
+the limbs, from which it had been stripped, and in this<span class="pagenum"><a id="Page_301"></a>[301]</span>
+manner, it was sown up and inflated and exposed on a
+high projection, as a terrible example to other soldiers,
+of the punishment they would be subjected to if also
+guilty of cowardice in the discharge of their duty as
+soldiers.<a id="FNanchor_730" href="#Footnote_730" class="fnanchor">[109]</a></p>
+
+<p>Flaying is of rare appearance in Europe, but one or
+two cases are recorded. Philip the Fair is said to have
+inflicted such punishment upon the lovers of his sister-in-law,
+in 1314, and Pope John XXII., after the conviction
+of Hugues Geraldi, Bishop of Cahors, in 1317, for
+sorcery, handed him over to the Judge of Avignon, who
+caused him to be flayed alive and then torn asunder by
+four horses, after which his remains were burnt.<a id="FNanchor_731" href="#Footnote_731" class="fnanchor">[110]</a></p>
+
+<p><i>The Wheel</i> was used as a method of punishment in
+France and England and other countries, during the
+middle ages and down to a comparatively recent period.
+St. Catherine, of Alexandria is said to have been put
+to death on a wheel, with jagged edges or spikes, which
+tore and cut her tender limbs, after the fashion of a
+modern chaff-cutter. According to the report of her
+case, the wheel was shattered, during the torture, by
+Divine Grace, hence the embroidered tunic worn by the
+Knights of Mount Sinai, a religious order, instituted in
+her honour, in 1063, representing a broken wheel, with
+spikes.<a id="FNanchor_732" href="#Footnote_732" class="fnanchor">[111]</a></p>
+
+<p>Bouchard, who was implicated in the murder of
+Charles le Bon, Count of Flanders, in the twelfth century,
+was bound to a wheel suspended in mid-air, so
+that the vultures could pluck out his eyes and otherwise<span class="pagenum"><a id="Page_302"></a>[302]</span>
+torture him. After his eyes were torn from their sockets
+and his face slit and torn by the sharp beaks of the birds
+of prey, he was finally put out of his misery, by darts
+and javelins, shot into his quivering body, by the blood-thirsty
+mob below.<a id="FNanchor_733" href="#Footnote_733" class="fnanchor">[112]</a></p>
+
+<p><i>Scourging with thorns</i>, was another form of punishment
+inflicted upon the peoples of other tribes, by the
+good old Jewish patriarchs.</p>
+
+<p>Gideon threatened that when the Lord of Israel
+should deliver Zebah and Zalmunna into his hands
+that he would tear their flesh with the thorns of the
+wilderness and with briars.<a id="FNanchor_734" href="#Footnote_734" class="fnanchor">[113]</a> And according to the
+Divine word, when the men of Succoth were delivered
+into his hand he took the elders of the city and with
+briars and thorns, he scourged them.<a id="FNanchor_735" href="#Footnote_735" class="fnanchor">[114]</a></p>
+
+<p>Knotted sticks, or ropes, with thorns, or iron points
+were customarily used as instruments of chastisement
+by the Jews, when they were successful in subjugating
+another race of people<a id="FNanchor_736" href="#Footnote_736" class="fnanchor">[115]</a> and they did not hesitate to
+apply the scourge on all occasions, as they regarded
+this as a method of teaching foreign nations their
+strength and their power to punish, so that it would
+be advertised abroad and cause other timorous nations
+to voluntarily submit to their authority.</p>
+
+<p>David smote the Moabites with a line and cast them
+down to the ground and he scourged them and they
+became his servants and brought him gifts, to avoid
+being further scourged in this manner.<a id="FNanchor_737" href="#Footnote_737" class="fnanchor">[116]</a> And he<span class="pagenum"><a id="Page_303"></a>[303]</span>
+brought the children of Ammon out from the cities
+and not only scourged them with thorns and knotted
+sticks, with iron pikes in the sticks, but subjected them
+to saws and arrows of iron and made them to pass
+through the brick kiln.<a id="FNanchor_738" href="#Footnote_738" class="fnanchor">[117]</a></p>
+
+<p><i>The Bilboes</i>, were used in Spain and England, at an
+early day, for slanderers and other petty offenders.
+By means of this instrument, the culprit was held with
+his feet aloft, on his back, exposed to the public gaze
+and ridicule of the passers-by.</p>
+
+<p>The American Colonists made frequent use of this
+instrument of punishment and we read that in good
+old Massachusetts, in August, 1632, one “James Woodward
+was sett in the bilbowes, for being drunk at the
+Newetowne,” the name Cambridge then went by.<a id="FNanchor_739" href="#Footnote_739" class="fnanchor">[118]</a></p>
+
+<p><i>The Ducking-stool</i>, a stool or seat, arranged at the
+end of a rope tied to a long pole, so it could be lowered
+into the water, was used as a punishment for “scolds”
+and “slanderers” in old England and by the early
+American Colonies. Virginia, Maryland and other of
+the American Colonies, provided for the use of the
+ducking-stool and other similar correctionary punishments,
+by statutes.<a id="FNanchor_740" href="#Footnote_740" class="fnanchor">[119]</a></p>
+
+<p>As late as the year 1811, in Georgia, one Miss Palmer
+was sentenced to be ducked, as a scold or slanderer, in
+the Oconee River<a id="FNanchor_741" href="#Footnote_741" class="fnanchor">[120]</a> and in Washington, according to
+the interesting book on “Curious Punishments of By-Gone<span class="pagenum"><a id="Page_304"></a>[304]</span>
+Days,” by Alice Morse Earle, almost in our own
+day, Mrs. Anne Royal, Editor of the “Washington
+Paul Pry,” was sentenced before Judge William
+Cranch to suffer punishment by being ducked in the
+Potomac River.<a id="FNanchor_742" href="#Footnote_742" class="fnanchor">[121]</a></p>
+
+<p><i>The Stocks</i> graced each parish, in England, at an
+early day and along with the <i>pillory</i> and the <i>rack</i>, were
+used on different classes of petty criminals. Many
+criminals were also punished by the American Colonists
+by use of the stocks and the pillory, and in Massachusetts,
+New Hampshire, Virginia and Maryland,
+the manners and morals of many an early patriot were
+mended by the use of these instruments.<a id="FNanchor_743" href="#Footnote_743" class="fnanchor">[122]</a></p>
+
+<p><i>The Rack</i> was a wooden framework, in which the culprit
+was fastened and by means of ropes and pulleys
+his arms and legs were violently stretched and pulled
+until the tension caused the most intense pain and frequently
+the bones were broken by the use of this fearful
+appliance. According to Lord Coke, the appliance was
+first introduced into the Tower, in England, by the
+Duke of Exeter, in 1467, and for this reason it was
+called, “The Duke of Exeter’s Daughter.” The Tower
+rack was in the long vaulted dungeon below the
+Armoury and continued as an instrument of torture
+for many centuries. During the reign of Elizabeth, it
+was a customary means of torture and in 1580 the
+Jesuit Priests concerned in the alleged Jesuit Invasion,
+were terribly racked to compel them to disclose the
+names of their leaders.<a id="FNanchor_744" href="#Footnote_744" class="fnanchor">[123]</a></p>
+
+<p><span class="pagenum"><a id="Page_305"></a>[305]</span></p>
+
+<p>Shakespeare makes frequent references to this instrument
+of torture, so generally used during his time,
+in England. Thus, in Merchant of Venice, Portia refers
+to the enforced statements of Bassanio:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Ay, but I fear, you speak upon the rack,</div>
+ <div class="verse indent0">Where men enforced do speak anything.”<a id="FNanchor_745" href="#Footnote_745" class="fnanchor">[124]</a></div>
+ </div>
+</div>
+</div>
+
+<p><i>The Brank</i>, known as the “Scold’s bridle,” was an
+iron hood, with a ring, around the face, with a flat
+tongue of iron to be placed in the mouth, over the
+tongue. It was applied, with the “scold” or slanderer
+tied in a public place, where she was subjected to the
+ridicule of the passers-by and was generally used to
+correct scolds and fussy women, for many years, in
+both England and America. It was used on the poor
+unfortunates during the Salem Witchcraft craze and
+many an old dame in good old England was made to
+bridle her tongue and desist from gossiping or henpecking
+her husband, because of the fear of the “scold’s
+bridle” and the gag, used indiscriminately, in all such
+cases.<a id="FNanchor_746" href="#Footnote_746" class="fnanchor">[125]</a></p>
+
+<p>Fortunately, with the dawn of better days, this torture
+system began to decline and in most civilized
+countries, such “crimes against criminals” are now but
+curious and quaint, yet oft-times terrible and fearful
+examples of the customs and procedure of other days.</p>
+
+<p>The strange thing is that such things lasted as long
+as they did in a growing, increasing world of knowledge,
+with men who sought the truth and attempted to
+attain the higher ideals and who should have been<span class="pagenum"><a id="Page_306"></a>[306]</span>
+imbued with the love of their fellow-man, which the
+sufferings and mistakes of the past had, for centuries,
+led them to emulate.</p>
+
+<p>With the striking example in history of the horrible
+punishment by Crucifixion, all men now dread to think
+of the time when innocence and goodness could be so
+crucified, yet for two thousand years, in the slow evolution
+of the human race, other innocents and good men
+and women have been tortured and racked by men and
+women holding the superior power and authority over
+the masses, who through superstition and delusion,
+were led to endorse the cruel domination of such misused
+force.</p>
+
+<p>When we stop and contemplate the enormity of
+“Man’s inhumanity to man,” as recorded in the lessons
+of the past, “the marvel is that man can smile, dreaming
+his ghostly, ghastly dream.”</p>
+
+<p>The basis of such misanthropy lies in the fact that
+criminals have been treated as enemies, to such an extent
+that mankind has warred upon them and committed
+deeds of war, when, in point of fact, the alleged
+criminal, frequently was less guilty than his judges,
+and, if guilty, he was only a mistaken man, needing correction,
+but not torture or death, to teach him the better
+path to tread. Would that future generations might
+be fully emancipated from the selfish creed which calls
+that good, which works <i>me</i> weal and holds that ill, which
+<i>me</i> alone doth harm or hurt.</p>
+
+<p>For our lives, like ravelled skeins, cross back and
+forth, connect and blend,</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“They change with place, they shift with race; and, in the veriest span of Time,</div>
+ <div class="verse indent0">Each Vice has worn a Virtue’s crown; all Good was banned as Sin or Crime.”</div>
+ </div>
+</div>
+</div>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_622" href="#FNanchor_622" class="label">[1]</a> Justice is the bond which keeps the interest of individuals
+united and without this virtue men would return to their original
+state of barbarity. Marquis Beccaria, on “Crimes and Punishments,”
+9.</p>
+
+<p>Carlyle has well said: “Cruel is the panther of the woods, the
+she-bear, bereaved of her whelps; but there is in man a hatred
+crueler than that.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_623" href="#FNanchor_623" class="label">[2]</a> Beccaria’s “Crimes and Punishments,” p. 41.</p>
+
+<p>The three theories regarding lawful punishment, are, retribution,
+prevention and reformation. According to the first of these theories,
+the object of punishment is the vindication of the law upon the
+offender, by the infliction of such pain or penalty as his crime
+deserves, hence, the motto for this theory, might be properly said
+to be Justice. The second idea, makes prevention of further crime,
+the sole object, the criminal being placed where he can do no
+further wrong to society, and the motto of this school of legal
+philosophers, can therefore properly be said to be protection. The
+third and by far the most philanthropic doctrine of punishment
+regards the object of correction as the primary one to be attained
+and that all punishment should cease when the criminal has been
+reformed. The motto for the last school of philosophy, might
+properly be said to be Brotherly Love.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_624" href="#FNanchor_624" class="label">[3]</a> Rawlinson’s “Ancient Monarchies.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_625" href="#FNanchor_625" class="label">[4]</a> Genesis, XL., 19, 22.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_626" href="#FNanchor_626" class="label">[5]</a> Matthew, XIV., 8, 10.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_627" href="#FNanchor_627" class="label">[6]</a> Acts, XII., 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_628" href="#FNanchor_628" class="label">[7]</a> Revelation, XX., 4. A common punishment during the French
+Revolution.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_629" href="#FNanchor_629" class="label">[8]</a> Genesis, XXXVIII., 24.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_630" href="#FNanchor_630" class="label">[9]</a> Leviticus, XXI., 9.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_631" href="#FNanchor_631" class="label">[10]</a> Leviticus, XX., 14.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_632" href="#FNanchor_632" class="label">[11]</a> John’s “Babylonian Laws,” etc., Josephus; Matthew, XVIII., 6.</p>
+
+<p>The Emperor Tiberius, after torturing the victims of his wrath,
+cast them into the sea, where they were drowned. Sueton. Tiberii,
+lxii; Lea, “Superstition and Force,” (3 ed.) p. 377.</p>
+
+<p>In France, death by drowning was inflicted upon the incontinent,
+as late as the sixteenth century and it was revived again during the
+revolution by the infamous Carrier, at Nantes, in the eighteenth
+century.</p>
+
+<p>Ninety priests were loaded into the <i>gabare</i> and sunk in the river
+Seine. Then a hundred and thirty-eight persons were similarly
+drowned, but the <i>gabare</i> was soon done away with and men, women
+and children were stripped naked and thrown into the river, in
+broad daylight and not even under the cover of darkness. They
+were tied together, feet and feet and hands and hands, and in their
+hideous death struggles they churned the water, for the edification
+of the cruel crowd, until the last poor struggler had sunk to his
+final rest. (See article by W. H. Davenport Adams, “Pains and
+Penalties,” in The Gentleman’s Magazine, Vol. 46, p. 362.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_633" href="#FNanchor_633" class="label">[12]</a> Herbert’s Antiquities (1804), 154; Ex. vet. cod. M. S. pene’s
+Rog. Twysden bar. p. 108.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_634" href="#FNanchor_634" class="label">[13]</a> Gentleman’s Magazine, Vol. 46, p. 501.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_635" href="#FNanchor_635" class="label">[14]</a> Archibald’s Stewart’s “Wigtoun Martyrs.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_636" href="#FNanchor_636" class="label">[15]</a> Daniel, VI., 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_637" href="#FNanchor_637" class="label">[16]</a> Josephus, Ant. VIII., IX., 1.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_638" href="#FNanchor_638" class="label">[17]</a> 2 Samuel, IV., 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_639" href="#FNanchor_639" class="label">[18]</a> Rawlinson’s Anc. Mon. i, 477; Layard’s Ninevah and Babylon,
+295 note.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_640" href="#FNanchor_640" class="label">[19]</a> Herodotus, iii, 159; Josephus, Ant. VI., XIV., 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_641" href="#FNanchor_641" class="label">[20]</a> Beccaria’s “Crimes and Punishments.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_642" href="#FNanchor_642" class="label">[21]</a> 2 Chronicles, XXV., 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_643" href="#FNanchor_643" class="label">[22]</a> 1 Chronicles, XX., 3.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_644" href="#FNanchor_644" class="label">[23]</a> Exodus, XIX., 13.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_645" href="#FNanchor_645" class="label">[24]</a> Exodus, XXXII., 27.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_646" href="#FNanchor_646" class="label">[25]</a> 1 Samuel, XV., 33.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_647" href="#FNanchor_647" class="label">[26]</a> Hasting’s Dict. Bible, vol. I., p. 527.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_648" href="#FNanchor_648" class="label">[27]</a> 1 Kings, XX., 31.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_649" href="#FNanchor_649" class="label">[28]</a> Rawlinson’s Ancient Monarchies, iii, 246.</p>
+
+<p>Hanging was ordained by the Laws of Ina, in England, twelve
+hundred years ago. (Herbert’s Antiquities, p. 153.) Until 1783
+Tyburn Tree, at the west end of Oxford Road (now street), was
+the usual place for execution of felons by hanging, in England.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_650" href="#FNanchor_650" class="label">[29]</a> Josephus, Ant. XVII., X., 9.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_651" href="#FNanchor_651" class="label">[30]</a> <i>Idem.</i>, XX., V., 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_652" href="#FNanchor_652" class="label">[31]</a> John, XIX.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_653" href="#FNanchor_653" class="label">[32]</a> Matthew, XVI., 24; Mark, VIII., 14; Luke, IX., 23.</p>
+
+<p>All authorities agree that of all deaths crucifixion was the most
+abhorrent, not only because of the pain resulting, but also because
+of the shame of such a death. Cicero, in his Oration against Varres,
+declared that it was impossible to find a fit word to describe such
+an outrage as the crucifixion of a Roman citizen, yet the gentle
+Galilean suffered this horrible death, with perfect resignation.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_654" href="#FNanchor_654" class="label">[33]</a> Cedrenus, Hist. Comp. p. 148, 259.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_655" href="#FNanchor_655" class="label">[34]</a> Dions, iii. 67: Zonaras, vii, 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_656" href="#FNanchor_656" class="label">[35]</a> Dions, ix, 40; Smith’s Dict. Gr. &amp; Rom. Ant. By a beneficent
+law, the poor lady’s paramour was simply scourged to death, for his
+complicity in her awful crime.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_657" href="#FNanchor_657" class="label">[36]</a> Gentleman’s Magazine, Vol. 46, p. 366.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_658" href="#FNanchor_658" class="label">[37]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_659" href="#FNanchor_659" class="label">[38]</a> <i>Idem.</i>, p. 367.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_660" href="#FNanchor_660" class="label">[39]</a> Fleta, p. 54; II. Pollock and Maitland’s History English Law,
+p. 556.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_661" href="#FNanchor_661" class="label">[40]</a> Rawlinson’s <i>Anc. Mon.</i>; Niebuhr, ii, 313.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_662" href="#FNanchor_662" class="label">[41]</a> Gentleman’s Magazine, Vol. 46, p. 368.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_663" href="#FNanchor_663" class="label">[42]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_664" href="#FNanchor_664" class="label">[43]</a> Gentleman’s Magazine, Vol. 46, p. 496.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_665" href="#FNanchor_665" class="label">[44]</a> <i>Ante idem.</i>, p. 368.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_666" href="#FNanchor_666" class="label">[45]</a> Green’s History of England.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_667" href="#FNanchor_667" class="label">[46]</a> Select Pl. Cr. pl. 191; Munim. Gildh. i, 101; II. Pollock and
+Maitland’s History English Law, p. 511.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_668" href="#FNanchor_668" class="label">[47]</a> 22 Henry VIII. c. 9. This statute was passed in 1531.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_669" href="#FNanchor_669" class="label">[48]</a> IV. Reeve’s History English Law, p. 427.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_670" href="#FNanchor_670" class="label">[49]</a> The Winter’s Tale, Act III., Scene II.; White’s “Law in Shakespeare,”
+p. 186, Sec. 146.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_671" href="#FNanchor_671" class="label">[50]</a> Gentleman’s Magazine, Vol. 46, p. 364.</p>
+
+<p>As late as the sixteenth century, in England, counterfeiters were
+punished by being thrown into boiling water. Gentleman’s Magazine,
+Vol. 46, p. 364.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_672" href="#FNanchor_672" class="label">[51]</a> Llorente, ii, 147, 237.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_673" href="#FNanchor_673" class="label">[52]</a> Lea’s “History of the Inquisition.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_674" href="#FNanchor_674" class="label">[53]</a> Lea’s “Superstition and Force,” (3 ed.) p. 404.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_675" href="#FNanchor_675" class="label">[54]</a> Lea’s “Superstition and Force,” (3 ed.) p. 409.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_676" href="#FNanchor_676" class="label">[55]</a> <i>Ante idem.</i> 407, 409.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_677" href="#FNanchor_677" class="label">[56]</a> Llorente’s <i>Istoria de la Inquisition</i>; Lea’s “History of the Inquisition.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_678" href="#FNanchor_678" class="label">[57]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_679" href="#FNanchor_679" class="label">[58]</a> Lea’s “Superstition and Force,” (3 ed.) 451.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_680" href="#FNanchor_680" class="label">[59]</a> Du Cange’s <i>Questionarius</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_681" href="#FNanchor_681" class="label">[60]</a> L. Tanon, Registre Crimenel de la Justice de S. Martin-des-Champs,
+Introd. p. 85.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_682" href="#FNanchor_682" class="label">[61]</a> <i>Ante idem.</i></p>
+
+<p>In applying the ordinary and extraordinary question, in France,
+by means of the <i>estrapado</i>, an iron key was placed between the
+palms of the accused’s hands, and they were tied behind his back
+and, by means of a rope passed through a pulley, in the ceiling,
+he was raised twelve inches above the floor with a weight of one
+hundred and eighty pounds to his right foot. This was the “ordinary”
+question. In applying the “extraordinary” interrogation, the same
+process was used, but the accused was raised up to the ceiling,
+with a two hundred and fifty pound weight tied to his foot, in a
+running line, two or three times, with the result that he usually
+swooned before the ceiling was reached the last time. (Gentleman’s
+Magazine, Vol. 46, p. 504.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_683" href="#FNanchor_683" class="label">[62]</a> Lea’s “Superstition and Force,” (3 ed.) 441, 442.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_684" href="#FNanchor_684" class="label">[63]</a> Registrae Criminel de Chatelet de Paris, 1, 36.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_685" href="#FNanchor_685" class="label">[64]</a> <i>Ante idem.</i>, p. 36.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_686" href="#FNanchor_686" class="label">[65]</a> Register Criminal du Chatelet de Paris, 201, 209.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_687" href="#FNanchor_687" class="label">[66]</a> <i>Idem.</i>, p. 322.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_688" href="#FNanchor_688" class="label">[67]</a> Lalanne, Recueil des anciennes Lois Francaisse, tome xx, pp.
+284, etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_689" href="#FNanchor_689" class="label">[68]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_690" href="#FNanchor_690" class="label">[69]</a> Article by W. H. Davenport Adams, in Gentleman’s Magazine,
+Vol. 46, p. 506, entitled “<i>Pains and Penalties</i>.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_691" href="#FNanchor_691" class="label">[70]</a> History of Jean D’Auton; Holinshed’s History.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_692" href="#FNanchor_692" class="label">[71]</a> Holinshed; Gentleman’s Magazine, Vol. 46, p. 371.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_693" href="#FNanchor_693" class="label">[72]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_694" href="#FNanchor_694" class="label">[73]</a> The Gentleman’s Magazine, Vol. 46, p. 372.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_695" href="#FNanchor_695" class="label">[74]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_696" href="#FNanchor_696" class="label">[75]</a> The Gentleman’s Magazine, Vol. 46, p. 370.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_697" href="#FNanchor_697" class="label">[76]</a> Exodus, XXI., 24; 2 Kings, XXV., 7; Rawlinson’s Anc. Mon.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_698" href="#FNanchor_698" class="label">[77]</a> 2 Samuel, IV., 12; Rawlinson’s Anc. Mon. iii, 7.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_699" href="#FNanchor_699" class="label">[78]</a> Rawlinson’s Anc. Mon. iii, 194.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_700" href="#FNanchor_700" class="label">[79]</a> 2 Samuel, X., 4.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_701" href="#FNanchor_701" class="label">[80]</a> Rawlinson’s Anc. Mon. i, 478; iii, 246; Herodotus, IV., 64.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_702" href="#FNanchor_702" class="label">[81]</a> Samuel, VIII., 2; XII., 31; Stanley’s History Jew. Ch.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_703" href="#FNanchor_703" class="label">[82]</a> Leviticus, XIX., 20. 2 Corinthians, XI., 24; Josephus, Ant. IV.,
+VIII., 21.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_704" href="#FNanchor_704" class="label">[83]</a> Lea’s “Superstition and Force,” (3 ed.) 375.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_705" href="#FNanchor_705" class="label">[84]</a> Exodus, XXI., 24; Leviticus, XXIV. 20.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_706" href="#FNanchor_706" class="label">[85]</a> John’s “Babylonian Laws,” etc.; Rawlinson’s <i>Anc. Mon.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_707" href="#FNanchor_707" class="label">[86]</a> Esther, VII., 8.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_708" href="#FNanchor_708" class="label">[87]</a> Rawlinson’s <i>Anc. Mon.</i> Josephus, <i>Ant.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_709" href="#FNanchor_709" class="label">[88]</a> John’s “Babylonian Laws,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_710" href="#FNanchor_710" class="label">[89]</a> Herbert’s Antiquities, p. 153; Michelet.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_711" href="#FNanchor_711" class="label">[90]</a> Flor. Wigorn, Annals, <i>Ann.</i> 1098.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_712" href="#FNanchor_712" class="label">[91]</a> Fox’s Martyrology, lib. IV., fol. 229.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_713" href="#FNanchor_713" class="label">[92]</a> Herbert’s Antiquities (1804), p. 154.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_714" href="#FNanchor_714" class="label">[93]</a> Gentleman’s Magazine, Vol. 46, p. 495.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_715" href="#FNanchor_715" class="label">[94]</a> <i>Ante idem.</i></p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_716" href="#FNanchor_716" class="label">[95]</a> Gentleman’s Magazine, Vol. 46, 373.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_717" href="#FNanchor_717" class="label">[96]</a> Rawlinson’s <i>Anc. Mon.</i> ii, 194.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_718" href="#FNanchor_718" class="label">[97]</a> Hastings Dict. of Bible, i, p. 523.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_719" href="#FNanchor_719" class="label">[98]</a> Isaiah, XLIV., 5.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_720" href="#FNanchor_720" class="label">[99]</a> Leviticus, XIX., 28.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_721" href="#FNanchor_721" class="label">[100]</a> 21 Victoria, c. 9, sec. 35.</p>
+
+<p>Branding was used by the American Colonists and in New England
+was a common punishment for Quakers, who were branded
+with red hot iron, on the shoulder, with a letter “H” for Heretic.
+(Alice Morse Earle’s “Curious Punishments of By-Gone Days,” pp.
+138, 148.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_722" href="#FNanchor_722" class="label">[101]</a> “In those days, also saw I Jews, that had married wives, of
+Ashdol, of Ammon, and of Moah.... And I contended with
+them, and cursed them, and smote certain of them, and <i>plucked
+off their hair</i>, and made them swear, by God, saying Ye shall not
+give your daughters unto their sons, nor take their daughters unto
+your sons, or for yourselves.” Nehemiah, XIII., 23, 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_723" href="#FNanchor_723" class="label">[102]</a> Isaiah, L., 6.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_724" href="#FNanchor_724" class="label">[103]</a> 2 Mac. VII., 7.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_725" href="#FNanchor_725" class="label">[104]</a> Ancient Monarchies, i, 478; Layard’s Ninevah and Babylon.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_726" href="#FNanchor_726" class="label">[105]</a> Rawlinson’s Ancient Monarchies, iii, 246; Herodotus, iv, 64, v, 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_727" href="#FNanchor_727" class="label">[106]</a> John’s “Babylonian Laws,” etc.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_728" href="#FNanchor_728" class="label">[107]</a> Herodotus, <i>ante</i>.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_729" href="#FNanchor_729" class="label">[108]</a> Gibbon’s Rome.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_730" href="#FNanchor_730" class="label">[109]</a> Agathiu’s “Life of Justinian.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_731" href="#FNanchor_731" class="label">[110]</a> Bertrandy’s “Un Eveque Supplicie.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_732" href="#FNanchor_732" class="label">[111]</a> Martin’s “<i>Les Vies des Saints</i>.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_733" href="#FNanchor_733" class="label">[112]</a> Segur’s Memoirs and Anecdotes.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_734" href="#FNanchor_734" class="label">[113]</a> Judges, VIII., 7.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_735" href="#FNanchor_735" class="label">[114]</a> Judges, VIII., 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_736" href="#FNanchor_736" class="label">[115]</a> 1 Kings, XII., 11.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_737" href="#FNanchor_737" class="label">[116]</a> 2 Samuel, VIII., 2.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_738" href="#FNanchor_738" class="label">[117]</a> 2 Samuel, XII., 31.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_739" href="#FNanchor_739" class="label">[118]</a> “Curious Punishments of By-Gone Days,” by Alice Morse Earle,
+p. 5.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_740" href="#FNanchor_740" class="label">[119]</a> “Curious Punishments of By-Gone Days,” by Alice Morse Earle,
+pp. 17, 20.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_741" href="#FNanchor_741" class="label">[120]</a> <i>Ante idem.</i>, p. 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_742" href="#FNanchor_742" class="label">[121]</a> <i>Ante idem.</i>, p. 28.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_743" href="#FNanchor_743" class="label">[122]</a> The Gentleman’s Magazine, Vol. 46, p. 373; Alice Morse Earle’s
+“Curious Punishments of By-Gone Days,” pp. 29, 43.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_744" href="#FNanchor_744" class="label">[123]</a> The Gentleman’s Magazine, Vol. 46, p. 499.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_745" href="#FNanchor_745" class="label">[124]</a> Act III., Scene II. For many other references to this instrument
+of torture, by Shakespeare, see note, to section 82, in White’s “Law in
+Shakespeare,” pp. 116, 118.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_746" href="#FNanchor_746" class="label">[125]</a> Alice Morse Earle’s “Curious Punishments of By-Gone Days,” pp.
+96, 105.</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_307"></a>[307]</span></p>
+
+<h2 class="nobreak" id="CHAPTER_XI">CHAPTER XI.<br>
+<span class="smcap">Wills, Quaint and Curious.</span></h2>
+
+</div>
+
+<p>A last will and testament is the instrument whereby
+one disposes of his property, to take effect after his
+death.<a id="FNanchor_747" href="#Footnote_747" class="fnanchor">[1]</a></p>
+
+<p>The right to dispose of one’s property, by will, consistent
+with existing rules of law, is one of the results
+of man’s social condition, based upon an instinctive
+sentiment, akin to self love, which looks to the preservation
+and alienation, according to the intent of the
+owner, of the individual acquisitions, resulting from
+personal endeavor.</p>
+
+<p>There is a vast amount of interesting information,
+in connection with the history and forms of antique
+wills, and testamentary dispositions of property, in
+one form or another, are of extremely ancient origin.<a id="FNanchor_748" href="#Footnote_748" class="fnanchor">[2]</a></p>
+
+<p>Historians and law writers have told us that the will,
+as we know it, is a Roman invention, but in this statement
+the testimony of others is accepted as establishing
+the fact, rather than the knowledge, or want of
+knowledge of the fact asserted. Indeed, writers are
+frequently given to accepting and repeating the statements
+of others, without investigating the facts upon
+which such statements are based, much as the court did,
+that decided that a given windstorm was not a cyclone,
+where the conclusion was based wholly upon the evidence
+showing that the clouds lacked the funnel shape<span class="pagenum"><a id="Page_308"></a>[308]</span>
+and circling motion, while the effect of the storm, evidenced
+by the twisted trunks of giant trees, the houses
+awry and other primary evidence of the fact asserted,
+was wholly over-looked, in reaching the conclusion.<a id="FNanchor_749" href="#Footnote_749" class="fnanchor">[3]</a></p>
+
+<p>There is evidence that wills were used in Egypt
+centuries before they were known in Europe;<a id="FNanchor_750" href="#Footnote_750" class="fnanchor">[4]</a> Solon
+is said to have introduced them into Greece,<a id="FNanchor_751" href="#Footnote_751" class="fnanchor">[5]</a> and wills
+were used in Rome, long before the date of the Twelve
+Tables.<a id="FNanchor_752" href="#Footnote_752" class="fnanchor">[6]</a></p>
+
+<p>Abraham, in his lament of the want of a legitimate
+heir, appointed the steward and servant born in his
+house to take his estate, after his death and this was,
+virtually, the appointment of an heir by will.<a id="FNanchor_753" href="#Footnote_753" class="fnanchor">[7]</a> And<span class="pagenum"><a id="Page_309"></a>[309]</span>
+the Hebrew Patriarch, Jacob, before taking his departure
+from his sons, with the knowledge of approaching
+death, said unto Joseph:<a id="FNanchor_754" href="#Footnote_754" class="fnanchor">[8]</a></p>
+
+<div class="blockquote">
+
+<p>“Behold, I die; but God shall be with you and bring
+you again unto the land of your fathers. Moreover, I
+have given to thee, one portion above thy brethren,
+which I took out of the land of the Amorite with my
+sword and with my bow. And Jacob called unto his
+sons and said, gather yourselves together, that I may
+tell you that which shall befall you in the last days.”</p>
+
+</div>
+
+<p>Of course this is but an oral bequest, but it has all
+the elements of a death-bed disposition, made under the
+apprehension of approaching death and it sets forth the
+“portion” to Joseph, after mentioning the derivation
+of the testator’s title, and the symbolic emblems
+to the other sons are distributed, with all the solemnity
+of a will, in fact.</p>
+
+<p>From these illustrations, it will be seen, that from
+the beginning of the history of man, as we know him,
+or at least in the patriarchial days of the ancient Hebrews,
+the custom obtained of making testamentary dispositions
+of property, and there is also evidence extant
+that this custom was not confined alone to the ancient
+Israelites.</p>
+
+<p>An Egyptian will, dating back to patriarchial times,
+was recently unearthed at Kahun, by the English Egyptologist,
+William Petrie.<a id="FNanchor_755" href="#Footnote_755" class="fnanchor">[9]</a> By this document, written
+2548 B. C. one Sekrehen, a citizen of the time of Amenemhat
+IV., settles upon his wife, Teta, all the property
+given him by his brother, for life, with a condition
+against the commission of waste, and one Siou, a lieutenant,<span class="pagenum"><a id="Page_310"></a>[310]</span>
+is appointed guardian for the infant children.
+Two scribes attest the execution of this will in solemn
+form and thus we have the indisputable evidence, by
+this document executed forty-six hundred years ago,
+that the statement of modern historians that wills are
+of Roman origin and were invented by the clergy of
+mediaeval times,<a id="FNanchor_756" href="#Footnote_756" class="fnanchor">[10]</a> is in error.</p>
+
+<p>The written will of the Assyrian monarch, Sennacherib,
+assassinated in the year 681, B. C., is preserved in
+the royal library of Kenyunjik<a id="FNanchor_757" href="#Footnote_757" class="fnanchor">[11]</a> and in the form customarily
+used in that period, he bequeathed to his
+son, Esarhadden, his bracelets, coronets and other gifts
+of gold, ivory and precious stones, deposited, for safekeeping,
+“in the temple of Nebo.”</p>
+
+<p>The will of the philosopher, Plato, 348 B. C., who
+left “no debts,” but devised his farms, with a provision
+against alienation,<a id="FNanchor_758" href="#Footnote_758" class="fnanchor">[12]</a> to his son, Adimantes, together
+with his vase, gold, cash, slaves, “also all my chattels,
+as specified in an inventory, held and possessed by
+Demetrius,” is a model of brevity and concise legal
+form, such as the experienced lawyer of today would
+have prepared for his client.</p>
+
+<p>The will of the great Aristotle, who, at sixty-eight
+entered upon his final long sleep of death, in the year
+322 B. C., after appointing Antipater his executor, with
+other named friends to assist him in the management
+and care of his estate, proceeds to dispose of his acquisitions,
+in a most reasonable business-like manner,
+from the provision for his daughter, in case of her<span class="pagenum"><a id="Page_311"></a>[311]</span>
+marriage, including the disposition of his various
+slaves, the finishing of his statues and the depositing
+of the bones of his wife, Pythias, in his tomb, “even
+as she desired,” to the final arrangements for the
+offering of the four stone animals, for the preservation
+of Nicanor, to Jupiter and Minerva, is just such
+a sane, sensible testamentary provision as one would
+expect from such an astute philosopher.<a id="FNanchor_759" href="#Footnote_759" class="fnanchor">[13]</a></p>
+
+<p>Virgil died ten years before Christ and his will left
+his manuscript of the Aeneid to his friends and executors,
+Tucca and Varus, and divided his property between
+his half-brother, Proculus and Valerius, after
+leaving a fourth to Augustus, a twelfth to Macaenas
+and the rest to Varus.<a id="FNanchor_760" href="#Footnote_760" class="fnanchor">[14]</a></p>
+
+<p>But we cannot devote more space in this chapter to
+the wills of the most gifted of men of this ancient
+period, however interesting it would be to follow the
+testamentary devises of the statesmen, poets and philosophers
+of the period before Christ, but to trace the
+origin and growth of English wills, with a few illustrations
+of the quaint and curious, will sufficiently lengthen
+the scope of the present subject-matter.</p>
+
+<p>Forms of testamentary disposition of personalty obtained
+in Great Britain at a very early period,<a id="FNanchor_761" href="#Footnote_761" class="fnanchor">[15]</a> but
+until the Statute of Wills, in 1540,<a id="FNanchor_762" href="#Footnote_762" class="fnanchor">[16]</a> there was no right
+of disposition by will, in England, on the part of the
+owner of real estate.<a id="FNanchor_763" href="#Footnote_763" class="fnanchor">[17]</a></p>
+
+<p><span class="pagenum"><a id="Page_312"></a>[312]</span></p>
+
+<p>The Anglo-Saxon will is not a product of the Roman
+will at all, but is purely a creature of the manners and
+customs of the English people themselves.<a id="FNanchor_764" href="#Footnote_764" class="fnanchor">[18]</a> In the
+early Anglo-Saxon law wills were unknown, but owed
+their origin to the privilege accorded the crowned heads
+and great ones to make testamentary disposition and
+death-bed gifts of their property.<a id="FNanchor_765" href="#Footnote_765" class="fnanchor">[19]</a> In Cnut’s day it
+was not unusual for a man to make a post obit gift
+of his land or goods, and after the Norman conquest
+this custom continued and one could dispose of his land,
+after his death, by a charter, effective upon his own
+death, or that of his wife,<a id="FNanchor_766" href="#Footnote_766" class="fnanchor">[20]</a> but the testamentary devise,
+as we know it, was not a common instrument in
+this day.</p>
+
+<p>After the middle of the thirteenth century the king’s
+court condemned the post obit gift of land, by charter,
+but allowed it only in certain boroughs where the custom
+obtained; primogeniture was held to destroy the
+existing law of succession; the church asserted the right
+to execute the last will and testament of every person
+and the horror of intestacy increased, as the church
+assumed the right to administer the goods of the deceased,
+for the good of his soul.<a id="FNanchor_767" href="#Footnote_767" class="fnanchor">[21]</a></p>
+
+<p>We read, in the old books, that a great man, Eude,
+died in Normandy, during the reign of Henry I., and
+made a certain division or devise of his property, leaving<span class="pagenum"><a id="Page_313"></a>[313]</span>
+his manor to the abbey he had built at Colchester,
+with a hundred pounds and a gold ring, together with
+a cup and horse and mule; but before the King would
+confirm the devise of the manor, he compelled the surrender
+of the cup, horse and mule to the Crown.<a id="FNanchor_768" href="#Footnote_768" class="fnanchor">[22]</a></p>
+
+<p>And the post obit gift to Walden Abbey attempted
+by William de Mandeville, Earl of Essex, during the
+reign of Henry II. was also set aside by Geoffrey Fitz
+Peter, one of Glanville’s successors as Chief Justiciar,<a id="FNanchor_769" href="#Footnote_769" class="fnanchor">[23]</a>
+under Henry II., and his successor.</p>
+
+<p>Of course the church-men frequently procured confirmations
+from the heirs of these post obit gifts of
+land to the church, by the threat of a dying father and
+the disapprobation of the church, if the gift was not
+confirmed, but in the law these gifts were not recognized,
+for, as Glanville puts it, in this period it was
+an axiom of the law that “God alone and not man can
+make an heir.”<a id="FNanchor_770" href="#Footnote_770" class="fnanchor">[24]</a></p>
+
+<p>Glanville speaks of the probate of wills, as if that
+mode of authenticating these documents had been long
+in use, when he wrote, but just when this custom was
+crystalized into law, in England, it is difficult to determine.<a id="FNanchor_771" href="#Footnote_771" class="fnanchor">[25]</a>
+In the reign of Henry III. the ecclesiastical
+courts assumed jurisdiction in the probate of wills and
+soon thereafter attempted quite generally to enforce
+the execution of them in payment of legacies, for
+since the reign of Henry I., the estate of one dying
+intestate, was subject to division by those succeeding<span class="pagenum"><a id="Page_314"></a>[314]</span>
+thereto, <i>pro anima ejus</i>.<a id="FNanchor_772" href="#Footnote_772" class="fnanchor">[26]</a> The church seemed best
+suited to make this division, for the benefit of the intestate’s
+soul and this finally gave rise to the grant of
+letters by the ordinary to the next of kin, from which
+the custom of issuing letters of administration no doubt
+arose, in after-times.<a id="FNanchor_773" href="#Footnote_773" class="fnanchor">[27]</a></p>
+
+<p>The church continued to execute the powers concerning
+wills and the estates of decedents—and this is no
+doubt the reason why Glanville and Bracton do not
+treat at length of wills, further than to mention the
+custom, in certain boroughs, of devising land by will<a id="FNanchor_774" href="#Footnote_774" class="fnanchor">[28]</a>—until
+the people complained of oppression by the
+bishops and ordinaries in the exaction of fines for probating
+wills, when the statute of 31 Edward III., was
+enacted, giving the justices of the king’s court jurisdiction
+to enquire into such exactions and oppressions,
+either at the instance of the king, or that of the injured
+person.<a id="FNanchor_775" href="#Footnote_775" class="fnanchor">[29]</a></p>
+
+<p>Having thus assumed the jurisdiction over the estates
+of deceased persons, by this statute, which was
+the entering wedge to oust the jurisdiction of the ecclesiastical
+courts, in the gradual processes of time, the
+courts learned in the law, instead of those concerned
+only about spiritual affairs, assumed larger control
+and jurisdiction over the estates of decedents. While
+the church retained control over the estates of decedents,
+the bishop exercised practically the same authority
+that the probate judge exercises under our law, in
+the granting of letters of administration, the listing<span class="pagenum"><a id="Page_315"></a>[315]</span>
+and inventorying of the property and the accounting
+by the trustee to the ordinary, granting the letters of
+administration.<a id="FNanchor_776" href="#Footnote_776" class="fnanchor">[30]</a></p>
+
+<p>From the delegation of the trust to some personal
+friend to carry out the will of the decedent, the clergy,
+in compelling fidelity in the performance of the trust,
+no doubt developed that particular kind of a trustee
+known to our law of today as an executor or administrator
+and with the appearance of this legal personality,
+the devise may be said to first legally assume
+the dignity analogous to our present testamentary devise.<a id="FNanchor_777" href="#Footnote_777" class="fnanchor">[31]</a></p>
+
+<p>One of the earliest wills, with executors, that the
+older books refer to, is that of King Henry II.,<a id="FNanchor_778" href="#Footnote_778" class="fnanchor">[32]</a> made at
+Waltham, in the year 1182 in the presence of ten witnesses,
+among whom we note the name of Ranulf Glanville,
+his justiciar, the author of the first English law
+book. The English bishops and Glanville were to make
+division among the religious houses of five thousand
+marks; Norman bishops were to make division of certain
+sums among Norman elemosinary institutions;
+his sons were charged with the distribution of a fund
+to be expended in providing marriages for poor free
+women; God’s curse was invoked upon all those who
+violate his laws and the Pope was said to have confirmed
+the devise, no doubt because all the legacies were
+for pious purposes. The will, however, had executors,<a id="FNanchor_779" href="#Footnote_779" class="fnanchor">[33]</a>
+for one set of the trustees looked after the English
+behests; another set after the Norman legacies; others,<span class="pagenum"><a id="Page_316"></a>[316]</span>
+still, those left to institutions in Maine and Anjou, and
+all of these several executors, save only Glanville, were
+from among the clergy, and this evidences the high
+regard in which this monarch held his learned justiciar.</p>
+
+<p>But few of the thirteenth century wills have come
+down to us, although we have an ampler supply in the
+fourteenth century. In the thirteenth century, the will
+was usually made in Latin and wills written in the
+English language first began to appear generally in
+the second half of the fourteen century.<a id="FNanchor_780" href="#Footnote_780" class="fnanchor">[34]</a></p>
+
+<p>In the year 1268, or the 53 year of Henry III., William
+de Beauchamp executed a will<a id="FNanchor_781" href="#Footnote_781" class="fnanchor">[35]</a> that looks very like
+the modern documents, except that it only provided for
+specific legacies and behests of personalty other
+than to the church. It provided that his horse, fully
+harnessed, with all military caparisons, should precede
+the hearse bearing his corpse; provided for masses for
+his soul; gave a house to the church for his own soul
+and that of his wife; a behest to his son, Walter, to
+defray his expenses in a pilgrimage to the holy-land;
+to his daughter, Joane, a canopy and a book of Lancelot;
+a silver cup to his daughter Isabel, rings for his
+friends, with small legacies to others and a house for
+the church, are the principal features of this ancient
+will. The testator finally closed this interesting old
+will, in the following form:</p>
+
+<div class="blockquote">
+
+<p>“And I appoint my eldest son, William, Earl of
+Warwick, Sir Roger Mortimer, Sir Bartholomew de
+Sudley, and the Abbots of Evesham and of Great
+Malverne, my executors.”</p>
+
+</div>
+
+<p><span class="pagenum"><a id="Page_317"></a>[317]</span></p>
+
+<p>So here we have, in modern form, the recognition of
+the custom to appoint executors, by testamentary devise,
+just as today.</p>
+
+<p>Primogeniture, under the feudal law of the middle
+ages, in England, created the necessity for wills of real
+estate, for although all children of the Germanic races
+took equally and this was true, at Rome, under the
+feudal law all the children were practically disinherited
+in favor of the eldest son; some method of devising the
+estate to the eldest son was essential, on the part of
+the testator of real estate, so the Clergy adopted the
+Roman will as the instrument for accomplishing the
+purpose and thus it is sometimes called “an accidental
+fruit of feudalism.”<a id="FNanchor_782" href="#Footnote_782" class="fnanchor">[36]</a></p>
+
+<p>The liberty taken by the Church with the estates of
+deceased persons was a matter of such scandal and
+oppression, during the reigns of Henry III. and Edward
+II., that Parliament on several occasions imposed
+rules for the government of the bishops in the administration
+of the estates of intestates. Executors were
+required, during the reign of Henry III., to make a
+true inventory of the property of the deceased, and
+exhibit it to credible persons, acquainted with the
+property of the deceased,<a id="FNanchor_783" href="#Footnote_783" class="fnanchor">[37]</a> and this is no doubt, the
+foundation for this provision of our modern law, requiring
+inventories, in such cases.</p>
+
+<p>During the reign of Edward IV. the <i>testamentum</i> and
+<i>ultima voluntas</i> came to be regarded in much the same
+legal aspect, although the former was the more solemn<span class="pagenum"><a id="Page_318"></a>[318]</span>
+act and the execution of the testament was always in
+accordance with the forms prescribed in the older
+law books and if these preliminaries were omitted it
+was but a mere <i>ultima voluntas</i>.<a id="FNanchor_784" href="#Footnote_784" class="fnanchor">[38]</a></p>
+
+<p>In the reign of Edward VI. the reformers of that
+period objected to the promiscuous use of wills by all
+classes, so an act was passed preventing the execution
+of wills by wives, <i>servi</i>, by minors under fourteen, by
+heretics, criminals, condemned to death, exile, or chains;
+those who did not dismiss their concubines before they
+were in extremis, people with two wives or husbands,
+libelers, prostitutes or procuresses and usurers. The
+indulgence was granted to those keeping concubines,
+however, and to those with two wives or husbands—perhaps
+because of the leniency with which such crimes
+were looked upon at this period—of disposing of their
+goods <i>in pias causas</i>, or for the relief of the poor, afflicted,
+for young women, the support of students and
+the reparation of highways.<a id="FNanchor_785" href="#Footnote_785" class="fnanchor">[39]</a></p>
+
+<p>Under the old law, the division of the decedent’s
+property, whether by will or otherwise, was one-third
+to his wife, a third to his children and the other third,
+the owner himself could dispose of. If no will was left,
+the wife and children took their one-third each and the
+rest was divided by the administrator. If no children
+survived, the widow took half and the owner could dispose
+of the other half, or, if the owner died intestate,
+the administrator disposed of the remaining half and
+the same was true, if there were no children, but a
+widow survived.<a id="FNanchor_786" href="#Footnote_786" class="fnanchor">[40]</a></p>
+
+<p><span class="pagenum"><a id="Page_319"></a>[319]</span></p>
+
+<p>The modern statutes of descents and distributions, in
+the United States, are no doubt founded upon the customs,
+which had taken the fixed form of law, at this
+early period of English history.</p>
+
+<p>In the written English wills that have come down to
+us, from the middle ages, we find the dispositions of
+property governed, largely, by the customs and laws
+of the period when the will was written and the forms
+and dispositions of property devised by these instruments
+is as varied as the imaginations and whims of the
+testators.</p>
+
+<p>The will of Guy de Beauchamp, Earl of Warwick,
+dated at Warwick Castle, Monday, next after the feast
+of St. James, the Apostle, 1315, provided for the interment
+of his body in the Abbey of Bordsley, without
+funeral pomp. To Alice, his wife, he left a portion of
+his plate, a crystal cup and half his bedding, with all
+the books in his chapel; to his daughters, he left the
+other half of his bedding, rings and jewels; to his son,
+Thomas, he left his best coat of mail, helmet and suit
+of harness, and to his son, John, he left his second best
+coat of mail, helmet and harness, and the remainder
+of his armour, bows, and other warlike implements were
+to remain in Warwick castle, for his heir.<a id="FNanchor_787" href="#Footnote_787" class="fnanchor">[41]</a></p>
+
+<p>Noticeable among the wills of the fourteenth century
+is the specific provision for the place and manner of the
+interment of the body of the deceased. The testators
+of this period of the world’s history, prompted by their
+superstition, wrote their wills as if they thought that
+the angel of the Lord, on the resurrection day, would<span class="pagenum"><a id="Page_320"></a>[320]</span>
+scan their wills, to find the place of their interment.
+They talked “of graves, of worms, and epitaphs,” just
+as the Great Bard makes the weak King Richard speak,
+who had naught to bequeath, save his deposed body
+“to the ground.”<a id="FNanchor_788" href="#Footnote_788" class="fnanchor">[42]</a></p>
+
+<p>We find that old John of Gaunt, Duke of Lancaster,
+in 1399, directs, in his will,<a id="FNanchor_789" href="#Footnote_789" class="fnanchor">[43]</a></p>
+
+<div class="blockquote">
+
+<p>“If I die out of London, I desire that the night my
+body arrives there it be carried direct to the Friars
+Carmelites, in Fleet Street, and the next day be taken
+straight to St. Paul’s, and that it be not buried for
+forty days, during which I charge my executors that
+there be no embalming of my corpse.”</p>
+
+</div>
+
+<p>Sir Walter Manney, on St. Andrew’s day, in 1371,
+in London, provided for his interment, “at God’s
+pleasure,” in the midst of the Quire of the Carthusians,
+near Smithfield, in the suburbs of London, without any
+great pomp. He directed twenty masses be said for
+his soul and that every poor person attending his
+funeral, be given a penny to say a prayer for his soul
+and the remission of his sins. He left ten pounds to
+his sister, the nun, Mary; left a provision for each of
+his two bastard daughters and to his dear wife, the
+plate which he bought of Robert Francis, also a girdle
+of gold, a garter of gold and all of his beds and girdles,
+except his folding bed, which he left to his daughter of
+Pembroke. He willed that a tomb of alabaster with
+his own image thereon, as a knight and his arms thereon
+should be constructed, like unto that of Sir John
+Beauchamp, at Paul’s London, and that prayers should
+be said for his soul and also for that of Alice de Henalt,<span class="pagenum"><a id="Page_321"></a>[321]</span>
+the Countess Marshal and Sir Guy Bryan, Knt., was
+appointed executor of his will.<a id="FNanchor_790" href="#Footnote_790" class="fnanchor">[44]</a></p>
+
+<p>Queen Katherine of Aragon, wife of Henry VIII.,
+who died in 1536, after providing for the burial of
+her body in the Convent of Observant Friars, supplicated
+the King in her last will,<a id="FNanchor_791" href="#Footnote_791" class="fnanchor">[45]</a> to return the property
+that she had brought to him from Spain, out of which
+she stipulated for the payment of the annual wages
+due her physician, her druggist, her laundress, goldsmith
+and tailor; she left the collar of gold she had
+brought from Spain to her daughter and provided for
+masses for her soul and legacies to different priests
+and lady friends.</p>
+
+<p>Harris, in his recent book on “Ancient, Curious and
+Famous Wills,”<a id="FNanchor_792" href="#Footnote_792" class="fnanchor">[46]</a> reproduces, verbatim, many curious
+and strange testaments, evidencing the weaknesses,
+humors, whims and caprices, and sometimes, even the
+vengeance of the various testators, whose wills he has
+collected.</p>
+
+<p>William Pym, for instance, a gentleman of Somerset,
+England, who crept to his long sleep of death on January
+10’, 1608, after providing for different charitable
+behests, thus speaks of his wife, in his will:<a id="FNanchor_793" href="#Footnote_793" class="fnanchor">[47]</a></p>
+
+<div class="blockquote">
+
+<p>“I give to Agnes, which I did a long time take for
+my wyfe—till she denyd me to be her husband, all
+though wee were marryd with my friends’ consent, her
+father, mother, and uncle at it; and now she sweareth
+she will neither love mee nor evyr bee perswaded to,
+by preechers, nor by any other, which hath happened
+within these few years. And Toby Andrewes, the beginner,<span class="pagenum"><a id="Page_322"></a>[322]</span>
+which I did see with mine own eyes when he
+did more than was fitting and this, by means of others,
+their abettors. I have lived a miserable life this six or
+seven years, and now I leve the revenge to God—and
+ten pounds to buy her a gret horse, for I could not,
+this menny years, please her, with one gret enough.”</p>
+
+</div>
+
+<p>Dispositions of property for the use and benefit of
+horses and other domestic animals are not uncommon,
+in the list of quaint and curious wills to be met with by
+the student of ancient testaments.</p>
+
+<p>Harris cites the curious will of a childless peasant,
+who died near Toulouse, in 1781, by the terms of which
+he left his house and land and other property to his
+riding horse, in these words:</p>
+
+<div class="blockquote">
+
+<p>“I declare that I appoint my russet cob my universal
+heir, and I desire that he may belong to my nephew,
+George.”</p>
+
+</div>
+
+<p>Upon the will being brought before the court for
+construction, it was held that the intent of the testator
+would be given effect and the horse and the bequests
+he had bestowed upon it, would go to the nephew named
+in the will.<a id="FNanchor_794" href="#Footnote_794" class="fnanchor">[48]</a></p>
+
+<p>Madame Dupuis, who died in 1677,<a id="FNanchor_795" href="#Footnote_795" class="fnanchor">[49]</a> left a legacy
+of a fixed amount to her executor, with a detailed menu
+for her cats, which her sister and niece were to visit
+three times a week to see that at least thirty sous a
+week were expended for their living and care.</p>
+
+<p>As an illustration of the generosity and magnanimity
+of certain Jews, the will of the wealthy Israelite,
+Pinedo, who died at Amsterdam, in the eighteenth<span class="pagenum"><a id="Page_323"></a>[323]</span>
+century, is not without interest. He left to the city of
+his adoption, five tons of gold; to every Christian
+church in Amsterdam and at the Hague, the sum of
+10,000 florins each; to each Christian orphanage in
+these two towns, 10,000 crowns; to the poor of Amsterdam,
+forty shiploads of peat; to his synagogue two
+and a half tons of gold; he lent to the government, at
+three per cent, ten tons of gold, on condition that the
+interest should be paid to the Jews domiciled at Jerusalem;
+he then left certain legacies to his wife and
+nephew and other members of his family and to every
+unmarried person of either sex, attending his funeral,
+100 florins; to every Christian priest at Amsterdam and
+the Hague, 100 crowns and to every sacristan, fifty
+crowns.<a id="FNanchor_796" href="#Footnote_796" class="fnanchor">[50]</a></p>
+
+<p>Space will not permit the long list of charitable and
+philanthropic devises that could be collated from ancient
+and mediaeval times, which many of the testators
+of today would do well to emulate.</p>
+
+<p>John Wardell, of London, by his will dated August
+29’, 1656, devised his tenement, called the “White
+Bear,” in trust, to light the travelers passing to and
+fro along the watersides.<a id="FNanchor_797" href="#Footnote_797" class="fnanchor">[51]</a></p>
+
+<p>Charles Jones, of Lincoln’s Inn, by will dated January
+17’, 1640, established a charitable trust for the
+maintenance of a house to be used as a hospital, near
+Pullhelly, for twelve poor men.<a id="FNanchor_798" href="#Footnote_798" class="fnanchor">[52]</a></p>
+
+<p>George Butler, of Coleshill, Warwickshire, by his
+testament dated September 2’, 1591, gave his house<span class="pagenum"><a id="Page_324"></a>[324]</span>
+in trust for the lodgment of “any poor travelers” who
+should desire lodgment, not to exceed one night.<a id="FNanchor_799" href="#Footnote_799" class="fnanchor">[53]</a></p>
+
+<p>And Valentine Goodman, of Hallaton, England, by
+his will in 1684, left eight hundred pounds to be invested
+and the interest spent for the benefit of the
+“most indigent, poorest, aged, decrepit, miserable
+paupers.”<a id="FNanchor_800" href="#Footnote_800" class="fnanchor">[54]</a></p>
+
+<p>Among the freakish wills collected by Harris, may be
+mentioned that of the nobleman of the house Du Chatelet,
+who died in 1280,<a id="FNanchor_801" href="#Footnote_801" class="fnanchor">[55]</a> and directed that one of the
+pillars of the church at Neufchateau should be hollowed
+out and his body stood upright therein, so that the
+vulgar might not walk upon his corpse.</p>
+
+<p>The strange request of the great English jurist,
+Jeremy Bentham,<a id="FNanchor_802" href="#Footnote_802" class="fnanchor">[56]</a> that his corpse might be embalmed
+and placed in his favorite chair at the banquet table
+of his friends, on all occasions of state, was carefully
+carried out by his friend, Dr. Southwood Smith. By
+some scientific process the body of the philosopher and
+law writer was preserved, by a French artist and in
+his usual suit of clothes, with his broad-brimmed sombrero
+and his favorite walking-stick, in his old armed-chair,
+the lifeless body of this gifted man graced the
+meetings of his friends, until it was removed by Dr.
+Smith to University College.</p>
+
+<p>The will of the great Bard of Avon, has been discussed
+so frequently that its terms are known to many,
+but as the last writing of the Poet, like everything connected
+with his life, it is always of interest to posterity.</p>
+
+<p><span class="pagenum"><a id="Page_325"></a>[325]</span></p>
+
+<p>The first paragraph of his will, along with the many
+other prayers and Bible references which he places in
+the mouths of his characters in the plays,<a id="FNanchor_803" href="#Footnote_803" class="fnanchor">[57]</a> evidences
+the Poet’s firm belief in Jesus Christ and the “life everlasting.”</p>
+
+<p>In the entailment of his real estate to the bodily
+heirs male of his daughters, this will evidences the
+most careful legal preparation and the conclusion is
+not unreasonable that the same discrimination which
+characterizes this disposition of his real estate and
+other property, recognized the futility of any attempted
+disposal of his literary productions, which lacked the
+attribute of property, in law, in England, until 1709.<a id="FNanchor_804" href="#Footnote_804" class="fnanchor">[58]</a></p>
+
+<p>His legacies to his sister and his nieces and nephews
+is characteristic of his deep affection for his own
+family; his benevolence is established by his bequests
+to the “poor of Stratford”; his good-fellowship and
+love for his friends by the many legacies for rings for
+his different friends; his indifference toward his wife,
+by the fact that he only left her his “second best bed,
+with the furniture,” while all his landed acquisitions,
+with his gold and silver plate and other property were
+distributed among his sisters, daughters, nieces and
+nephews and his trust and confidence in his daughter,
+Susanna Hall, and her husband, John Hall, is finally
+established by the fact that he made them his executors
+and trustees.<a id="FNanchor_805" href="#Footnote_805" class="fnanchor">[59]</a></p>
+
+<p>The wills of the statesmen and patriots of the past<span class="pagenum"><a id="Page_326"></a>[326]</span>
+century, in our own country are equally interesting
+with those of our brothers of yesterday across the sea.</p>
+
+<p>After leaving his land in Nova Scotia, with his books
+and the debts owing to him by his son, William Franklin,
+former Governor of the Jerseys, the great statesman,
+philosopher and patriot, Benjamin Franklin, referred
+to his son’s part in attempting to deprive him of
+his property, during the war, as an excuse for not leaving
+him more of his estate. He left his dwelling house
+and three new houses, printing office, silver plate and
+household goods, to his daughter, Sarah Bache, and her
+husband, in entirety with remainder to their heirs, “as
+tenants in common and not as joint tenants.”<a id="FNanchor_806" href="#Footnote_806" class="fnanchor">[60]</a> The
+picture of the king of France, set with four hundred
+and eight diamonds, he left to his daughter, with the
+admonition not to use the diamonds to make ornaments
+for herself, so as not to thereby “introduce the expensive,
+vain and useless pastime of wearing jewels in
+this country.” He desired his philosophical instruments
+in Philadelphia, to go to his ingenious friend,
+Francis Hopkinson, and by a codicil, he left his “fine
+crab-tree walking-stick” to his friend and “the friend
+of mankind, General Washington. If it were a sceptre,
+he has merited it and would become it. It was a present
+to me from that excellent woman, Madame de Forbach,
+the Dowager Duchess of Deux Ponts, connected
+with some verses, which go with it.” He left a bond to
+his son-in-law, on the condition that he manumit and
+set free his negro man. This great patriot and friend
+of mankind, like General Washington, in his last testament,
+therefore, registered his opposition to human<span class="pagenum"><a id="Page_327"></a>[327]</span>
+slavery, an institution that was to be finally abolished
+a half century later in the United States, through the
+efforts of the great “Emancipator.”</p>
+
+<p>The will of the great Chief Justice John Marshall,
+is declared by him to be “entirely in my own handwriting”;
+he left his estate equally to his only daughter
+and his five sons and accompanying the will is a splendid
+eulogy to his deceased wife, whom he characterized
+as the “most affectionate of mothers.”<a id="FNanchor_807" href="#Footnote_807" class="fnanchor">[61]</a></p>
+
+<p>The will of Captain Miles Standish, Longfellow’s
+hero, was made March 7’, 1656. He desired his just
+debts to “bee paied”; that his body should be “buried
+in Decent manor ... as near as conveniently
+may bee to my two daughters, Lora Standish, my
+daughter, and Mary Standish, my daughter-in-law.”
+His dear and loving wife, Barbara Standish, was left
+a third of his estate; forty pounds were left to each of
+four sons and to his son Josias, upon his marriage, he
+left “one young horse, five sheep and two heifers,”
+with his forty pound legacy, if his estate “will bear it
+att p’sent.” His friends, Mr. Timothy Hatherly and
+Capt. James Cudworth, were appointed “supervisors”
+of his will, for he knew that they would “be pleased to
+Doe the office of Christian love to bee healpfull to my
+poor wife and Children by their Christian Counsell and
+advice.”<a id="FNanchor_808" href="#Footnote_808" class="fnanchor">[62]</a></p>
+
+<p>The “Father of our Country,” General George
+Washington, left the bulk of his estate to his wife,
+Martha Washington, for life,<a id="FNanchor_809" href="#Footnote_809" class="fnanchor">[63]</a> with the “liquors and<span class="pagenum"><a id="Page_328"></a>[328]</span>
+groceries” on hand at his death, to dispose of as she
+saw fit. Upon her death he willed that all slaves owned
+by him, in his own right, should have their freedom and
+that the old and infirm and sick ones should be protected
+and maintained by his heirs so long as they lived
+and the younger ones educated and maintained the
+same as other poor children.</p>
+
+<p>He left the fifty shares in the Potomac Company,
+given him for his services in the Revolutionary War, to
+endow a University within the limits of the District of
+Columbia; some of his lands were distributed among
+the sons of his deceased brothers; his military and
+state papers were left to his nephew, Bushrod Washington;
+he recommitted the “box of oak that sheltered
+the great Sir William Wallace,” to the Earl of Beuban;
+to his brother, Charles, he left the gold headed cane
+left him by Dr. Franklin and among the “mementos
+of esteem and regard,” to his many friends, are a pair
+of pistols to General De La Fayette. He desired that
+in case of any dispute over his will that the disputants
+select each an arbitrator, the two thus selected to
+agree upon a third and the finding of any two as to
+his intentions, he desired to be “as binding upon the
+parties as if it had been given in the Supreme Court of
+the United States.”</p>
+
+<p>Like Washington, and many other of the patriots of
+the past century, William Penn prepared his own will,
+in 1718, so as to cause no little concern to his friend,
+James Logan, as to the different constructions that
+could be placed upon it.</p>
+
+<p>The Government of the Province of “Pennsylvania
+and territories thereto belonging,” he devised in trust<span class="pagenum"><a id="Page_329"></a>[329]</span>
+to the Earls of Oxford, Mortimer and Powelett, “and
+their heirs, upon trust, to dispose thereof to the Queen”
+or to any other person to the best advantage to carry
+out the object of the devise.</p>
+
+<p>He further devised to his wife, Hannah Penn; to
+her father, Thomas Callowhill; to his sister, Margaret
+Lowther; to his friends “Gilbert Heathcote Physitian,
+Samuel Waldenfield, John Field, Henry Gouldney, all
+living in England” and to his friends, Samuel Carpenter,
+Richard Hill, Isaac Norris, Samuel Preston and
+James Logan, “liveing in or near Pensilvania and their
+heires” all his lands, tenements and hereditaments,
+with “other profitts scituate, lyeing and being in Pensilvania
+and the territores thereunto belonging,” in trust,
+first for the payment of his debts, second, to convey
+10,000 acres each to the three children of his son, William,
+a like quantity to his daughter, Aubrey, and the
+rest to be divided among the children of his present
+wife, “in such proporcon and for such estates as my
+said wife shall think fit.” His wife was made executrix
+and all his personal estate was left to her.</p>
+
+<p>Penn was a man of far more than the ordinary
+ability and wisdom in the customary affairs of life, but
+as his friend, James Logan, foresaw, from the contents
+of this will, which left such a large and varied estate
+to so many people to convey, with so little instructions
+regarding his intentions, it is not strange that litigation
+covering a period of nine years should have resulted
+from such a testament.<a id="FNanchor_810" href="#Footnote_810" class="fnanchor">[64]</a></p>
+
+<p><span class="pagenum"><a id="Page_330"></a>[330]</span></p>
+
+<p>The searcher for the curious in testaments, will find
+wills in poetry as well as in prose, collated in Harris’
+Ancient Wills.</p>
+
+<p>William Jackett, of the parish of St. Mary, Islington,
+died in 1789 and his will in the following form was
+admitted to probate:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“I give and bequeath,</div>
+ <div class="verse indent0">When I’m laid underneath,</div>
+ <div class="verse indent0">To my two loving sisters most dear,</div>
+ <div class="verse indent0">The whole of my store,</div>
+ <div class="verse indent0">Were it twice as much more,</div>
+ <div class="verse indent0">Which God’s goodness has given me here.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">And that none may prevent</div>
+ <div class="verse indent0">This my will and intent,</div>
+ <div class="verse indent0">Or occasion the least of law-racket,</div>
+ <div class="verse indent0">With a solemn appeal</div>
+ <div class="verse indent0">I confirm, sign and seal</div>
+ <div class="verse indent0">This, the true act and deed of Will Jackett.”<a id="FNanchor_811" href="#Footnote_811" class="fnanchor">[65]</a></div>
+ </div>
+</div>
+</div>
+
+<p><span class="pagenum"><a id="Page_331"></a>[331]</span></p>
+
+<p>William Hicklington, who dubbed himself, the Poet
+of Pocklington, penned his will in rhyme, in 1770, as
+follows:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Do give and bequeath,</div>
+ <div class="verse indent0">As free as I breathe,</div>
+ <div class="verse indent0">To thee, Mary Jarum,</div>
+ <div class="verse indent0">The Queen of my Harum,</div>
+ <div class="verse indent0">My cash and my cattle,</div>
+ <div class="verse indent0">With every chattel,</div>
+ <div class="verse indent0">To have and to hold,</div>
+ <div class="verse indent0">Come heat or come cold,</div>
+ <div class="verse indent0"><i>Sans</i> hindrance or strife,</div>
+ <div class="verse indent0">Though thou art not my wife,</div>
+ <div class="verse indent0">As witness my hand,</div>
+ <div class="verse indent0">Just here as I stand,</div>
+ <div class="verse indent0">The twelfth of July,</div>
+ <div class="verse indent0">In the year seventy.”<a id="FNanchor_812" href="#Footnote_812" class="fnanchor">[66]</a></div>
+ </div>
+</div>
+</div>
+
+<p>Apropos this will, is the rhymed testament of the
+sacriligious Irishman, who, as the old books record, in
+this quatrain disposed of his earthly effects:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“In the name of God, Amen:</div>
+ <div class="verse indent0">My featherbed to my wife Jen;</div>
+ <div class="verse indent0">Also my carpenter’s saw and hammer;</div>
+ <div class="verse indent0">Until she marries; then, God damn her.”<a id="FNanchor_813" href="#Footnote_813" class="fnanchor">[67]</a></div>
+ </div>
+</div>
+</div>
+
+<p>This, however, suggests the “Will in literature,”
+and in turning over the pages of the work above referred
+to, the “Lesser Testament,” of the plaintive
+poet, Francois Villon, who died in 1484, is not without
+interest.</p>
+
+<p>His gloves and silken hood are bequeathed to a friend
+in the following verse;</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Item, my gloves and silken hood</div>
+ <div class="verse indent0">My friend Jacques Cardon, I declare,</div>
+ <div class="verse indent0">Shall have in fair free gift for good;</div>
+ <div class="verse indent0">Also the acorns willows bear</div>
+ <div class="verse indent0">And every day a capon fair</div>
+ <div class="verse indent0">Or goose; likewise a tenfold vat</div>
+ <div class="verse indent0">Of chalk-white wine, besides a pair</div>
+ <div class="verse indent0">Of Lawsuits, lest he wax too fat.”</div>
+ </div>
+</div>
+</div>
+
+<p><span class="pagenum"><a id="Page_332"></a>[332]</span></p>
+
+<p>He desired his friends to record of him in his epitaph:</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Acre or furrow had he none.</div>
+ <div class="verse indent0">’Tis known his all he gave away;</div>
+ <div class="verse indent0">Bread, tables, tressels, all are gone,</div>
+ <div class="verse indent0">Gallants, of him this Roundel say.”<a id="FNanchor_814" href="#Footnote_814" class="fnanchor">[68]</a></div>
+ </div>
+</div>
+</div>
+
+<p>Among the wills in fiction and poetry, collated by Mr.
+Harris, in his recent work,<a id="FNanchor_815" href="#Footnote_815" class="fnanchor">[69]</a> are those of Olivia, in
+Twelfth Night; that of Don Quixote; the wills of
+Dickens, George Eliot, Dumas and other English
+writers. But it is not the object of this chapter to deal
+with wills in fiction, since testaments are founded in
+certainties, as real as life and death themselves. We
+have always made our wills in pursuance of a natural
+inclination, associated with the idea of property and
+intimately connected with the ties that bind us here
+on earth. As Hazlitt said, a century ago:</p>
+
+<div class="blockquote">
+
+<p>“We consign our possessions to our next of kin, as
+mechanically as we lean our heads on the pillow and go<span class="pagenum"><a id="Page_333"></a>[333]</span>
+out of the world in the same state of stupid amazement
+that we came into it.”</p>
+
+</div>
+
+<p>And as certain as we are to die, so certainly do we
+owe it to ourselves and to those who are the objects
+of our bounty, to provide for the proper disposition
+of our acquisitions, even as the men and women of
+antiquity did, before they pressed the pillow for the
+last time.</p>
+
+<p>The hands that wrote the wills referred to in the
+foregoing pages have been stilled with the silence of
+the centuries, e’en as the fingers that wove the figures
+in your antique rug; the voice that expressed the
+dying intent of the testator, like the nightingale that
+sang among the trees—ah, “whither hath it gone again,
+who knows” can be heard again no more. Like scattered
+threads from the warp and woof of the lives from which
+these skeins are taken, each age-scented document
+marks the close of a human life and the fact that other
+lives have fallen, like the leaves from trees, but emphasizes
+the pathos of our lives, since humanity, as one
+man, with a universal agony still strives and strains
+“to gain the goal where agonies shall cease to be.”
+Streams have been wept into the vast ocean of time
+since the first will and testament was made by dying
+man.</p>
+
+<div class="blockquote">
+
+<p>“A myriad races came and went; this Sphinx hath
+seen them come and go.”</p>
+
+</div>
+
+<p>True, a human life, is but “a drop in ocean’s boundless
+tide,” but as truly said by Burton:<a id="FNanchor_816" href="#Footnote_816" class="fnanchor">[70]</a></p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“Our deaths are twain; the Deaths we see</div>
+ <div class="verse indent6">Drop like the leaves in windy Fall;</div>
+ <div class="verse indent0">But ours, our own, are ruined worlds, a globe</div>
+ <div class="verse indent6">Collapst, last end of all.</div><span class="pagenum"><a id="Page_334"></a>[334]</span>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">We live our lives with rogues and fools,</div>
+ <div class="verse indent6">Dead and alive, alive and dead,</div>
+ <div class="verse indent0">We die ’twixt one who feels the pulse and</div>
+ <div class="verse indent6">One who frets and clouds the head.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">Hardly we learn to wield the blade, before</div>
+ <div class="verse indent6">The wrist grows stiff and old;</div>
+ <div class="verse indent0">Hardly we learn to ply the pen, ere Thought</div>
+ <div class="verse indent6">And Fancy faint with cold.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">And still the weaver plies his loom, whose</div>
+ <div class="verse indent6">Warp and woof is wretched Man</div>
+ <div class="verse indent0">Weaving th’ unpattern’d dark design, so dark</div>
+ <div class="verse indent6">We doubt it owns a plan.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">But ah, what vaileth man to mourn; shall</div>
+ <div class="verse indent6">Tears bring forth what smiles ne’er brought;</div>
+ <div class="verse indent0">Shall brooding breed a thought of joy? Ah</div>
+ <div class="verse indent6">Hush the sigh, forget the thought.</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">Silence thine immemorial quest, contain</div>
+ <div class="verse indent6">Thy nature’s vain complaint</div>
+ <div class="verse indent0">None heeds, none cares for thee or thine;</div>
+ <div class="verse indent6">Like thee how many came and went.</div>
+ </div>
+ <div class="stanza">
+ <div class="center">...</div>
+ </div>
+ <div class="stanza">
+ <div class="verse indent0">Wend now thy way, with brow serene, fear</div>
+ <div class="verse indent6">Not thy humble tale to tell:—”</div>
+ <div class="verse indent0">’Tis wisdom’s part to make thy will;</div>
+ <div class="verse indent6">The testament is not death’s knell.</div>
+ </div>
+</div>
+</div>
+
+<div class="footnotes">
+
+<h3>FOOTNOTES:</h3>
+
+<div class="footnote">
+
+<p><a id="Footnote_747" href="#FNanchor_747" class="label">[1]</a> 1 Redfield, on Wills, Ch. II., p. 4; 2 Bl. Comm. 499.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_748" href="#FNanchor_748" class="label">[2]</a> Redfield, on Wills, Ch. I., p. 1; Harris, Ancient Wills. Introd. XII.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_749" href="#FNanchor_749" class="label">[3]</a> Judge John F. Philips advised the writer that an opinion was
+prepared by a member of the federal court and submitted to him
+for his concurrence when he was on the bench, in a case similar to
+that referred to in the text, but it was changed when the attention
+of the writer was called to the existing facts, which the opinion
+failed to note. It is to be regretted that historians and law writers
+cannot so amend their works.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_750" href="#FNanchor_750" class="label">[4]</a> Harris, Ancient Wills, p. 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_751" href="#FNanchor_751" class="label">[5]</a> Plutarch’s Life of Solon; IV. Kent’s Comm. 503.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_752" href="#FNanchor_752" class="label">[6]</a> Chitty’s note, to 2 B. Comm. 491.</p>
+
+<p>The reason for recognizing, in law, a right of disposition of
+property by will, is the same as the law governing the descent
+and distribution, in case of intestacy. If there were no such provision,
+on the vacancy of the property, on the death of the last
+owner, an unseemly scramble would result, which would be both
+undesirable and contrary to a sound public policy. “Title,” or
+authority to make a will, is thus based upon the social instinct and
+both wills and intestacy statutes are in furtherance of this purpose.
+The owner, in case of a testamentary devise and the State, in case
+of intestacy, as a mediary, accomplish practically the same purpose,
+in the division of property, the prevention of a vacancy and the
+failure of the social instinct, which furnishes the foundation for
+society and order. (See interesting Essay by Professor Bigelow, in
+III. Essays in Anglo-American Legal History, pp. 776, 778.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_753" href="#FNanchor_753" class="label">[7]</a> Genesis, Ch. XV.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_754" href="#FNanchor_754" class="label">[8]</a> Genesis, 48 and 49 Chapters.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_755" href="#FNanchor_755" class="label">[9]</a> Harris, Ancient Wills, p. 12.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_756" href="#FNanchor_756" class="label">[10]</a> I. Reeve’s History English Law, 313; II. Pollock and Maitland’s
+History English Law, p. 314.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_757" href="#FNanchor_757" class="label">[11]</a> Harris, Ancient Wills, p. 13.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_758" href="#FNanchor_758" class="label">[12]</a> Harris, Ancient Wills, p. 14.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_759" href="#FNanchor_759" class="label">[13]</a> Harris, Ancient Wills, pp. 15, 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_760" href="#FNanchor_760" class="label">[14]</a> Harris, Ancient Wills, p. 16.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_761" href="#FNanchor_761" class="label">[15]</a> 2 Bl. Comm. 491.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_762" href="#FNanchor_762" class="label">[16]</a> 32 &amp; 34 Henry VIII.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_763" href="#FNanchor_763" class="label">[17]</a> I. Redfield, on Wills, sec. 4, p. 2; II. Pollock and Maitland’s
+History English Law, p. 315; IV. Reeve’s History English Law,
+510, 511.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_764" href="#FNanchor_764" class="label">[18]</a> II. Pollock and Maitland’s History English Law, pp. 316, 317.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_765" href="#FNanchor_765" class="label">[19]</a> II. Pollock and Maitland’s History English Law, p. 322.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_766" href="#FNanchor_766" class="label">[20]</a> <i>Ante idem.</i>, p. 323.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_767" href="#FNanchor_767" class="label">[21]</a> II. Pollock and Maitland’s History English Law, pp. 325, 326.</p>
+
+<p>The statute of wills ordained that all persons having manors,
+lands, tenements or hereditaments could give and dispose of them, as
+well by last will, or testament in writing, as by any act executed
+in their lifetime. (IV. Reeve’s History English Law, p. 374.)</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_768" href="#FNanchor_768" class="label">[22]</a> II. Pollock and Maitland’s History English Law, p. 326.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_769" href="#FNanchor_769" class="label">[23]</a> II. Pollock and Maitland’s History English Law, p. 327.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_770" href="#FNanchor_770" class="label">[24]</a> <i>Ante idem.</i>; Beame’s Glanville, p. 118.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_771" href="#FNanchor_771" class="label">[25]</a> I. Reeve’s History English Law, p. 313.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_772" href="#FNanchor_772" class="label">[26]</a> I. Reeve’s History English Law, p. 313.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_773" href="#FNanchor_773" class="label">[27]</a> I. Reeve’s History English Law, p. 314.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_774" href="#FNanchor_774" class="label">[28]</a> III. Reeve’s History English Law, 215.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_775" href="#FNanchor_775" class="label">[29]</a> III. Reeve’s History English Law, 125.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_776" href="#FNanchor_776" class="label">[30]</a> IV. Reeve’s History English Law, 123, 124.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_777" href="#FNanchor_777" class="label">[31]</a> II. Pollock and Maitland’s History English Law, p. 335.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_778" href="#FNanchor_778" class="label">[32]</a> Nicholas’ “Testamenta Vetusta.”</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_779" href="#FNanchor_779" class="label">[33]</a> II. Pollock and Maitland’s History English Law, pp. 334, 335.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_780" href="#FNanchor_780" class="label">[34]</a> II. Pollock and Maitland’s History English Law, p. 337.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_781" href="#FNanchor_781" class="label">[35]</a> Harris, Ancient Wills, p. 22.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_782" href="#FNanchor_782" class="label">[36]</a> Maine, Ancient Law, ch. 7, p. 217; III. Essays in Anglo-American
+Legal History, pp. 780, 781.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_783" href="#FNanchor_783" class="label">[37]</a> IV. Reeve’s History English Law, p. 115.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_784" href="#FNanchor_784" class="label">[38]</a> IV. Reeve’s History English Law, 117.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_785" href="#FNanchor_785" class="label">[39]</a> V. Reeve’s History English Law, pp. 81, 82.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_786" href="#FNanchor_786" class="label">[40]</a> V. Reeve’s History English Law, p. 82.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_787" href="#FNanchor_787" class="label">[41]</a> Harris, Ancient Wills, p. 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_788" href="#FNanchor_788" class="label">[42]</a> King Richard II., Act II., Scene I.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_789" href="#FNanchor_789" class="label">[43]</a> Harris, Ancient Wills, p. 25.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_790" href="#FNanchor_790" class="label">[44]</a> Harris, Ancient Wills, p. 29.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_791" href="#FNanchor_791" class="label">[45]</a> Harris, Ancient Wills, p. 39.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_792" href="#FNanchor_792" class="label">[46]</a> Published by Little, Brown &amp; Co., 1911.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_793" href="#FNanchor_793" class="label">[47]</a> Harris, Ancient Wills, p. 87.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_794" href="#FNanchor_794" class="label">[48]</a> Harris, Ancient Wills, p. 94.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_795" href="#FNanchor_795" class="label">[49]</a> <i>Ante idem.</i>, 101.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_796" href="#FNanchor_796" class="label">[50]</a> Schutt’s Memorabilia Judaica, lib. iv, cap. 18.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_797" href="#FNanchor_797" class="label">[51]</a> Harris, Ancient Wills, p. 105.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_798" href="#FNanchor_798" class="label">[52]</a> <i>Ante idem.</i>, p. 105.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_799" href="#FNanchor_799" class="label">[53]</a> <i>Ante idem.</i>, p. 107.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_800" href="#FNanchor_800" class="label">[54]</a> <i>Ante idem.</i>, p. 111.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_801" href="#FNanchor_801" class="label">[55]</a> <i>Ante idem.</i> p. 123.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_802" href="#FNanchor_802" class="label">[56]</a> <i>Ante idem.</i> p. 139.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_803" href="#FNanchor_803" class="label">[57]</a> For collection of the many beautiful prayers in the plays, see
+the interesting book by Mary A. Wadsworth, “Shakespeare and
+Prayer,” by The Welch Publishing Co., Chicago.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_804" href="#FNanchor_804" class="label">[58]</a> White’s “Law in Shakespeare,” p. 5.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_805" href="#FNanchor_805" class="label">[59]</a> Harris, Ancient Wills, pp. 305, 309.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_806" href="#FNanchor_806" class="label">[60]</a> Harris, Ancient Wills, p. 369.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_807" href="#FNanchor_807" class="label">[61]</a> Harris, Ancient Wills, p. 407.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_808" href="#FNanchor_808" class="label">[62]</a> Harris, Ancient Wills, p. 427.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_809" href="#FNanchor_809" class="label">[63]</a> Harris, Ancient Wills, p. 439.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_810" href="#FNanchor_810" class="label">[64]</a> Dixon’s “Life of Penn”; Stoughton’s “William Penn”; Harris,
+Ancient Wills, p. 291.</p>
+
+<p>The will of Penn, and other of the earlier patriots of the United
+States who drew their own wills, in such manner as to cause
+protracted litigation, suggests the old poem, tuned to the toast of
+a century ago, “The lawyer’s best friend—the man who makes his
+own will,” inscribed to “The jolly testator who makes his own will.”</p>
+
+<div class="poetry-container">
+<div class="poetry">
+ <div class="stanza">
+ <div class="verse indent0">“He premises his wish and his purpose to save</div>
+ <div class="verse indent0">All dispute among friends when he’s laid in his grave;</div>
+ <div class="verse indent0">Then he straightway proceeds more disputes to create</div>
+ <div class="verse indent0">Than a long summer’s day would give time to relate.</div>
+ <div class="verse indent0">He writes and erases, he blunders and blots,</div>
+ <div class="verse indent0">He produces such puzzles and Gordian knots,</div>
+ <div class="verse indent0">That a lawyer, intending to frame the thing ill,</div>
+ <div class="verse indent0">Couldn’t match the testator who makes his own will.</div>
+ <div class="center">...</div>
+ <div class="verse indent0">You had better pay toll when you take to the road,</div>
+ <div class="verse indent0">Than attempt by a by-way to reach your abode;</div>
+ <div class="verse indent0">You had better employ a conveyancer’s hand,</div>
+ <div class="verse indent0">Than encounter the risk that your will shouldn’t stand.</div>
+ <div class="verse indent0">From the broad beaten track, when the traveler strays,</div>
+ <div class="verse indent0">He may land in a bog, or be lost in a maze;</div>
+ <div class="verse indent0">And the law, when defied, will avenge itself still,</div>
+ <div class="verse indent0">On the man and the woman who make their own will.”</div>
+ </div>
+</div>
+</div>
+
+<p>For reproduction of this quaint poem in full, see, Harris, Ancient
+Wills, p. 209.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_811" href="#FNanchor_811" class="label">[65]</a> Harris, Ancient Wills, p. 67.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_812" href="#FNanchor_812" class="label">[66]</a> Harris, Ancient Wills, p. 67.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_813" href="#FNanchor_813" class="label">[67]</a> <i>Ante idem.</i> 68.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_814" href="#FNanchor_814" class="label">[68]</a> Harris, Ancient Wills, p. 64.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_815" href="#FNanchor_815" class="label">[69]</a> Harris, Ancient Wills, pp. 49, 62.</p>
+
+<p>This bequest of Francois Villon, may have suggested to Mr. Williston
+Fish of Chicago, the “Insane Man’s Will,” published in
+Harper’s Weekly, in 1898, wherein he makes an imaginary will
+that has become a classic in English literature, among the bequests
+being “all good little words of praise and encouragement,” to good
+fathers and mothers, in trust for their children; to children, subject
+to the rights of lovers, he devises, the flowers, the banks of
+brooks, the blossoms of the woods, the golden sands and waters of
+the brooks, the white clouds floating high over the giant trees and
+the Milky Way, to wonder at, at night; to lovers, he devises the
+imaginary world, with the stars in the sky, the red roses by the
+wall, the sweet strains of music and all else by which they may
+figure to each other the lastingness and beauty of their love. To
+those no longer children or lovers, he bequeaths the pleasures of
+sweet memories, the poems of Burns and Shakespeare and other
+poets, and to those with snowy crowns he leaves the happiness of
+old age, with the love and gratitude of their children, until they
+fall asleep.</p>
+
+</div>
+
+<div class="footnote">
+
+<p><a id="Footnote_816" href="#FNanchor_816" class="label">[70]</a> “The Kasidah.”</p>
+
+</div>
+
+</div>
+
+<hr class="chap x-ebookmaker-drop">
+
+<div class="chapter">
+
+<p><span class="pagenum"><a id="Page_335"></a>[335]</span></p>
+
+<h2 class="nobreak" id="INDEX">INDEX.</h2>
+
+<p class="center"><i>References are to Pages</i></p>
+
+</div>
+
+<ul>
+
+<li class="ifrst">A</li>
+
+<li class="indx">Abjuration, in case of sanctuary, <a href="#Page_250">250</a>.</li>
+
+<li class="indx">Adonijah, sanctuary claimed by, <a href="#Page_245">245</a>, <a href="#Page_246">246</a>.</li>
+
+<li class="indx">Adulteress, lost dower, in England, <a href="#Page_26">26</a>.</li>
+
+<li class="indx">Agrippina, her marriage to Claudius, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Alcibiades, recall of, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Alexander III., decree concerning consent marriages, <a href="#Page_22">22</a>.</li>
+
+<li class="indx">Alfred, administration of justice under, <a href="#Page_89">89</a>, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Alfred, jury trials under, <a href="#Page_151">151</a>.</li>
+
+<li class="indx">Alfred, sanctuary under, <a href="#Page_251">251</a>.</li>
+
+<li class="indx">Alfred, wager of law, under, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Amber witch, <a href="#Page_71">71</a>.</li>
+
+<li class="indx" id="Ancient_punishments">Ancient punishments (see <a href="#Punishment">punishment</a>), <a href="#Page_273">273</a>, <a href="#Page_306">306</a>.</li>
+
+<li class="indx">Anglo-Saxon courts, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Anglo-Saxon law against witchcraft, <a href="#Page_49">49</a>.</li>
+
+<li class="indx">Anglo-Saxon wills, <a href="#Page_312">312</a>.</li>
+
+<li class="indx">Anglo-Saxons, judicial recall under, <a href="#Page_88">88</a>, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Anglo-Saxons, recognized sale-marriages, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Animals, wills to, <a href="#Page_322">322</a>.</li>
+
+<li class="indx">Appellee, meaning of, in trial by battle, <a href="#Page_115">115</a>.</li>
+
+<li class="indx">Approver, in trials for felony charges, <a href="#Page_117">117</a>.</li>
+
+<li class="indx">Aristeides, recall of, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Aristotle, on judicial recall, <a href="#Page_82">82</a>, <a href="#Page_86">86</a>.</li>
+
+<li class="indx">Aristotle, will of, <a href="#Page_310">310</a>.</li>
+
+<li class="indx">Arrowsmith, case of, Anthony, <a href="#Page_183">183</a>.</li>
+
+<li class="indx">Arthur, king, and Flollo, trial by battle between, <a href="#Page_127">127</a>.</li>
+
+<li class="indx">Ashford, trial by battle with Thornton, <a href="#Page_133">133</a>.</li>
+
+<li class="indx">Assize, a substitute for battle, under Henry II., <a href="#Page_119">119</a>.</li>
+
+<li class="indx">Assyrian marriages, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Astrology in mediaeval times, <a href="#Page_49">49</a>.</li>
+
+<li class="indx">Athelstan, laws of, governing ordeals, <a href="#Page_149">149</a>.</li>
+
+<li class="indx">Athelstan, sanctuary, under, <a href="#Page_252">252</a>.</li>
+
+<li class="indx">Athenian judges, recall of, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Athens, recall in, <a href="#Page_81">81</a>.</li>
+
+<li class="indx">Attainder, standing mute to avoid, <a href="#Page_173">173</a>.</li>
+
+<li class="indx">Aunts and nephews, marriages between, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Authorities upon witchcraft, <a href="#Page_70">70</a>.</li>
+
+<li class="ifrst">B</li>
+
+<li class="indx">Babylon, effect of recall in, <a href="#Page_103">103</a>, <a href="#Page_104">104</a>.</li>
+
+<li class="indx">Babylon marriages, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Babylon, trials in ancient, <a href="#Page_79">79</a>.</li>
+
+<li class="indx">Babylon, wager of law, in ancient, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Babylonian judges <a href="#Footnote_159">(note), 74</a>.</li>
+
+<li class="indx">Balance, ordeal by, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Banishment, in ancient Greece, <a href="#Page_82">82</a>.</li>
+
+<li class="indx">Banns, custom of, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Banns, legal advantages of, <a href="#Page_22">22</a>.</li>
+
+<li class="indx">Barabas, release of, by Pilate, <a href="#Page_102">102</a>.</li>
+
+<li class="indx" id="Battle">Battle, trial by, <a href="#Page_109">109</a>, <a href="#Page_140">140</a>.</li>
+
+<li class="indx">Battle, origin of trial by, <a href="#Page_109">109</a>.</li>
+
+<li class="indx">Battle, traced to ancient periods, <a href="#Page_109">109</a>.</li>
+
+<li class="indx">Battle, regulated by Burgundians, 501 A. D., <a href="#Page_111">111</a>.</li>
+
+<li class="indx">Battle, regulated by Otho, in 983 A. D., <a href="#Page_112">112</a>.</li>
+
+<li class="indx">Battle, adjudged legal method of trial by Ld. Ellenborough, <a href="#Page_133">133</a>.</li>
+
+<li class="indx">Battle, intended to prevent perjury, when established, <a href="#Page_112">112</a>.</li>
+
+<li class="indx">Battle, London exempted from, by charter, <a href="#Page_119">119</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_336"></a>[336]</span>Battle by use of “Approvers”, <a href="#Page_117">117</a>.</li>
+
+<li class="indx">Battle, under military form, <a href="#Page_125">125</a>, <a href="#Page_126">126</a>.</li>
+
+<li class="indx">Battle, in case William of Eu, <a href="#Page_126">126</a>.</li>
+
+<li class="indx">Battle, in finance, <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Battle, in trials on debt, <a href="#Page_119">119</a>.</li>
+
+<li class="indx">Battle, under writ of right, in full, <a href="#Page_120">120</a>, <a href="#Page_122">122</a>.</li>
+
+<li class="indx">Battle, trial before Henry III., <a href="#Page_129">129</a>.</li>
+
+<li class="indx">Battle, trial before Henry VI., <a href="#Page_131">131</a>.</li>
+
+<li class="indx">Battle, discouraged by Edward III., <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Battle, trial by, before Henry VII., <a href="#Page_132">132</a>.</li>
+
+<li class="indx">Battle, under felony charge, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Battle, superceded by assize, under Henry II., <a href="#Page_119">119</a>.</li>
+
+<li class="indx">Battle, under charge of treason, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Battle between Hereford and Norfolk, <a href="#Page_130">130</a>.</li>
+
+<li class="indx">Battle, introduced into England by Normans, <a href="#Page_114">114</a>.</li>
+
+<li class="indx">Battle, between King Arthur and Flollo, <a href="#Page_127">127</a>.</li>
+
+<li class="indx">Battle for treason, under Priscot, C. J., in reign of Henry VI., <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Battle, effect of chivalry upon, <a href="#Page_113">113</a>.</li>
+
+<li class="indx">Battle under writ of right, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Battle, trial before Edward III., <a href="#Page_129">129</a>.</li>
+
+<li class="indx">Battle between Essex and Montford, <a href="#Page_128">128</a>.</li>
+
+<li class="indx">Battle, under Queen Elizabeth, <a href="#Page_132">132</a>.</li>
+
+<li class="indx">Battle between men and women, in Germany, <a href="#Page_127">127</a>.</li>
+
+<li class="indx">Battle, abolished by St. Louis, in France, in 1260, <a href="#Page_134">134</a>.</li>
+
+<li class="indx">Battle, abolished by 59’ George III., <a href="#Page_134">134</a>.</li>
+
+<li class="indx">Battle, used by Chaucer, <a href="#Page_135">135</a>.</li>
+
+<li class="indx">Battle, Shakespeare’s references to, <a href="#Page_136">136</a>, <a href="#Page_137">137</a>.</li>
+
+<li class="indx">Battle, reference of Scott, to, <a href="#Page_137">137</a>, <a href="#Page_138">138</a>.</li>
+
+<li class="indx">Battle, referred to, by Thackeray, <a href="#Page_139">139</a>.</li>
+
+<li class="indx">Beccaria, his views on punishment, <a href="#Page_274">274</a>.</li>
+
+<li class="indx">Beheading, punishment by, <a href="#Page_276">276</a>.</li>
+
+<li class="indx">Bekker’s work on witchcraft, <a href="#Page_69">69</a>.</li>
+
+<li class="indx" id="Benefit_of_clergy">Benefit of clergy, <a href="#Page_233">233</a>, <a href="#Page_243">243</a>.</li>
+
+<li class="indx">Benefit of clergy, definition of, <a href="#Page_224">224</a>.</li>
+
+<li class="indx">Benefit of clergy, Biblical foundation for, <a href="#Page_228">228</a>.</li>
+
+<li class="indx">Benefit of clergy, condition contributing to, <a href="#Page_225">225</a>.</li>
+
+<li class="indx">Benefit of clergy, none, in desertion, <a href="#Page_234">234</a>.</li>
+
+<li class="indx">Benefit of clergy, did not extend to treason, <a href="#Page_228">228</a>.</li>
+
+<li class="indx">Benefit of clergy, nuns entitled to, <a href="#Page_228">228</a>, <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Benefit of clergy, “clergyable” and “unclergyable crimes,” <a href="#Page_233">233</a>.</li>
+
+<li class="indx">Benefit of clergy, burning in hand, in, <a href="#Page_231">231</a>.</li>
+
+<li class="indx">Benefit of clergy, practice in reading, in, <a href="#Page_230">230</a>.</li>
+
+<li class="indx">Benefit of clergy, in Bracton’s time, <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Benefit of clergy, case of Ben Jonson, <a href="#Page_238">238</a>, <a href="#Page_239">239</a>.</li>
+
+<li class="indx">Benefit of clergy, under Henry II., <a href="#Page_226">226</a>.</li>
+
+<li class="indx">Benefit of clergy, under Edward III., <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Benefit of clergy, under Edward IV., <a href="#Page_230">230</a>.</li>
+
+<li class="indx">Benefit of clergy, under Henry VI., <a href="#Page_231">231</a>.</li>
+
+<li class="indx">Benefit of clergy, under Henry VII., <a href="#Page_231">231</a>.</li>
+
+<li class="indx">Benefit of clergy, under Henry VIII., <a href="#Page_234">234</a>, <a href="#Page_235">235</a>.</li>
+
+<li class="indx">Benefit of clergy, abolished, in England, in 1825, <a href="#Page_236">236</a>.</li>
+
+<li class="indx">Benefit of clergy, claimed in United States, <a href="#Page_239">239</a>, <a href="#Page_241">241</a>.</li>
+
+<li class="indx">Benefit of clergy, abolished in U. S. in 1790, <a href="#Page_236">236</a>.</li>
+
+<li class="indx">Bentham, Jeremy, will of, <a href="#Page_324">324</a>.</li>
+
+<li class="indx">Berkeley, marriage of Lord Thomas, <a href="#Page_28">28</a>.</li>
+
+<li class="indx">Betrothals, in Anglo-Saxon days, <a href="#Page_36">36</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_337"></a>[337]</span>Betrothal-rings, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Biblical theory of marriage, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">Bier, ordeal of, <a href="#Page_143">143</a>, <a href="#Page_145">145</a>.</li>
+
+<li class="indx">Bilboes, punishment, by, <a href="#Page_303">303</a>.</li>
+
+<li class="indx">Blinding, punishment, by, <a href="#Page_295">295</a>.</li>
+
+<li class="indx">Boaz, his espousal of Ruth, <a href="#Page_36">36</a>.</li>
+
+<li class="indx">Boiling in oil, punishment by, <a href="#Page_285">285</a>.</li>
+
+<li class="indx">Bracton, does not refer to ordeals, <a href="#Page_157">157</a>.</li>
+
+<li class="indx">Bracton, benefit of clergy, in time of, <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Bracton, description of law wager, by, <a href="#Page_201">201</a>, <a href="#Page_202">202</a>.</li>
+
+<li class="indx">Bracton, standing mute, during time, of, <a href="#Page_179">179</a>.</li>
+
+<li class="indx">Branding, punishment, by, <a href="#Page_297">297</a>.</li>
+
+<li class="indx">Brank, punishment, by, <a href="#Page_305">305</a>.</li>
+
+<li class="indx">Brazil, marriages of infants in, <a href="#Page_29">29</a>.</li>
+
+<li class="indx">Burgundian code, on trial by battle, <a href="#Page_111">111</a>.</li>
+
+<li class="indx">Burning in hand, in benefit of clergy, <a href="#Page_231">231</a>.</li>
+
+<li class="indx">Burning, punishment by, <a href="#Page_276">276</a>.</li>
+
+<li class="indx">Burnworth, case of, in 1726, <a href="#Page_186">186</a>.</li>
+
+<li class="indx">Burr, Aaron, trial of, <a href="#Page_100">100</a>.</li>
+
+<li class="indx">Burn’s idea of the devil, <a href="#Page_69">69</a>.</li>
+
+<li class="indx">Burying alive, punishment by, <a href="#Page_282">282</a>.</li>
+
+<li class="ifrst">C</li>
+
+<li class="indx">Caesar, Augustus used the recall, <a href="#Page_88">88</a>.</li>
+
+<li class="indx">Caesar’s reference to marriage-settlements among Gauls, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">Calverly, case of Walter, in 1605, <a href="#Page_184">184</a>.</li>
+
+<li class="indx">Cambyses, recall of Sisamnes <a href="#Footnote_166">(note), 78</a>.</li>
+
+<li class="indx">Canute, ordeals under, <a href="#Page_152">152</a>.</li>
+
+<li class="indx">Capture, marriage by, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Cardunville, William’s case, <a href="#Page_22">22</a>.</li>
+
+<li class="indx">Cathay, marriages in <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Catholic marriage forms, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Cato, loaning of wife by, <a href="#Page_27">27</a>.</li>
+
+<li class="indx">Ceylon, polyandry in, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Chancery, jurisdiction of, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Charitable wills, <a href="#Page_323">323</a>.</li>
+
+<li class="indx">Charlemagne, law of, against witchcraft, <a href="#Page_50">50</a>.</li>
+
+<li class="indx">Charlemagne, edict, of, on trials by ordeal, <a href="#Page_147">147</a>, <a href="#Page_148">148</a>.</li>
+
+<li class="indx">Charles le-Gros, accusation and trial of his wife, <a href="#Page_159">159</a>.</li>
+
+<li class="indx">Chatelet, of Paris, punishments, at, <a href="#Page_289">289</a>, <a href="#Page_292">292</a>.</li>
+
+<li class="indx">Child marriages, <a href="#Page_29">29</a>.</li>
+
+<li class="indx">Child of concubine, property right of, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Chinese marriage customs, <a href="#Page_12">12</a>.</li>
+
+<li class="indx">Chivalry, influence of, on battle, <a href="#Page_112">112</a>, <a href="#Page_113">113</a>.</li>
+
+<li class="indx">Church and witchcraft, in early times, <a href="#Page_49">49</a>.</li>
+
+<li class="indx">Churchmen, trials of, by wager of law, <a href="#Page_210">210</a>.</li>
+
+<li class="indx">Church’s influence on trials by ordeal, <a href="#Page_168">168</a>, <a href="#Page_169">169</a>.</li>
+
+<li class="indx">Cimon, recall of, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Circassians, capture-marriages among <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Clarendon, assize of, <a href="#Page_154">154</a>.</li>
+
+<li class="indx">Clarendon, assize of, and law wager, <a href="#Page_209">209</a>.</li>
+
+<li class="indx">Claudius, law allowing marriage to niece, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Cleisthenes, on judicial recall, <a href="#Page_82">82</a>.</li>
+
+<li class="indx">Clergy, benefit of (see <a href="#Benefit_of_clergy">benefit of clergy</a>), <a href="#Page_223">223</a>, <a href="#Page_243">243</a>.</li>
+
+<li class="indx">Clergy, neck-verse used in, <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Clitherow, Margaret, case of, <a href="#Page_180">180</a>, <a href="#Page_183">183</a>.</li>
+
+<li class="indx">Clovis’ marriage to Clotilde, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">Cnut, proceedings in “false judgment” under, <a href="#Page_106">106</a>.</li>
+
+<li class="indx">Cnut, wills, under, <a href="#Page_312">312</a>.</li>
+
+<li class="indx">Cnut’s law against witchcraft, <a href="#Page_49">49</a>.</li>
+
+<li class="indx">Cnut’s law against certain sale-marriages, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Code of Hammurabi, on recall of judges, <a href="#Page_78">78</a>.</li>
+
+<li class="indx"><i>Coemptio in manum</i>, definition of, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Coke, on Slade’s case of law wager, <a href="#Page_213">213</a>.</li>
+
+<li class="indx">Coke, on wager of law, <a href="#Page_200">200</a>.</li>
+
+<li class="indx">Colynbourgh, Alice, trial of, by law wager, in 1435, <a href="#Page_211">211</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_338"></a>[338]</span>Combat, trial by (see <a href="#Battle">Battle, trial by</a>), <a href="#Page_109">109</a>.</li>
+
+<li class="indx">Common pleas courts, in old England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Compurgators, character of, in wager or law, <a href="#Page_198">198</a>.</li>
+
+<li class="indx">Compurgators, as witnesses, <a href="#Page_158">158</a>.</li>
+
+<li class="indx">Compurgation by fire ordeal, <a href="#Page_142">142</a>, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Concubinage, definition of, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Concubine, property right of progeny of, <a href="#Page_18">18</a>.</li>
+
+<li class="indx"><i>Concubinatus</i>, under Roman law, <a href="#Page_18">18</a>.</li>
+
+<li class="indx"><i>Confarreatio</i>, definition of, <a href="#Page_16">16</a>.</li>
+
+<li class="indx"><i>Confarreatio</i>, obsolete, by end of Roman Republic <a href="#Footnote_21">(note), 17</a>.</li>
+
+<li class="indx">Congress, abolished benefit of clergy, in 1790, <a href="#Page_236">236</a>.</li>
+
+<li class="indx">Constantine, law of, against witchcraft, <a href="#Page_48">48</a>.</li>
+
+<li class="indx">Constantine, sanctuary, under, <a href="#Page_248">248</a>.</li>
+
+<li class="indx">Corey, Giles, trial for witchcraft, <a href="#Page_66">66</a>.</li>
+
+<li class="indx">Corey, Giles, case of pressing to death, in 1692, <a href="#Page_187">187</a>, <a href="#Page_189">189</a>.</li>
+
+<li class="indx">Corey, Martha’s trial for witchcraft, <a href="#Page_65">65</a>.</li>
+
+<li class="indx">Corsned, ordeal, by, <a href="#Page_143">143</a>, <a href="#Page_144">144</a>.</li>
+
+<li class="indx">County Court, of Anglo-Saxons, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Courts, in ancient England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Crimes, unclergyable, <a href="#Page_233">233</a>.</li>
+
+<li class="indx">Criminal cases, wager of law, in, during 14th century, <a href="#Page_204">204</a>.</li>
+
+<li class="indx">Crucifixion, punishment by, <a href="#Page_280">280</a>.</li>
+
+<li class="indx">Cross, ordeal by, <a href="#Page_143">143</a>, <a href="#Page_144">144</a>, <a href="#Page_148">148</a>.</li>
+
+<li class="indx">Cumanus, cruelty of, in witch persecutions, <a href="#Page_54">54</a>.</li>
+
+<li class="indx"><i>Curia regis</i>, in early England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Custom, of throwing rice, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Custom, of throwing shoes, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Custom, of throwing stockings, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Custom, of throwing bouquets, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Customs, of marriage, <a href="#Page_12">12</a>, <a href="#Page_44">44</a>.</li>
+
+<li class="ifrst">D</li>
+
+<li class="indx">David and Goliath, trial by, <a href="#Page_109">109</a>.</li>
+
+<li class="indx">David’s Psalms, authorizing benefit of clergy, <a href="#Page_228">228</a>.</li>
+
+<li class="indx">Debt, wager of law, in <a href="#Footnote_478">(note), 207</a>.</li>
+
+<li class="indx">Debt, battle in trials for, <a href="#Page_119">119</a>.</li>
+
+<li class="indx">Definition of benefit of clergy, <a href="#Page_224">224</a>.</li>
+
+<li class="indx">Definition of <i>Confarreatio</i>, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Definition of trial by ordeal, <a href="#Page_141">141</a>.</li>
+
+<li class="indx">Definition of wager of law, <a href="#Page_196">196</a>.</li>
+
+<li class="indx">Descent from concubine, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Detinue, wager of law, in <a href="#Footnote_478">(note), 207</a>.</li>
+
+<li class="indx">Dinah’s proposed marriage to Shechem, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">Diocletian, prohibition of polygamy by, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Divorcement, under Hammurabi, <a href="#Page_31">31</a>.</li>
+
+<li class="indx"><i>Donatio propter nuptias</i>, of Roman law, <a href="#Page_31">31</a>.</li>
+
+<li class="indx">Dower, at church door, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">Dower, under Anglo-Saxons, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">Dower, under reign of Edward I., <a href="#Page_26">26</a>.</li>
+
+<li class="indx">Dower, Shakespeare’s reference to law of <a href="#Footnote_73">(note), 33</a>.</li>
+
+<li class="indx">Dowry, under Hammurabi’s code, <a href="#Page_31">31</a>.</li>
+
+<li class="indx">Dowry, origin of, <a href="#Page_31">31</a>.</li>
+
+<li class="indx">Drawing and quartering, punishment by, <a href="#Page_283">283</a>.</li>
+
+<li class="indx">Drowning, punishment by, <a href="#Page_277">277</a>.</li>
+
+<li class="indx">Ducking, punishment by, <a href="#Page_303">303</a>.</li>
+
+<li class="indx">Durant, John, case of, in 1734, <a href="#Page_187">187</a>.</li>
+
+<li class="indx">“Dusty-foot courts”, <a href="#Page_90">90</a>.</li>
+
+<li class="ifrst">E</li>
+
+<li class="indx">Ears, cutting off, punishment, by, <a href="#Page_296">296</a>.</li>
+
+<li class="indx">“Earthenware-scourge”, recall known as, in Athens, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Edda, Elder, song of, <a href="#Page_165">165</a>.</li>
+
+<li class="indx">Edward, the Confessor, sanctuary, under, <a href="#Page_254">254</a>.</li>
+
+<li class="indx">Edward, the Confessor, ordeals, under, <a href="#Page_152">152</a>.</li>
+
+<li class="indx">Edward, the Confessor, accusation against his mother, <a href="#Page_159">159</a>, <a href="#Page_160">160</a>.</li>
+
+<li class="indx">Edward, the Elder, ordeals, under, <a href="#Page_152">152</a>.</li>
+
+<li class="indx">Edward I., his marriage to Marguerite, in 1299, <a href="#Page_32">32</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_339"></a>[339]</span>Edward I., sanctuary, under, <a href="#Page_256">256</a>.</li>
+
+<li class="indx">Edward I., timidity of judges, under, <a href="#Page_93">93</a>.</li>
+
+<li class="indx">Edward I., standing mute, under, <a href="#Page_175">175</a>.</li>
+
+<li class="indx">Edward I., statute on dower, <a href="#Page_26">26</a>.</li>
+
+<li class="indx">Edward II., punishment by drowning, under, <a href="#Page_278">278</a>.</li>
+
+<li class="indx">Edward III., benefit of clergy, under, <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Edward III., <i>peine forte et dure</i>, under, <a href="#Page_180">180</a>.</li>
+
+<li class="indx">Edward III., battle, discouraged by, <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Edward III., marriages of infants, under, <a href="#Page_28">28</a>.</li>
+
+<li class="indx">Edward III., wager of law, under, <a href="#Page_202">202</a>.</li>
+
+<li class="indx">Edward III., trial by battle before, <a href="#Page_129">129</a>.</li>
+
+<li class="indx">Edward IV., benefit of clergy, under, <a href="#Page_230">230</a>.</li>
+
+<li class="indx">Edward IV., wills, under, <a href="#Page_317">317</a>.</li>
+
+<li class="indx">Edward VI., wills, under, <a href="#Page_318">318</a>.</li>
+
+<li class="indx">Egypt, wills, in ancient, <a href="#Page_309">309</a>.</li>
+
+<li class="indx">Elizabeth, abolished law wager, in ecclesiastic courts, <a href="#Page_208">208</a>.</li>
+
+<li class="indx">Elizabeth, statute of, on benefit of clergy, <a href="#Page_231">231</a>.</li>
+
+<li class="indx">Elizabeth, trial, by battle, under, <a href="#Page_132">132</a>.</li>
+
+<li class="indx">Elizabeth, statute of, against witchcraft, <a href="#Page_57">57</a>.</li>
+
+<li class="indx">Elizabeth, Queen, sanctuary claimed by, <a href="#Page_260">260</a>, <a href="#Page_261">261</a>.</li>
+
+<li class="indx">Ellenborough, on trial by battle, in 1817, <a href="#Page_133">133</a>.</li>
+
+<li class="indx">Ellsworth, Oliver, framed judiciary bill, in U. S., <a href="#Page_96">96</a>.</li>
+
+<li class="indx">Emma, Queen, trial of, by ordeal, <a href="#Page_159">159</a>, <a href="#Page_160">160</a>.</li>
+
+<li class="indx">England, administration in ancient, of justice, <a href="#Page_89">89</a>, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">England, witchcraft in, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">Essex, trial by battle with Montford, <a href="#Page_128">128</a>.</li>
+
+<li class="indx">Eucharist, ordeal by, <a href="#Page_143">143</a>, <a href="#Page_144">144</a>.</li>
+
+<li class="ifrst">F</li>
+
+<li class="indx">“Fair Maid of Perth”, ordeal of bier, in <a href="#Footnote_374">(note), 166</a>.</li>
+
+<li class="indx">False-judgment, in Anglo-Saxon days, <a href="#Page_92">92</a>.</li>
+
+<li class="indx">Fejee-Islanders, marriages by <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Felony, attainder in, <a href="#Page_173">173</a>.</li>
+
+<li class="indx">Felony, trial by battle for, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Felton, case of John, in 1628 <a href="#Footnote_407">(note), 185</a>.</li>
+
+<li class="indx">Fiction, wills, in, <a href="#Page_332">332</a>.</li>
+
+<li class="indx">Fisher’s, trial by battle, <a href="#Page_131">131</a>.</li>
+
+<li class="indx">Flaying, punishment, by, <a href="#Page_300">300</a>.</li>
+
+<li class="indx">Flollo and King Arthur, battle between, <a href="#Page_127">127</a>.</li>
+
+<li class="indx">Fou-hi, Emperor, established marriage, in China, <a href="#Page_12">12</a>.</li>
+
+<li class="indx">Fourteenth century wills, <a href="#Page_319">319</a>.</li>
+
+<li class="indx">Franklin, will of Benjamin, <a href="#Page_326">326</a>.</li>
+
+<li class="indx">Freakish wills, <a href="#Page_324">324</a>.</li>
+
+<li class="indx">France, witchcraft in, <a href="#Page_70">70</a>.</li>
+
+<li class="ifrst">G</li>
+
+<li class="indx">Gallows-marriages, <a href="#Page_41">41</a>, <a href="#Page_43">43</a>.</li>
+
+<li class="indx">Galzu, the judge, <a href="#Page_74">74</a>.</li>
+
+<li class="indx">Garnier, case of, on witchcraft persecution, <a href="#Page_55">55</a>.</li>
+
+<li class="indx">Gauls, marriage among, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">Gaunt, John of, and Catherine Swinford, <a href="#Page_19">19</a>.</li>
+
+<li class="indx">Gaunt, John, will of, <a href="#Page_320">320</a>.</li>
+
+<li class="indx">Gemot court, of Anglo-Saxons, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Genesis, law of marriage traced to, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">George II., law of, regarding marriage, <a href="#Page_24">24</a>.</li>
+
+<li class="indx">George III., abolished <i>peine forte et dure</i>, in 1772, <a href="#Page_189">189</a>.</li>
+
+<li class="indx">George III., judges under, <a href="#Page_95">95</a>.</li>
+
+<li class="indx">George III., abolished trial by battle, in England, <a href="#Page_134">134</a>.</li>
+
+<li class="indx">Germans, trial by battle among, at early day, <a href="#Page_109">109</a>, <a href="#Page_110">110</a>.</li>
+
+<li class="indx">Glanville, law of marriage stated by, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Glanville, on trial by battle, under writ of right, <a href="#Page_120">120</a>, <a href="#Page_122">122</a>.</li>
+
+<li class="indx">Glanville, ordeals, in time of, <a href="#Page_155">155</a>.</li>
+
+<li class="indx">Glanville, wills, during time of, <a href="#Page_313">313</a>.</li>
+
+<li class="indx">Glanville, wager of law, during time of, <a href="#Page_200">200</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_340"></a>[340]</span>Glazier’s company case, <a href="#Page_214">214</a>.</li>
+
+<li class="indx">Godwin, Duke, trial of, by ordeal, <a href="#Page_160">160</a>, <a href="#Page_161">161</a>.</li>
+
+<li class="indx">Goliath, trial with David, <a href="#Page_109">109</a>.</li>
+
+<li class="indx">Goths, trial by battle among, <a href="#Page_111">111</a>.</li>
+
+<li class="indx">“Great Law”, wager by, in 14th century, <a href="#Page_204">204</a>.</li>
+
+<li class="indx">Greece, recall in, <a href="#Page_81">81</a>.</li>
+
+<li class="indx">Greece, effect of recall in, <a href="#Page_103">103</a>, <a href="#Page_104">104</a>.</li>
+
+<li class="indx">Greece, sanctuary in, <a href="#Page_247">247</a>.</li>
+
+<li class="indx">Gregory of Tours, case of law wager, <a href="#Page_209">209</a>.</li>
+
+<li class="indx">Guillotine, punishment by, <a href="#Page_293">293</a>.</li>
+
+<li class="indx">Gundibald, law of, regulating trial by battle, <a href="#Page_111">111</a>.</li>
+
+<li class="ifrst">H</li>
+
+<li class="indx">Hair, plucking off, punishment by, <a href="#Page_299">299</a>.</li>
+
+<li class="indx">Hale, Sir Mathew’s, trial of witches, <a href="#Page_60">60</a>.</li>
+
+<li class="indx">Hammurabi’s prerogatives, in decision of causes, <a href="#Page_79">79</a>.</li>
+
+<li class="indx">Hammurabi, made infallibility the test of the judge, <a href="#Page_106">106</a>.</li>
+
+<li class="indx">Hammurabi’s law against witchcraft, <a href="#Page_45">45</a>.</li>
+
+<li class="indx">Hammurabi, code of, regarding marriage dowry, <a href="#Page_31">31</a>.</li>
+
+<li class="indx">Hammurabi’s code, on judicial recall, <a href="#Page_77">77</a>, <a href="#Page_80">80</a>.</li>
+
+<li class="indx">Hand, marriages by, in Rome, <a href="#Page_17">17</a>.</li>
+
+<li class="indx">Hanging, punishment by, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Hawes, Nathaniel, case of, in 1721, <a href="#Page_186">186</a>.</li>
+
+<li class="indx">Hebrews, practiced polygamy, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Henry II., benefit of clergy, under, <a href="#Page_226">226</a>.</li>
+
+<li class="indx">Henry II., justices itinerant, under, <a href="#Page_91">91</a>.</li>
+
+<li class="indx">Henry II., will of, <a href="#Page_315">315</a>.</li>
+
+<li class="indx">Henry III., abolished ordeals, <a href="#Page_157">157</a>.</li>
+
+<li class="indx">Henry III., <i>peine forte et dure</i>, under reign of, <a href="#Page_178">178</a>.</li>
+
+<li class="indx">Henry III., trial by battle before, <a href="#Page_129">129</a>.</li>
+
+<li class="indx">Henry IV., sanctuary, in reign of, <a href="#Page_259">259</a>.</li>
+
+<li class="indx">Henry IV., <i>peine forte et dure</i>, under, <a href="#Page_180">180</a>.</li>
+
+<li class="indx">Henry VI., law wager, under, <a href="#Page_212">212</a>.</li>
+
+<li class="indx">Henry VI., wager of law, under, <a href="#Page_206">206</a>, <a href="#Page_207">207</a>.</li>
+
+<li class="indx">Henry VI., <i>peine forte et dure</i>, under, <a href="#Page_180">180</a>.</li>
+
+<li class="indx">Henry VI., trial by battle, before, <a href="#Page_131">131</a>.</li>
+
+<li class="indx">Henry VII., benefit of clergy, under, <a href="#Page_231">231</a>.</li>
+
+<li class="indx">Henry VII., trial by battle, before, <a href="#Page_132">132</a>.</li>
+
+<li class="indx">Henry VII., sanctuary, under, <a href="#Page_262">262</a>.</li>
+
+<li class="indx">Henry VII., sanctuary, under, <a href="#Page_257">257</a>.</li>
+
+<li class="indx">Henry VII., <i>peine forte et dure</i>, under <a href="#Footnote_402">(note), 180</a>.</li>
+
+<li class="indx">Henry VIII., benefit of clergy, under, <a href="#Page_234">234</a>, <a href="#Page_235">235</a>.</li>
+
+<li class="indx">Henry VIII., sanctuary curtailed by, <a href="#Page_267">267</a>.</li>
+
+<li class="indx">Henry VIII., law wager, under, in 1527 <a href="#Footnote_499">(note), 213</a>.</li>
+
+<li class="indx">Hereford, battle with Norfolk, <a href="#Page_130">130</a>.</li>
+
+<li class="indx">Hexham, sanctuary, at, <a href="#Page_253">253</a>.</li>
+
+<li class="indx">Hincmar, views of, on ordeals, <a href="#Page_162">162</a>.</li>
+
+<li class="indx">Holt, chief justice, cases by, on law wager, <a href="#Page_214">214</a>, <a href="#Page_216">216</a>.</li>
+
+<li class="indx">Holt, lord chief justice’s trial of witches, <a href="#Page_61">61</a>.</li>
+
+<li class="indx">Hopkins, Matthew, his cruelty against witches, <a href="#Page_59">59</a>.</li>
+
+<li class="indx">Horsey, Doctor’s case, <a href="#Page_236">236</a>.</li>
+
+<li class="indx">Hundred court, of Anglo-Saxons, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Hungarians, marriages of infants, among, <a href="#Page_29">29</a>.</li>
+
+<li class="indx">Huntingdon witch trials, <a href="#Page_61">61</a>.</li>
+
+<li class="indx">Hutchinson’s work on witchcraft, <a href="#Page_69">69</a>.</li>
+
+<li class="indx">Hyperbolus, recall of, in Athens, <a href="#Page_86">86</a>.</li>
+
+<li class="ifrst">I</li>
+
+<li class="indx">Ina, sanctuary, under, <a href="#Page_251">251</a>.</li>
+
+<li class="indx">Independence of judges, established by William III., <a href="#Page_94">94</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_341"></a>[341]</span>Independence of judges, under Constitution of U. S., <a href="#Page_97">97</a>.</li>
+
+<li class="indx">Independence of judges, wisdom of, demonstrated, <a href="#Page_106">106</a>.</li>
+
+<li class="indx">India, polyandry in, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Ine, laws of, governing ordeals, <a href="#Page_149">149</a>.</li>
+
+<li class="indx">Infallibility, the test of judicial action in Hammurabi’s time, <a href="#Page_106">106</a>.</li>
+
+<li class="indx">Infant marriages, <a href="#Page_28">28</a>.</li>
+
+<li class="indx">Infant marriages, in Brazil, <a href="#Page_29">29</a>.</li>
+
+<li class="indx">Innocent III., marriage under, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Inquisition, punishment by, <a href="#Page_286">286</a>, <a href="#Page_288">288</a>.</li>
+
+<li class="indx">Iron, ordeal by hot, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Isaac and Rebekah, <a href="#Page_33">33</a>.</li>
+
+<li class="indx">Israelites, taking a wife, by <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Israelites, wager of law, under ancient, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Itinerant justices, <a href="#Page_91">91</a>.</li>
+
+<li class="ifrst">J</li>
+
+<li class="indx">Jacob’s will, <a href="#Page_309">309</a>.</li>
+
+<li class="indx">James I., repealed right to sanctuary, <a href="#Page_268">268</a>.</li>
+
+<li class="indx">James of Scotland, his belief in witchcraft, <a href="#Page_57">57</a>.</li>
+
+<li class="indx">Jealousies, law of, <a href="#Page_141">141</a>, <a href="#Page_142">142</a>.</li>
+
+<li class="indx">Joan of Arc, persecution of, <a href="#Page_52">52</a>.</li>
+
+<li class="indx">Jonson, clergy, claimed by Ben, <a href="#Page_238">238</a>, <a href="#Page_239">239</a>.</li>
+
+<li class="indx">Judge, definition of, <a href="#Page_74">74</a>.</li>
+
+<li class="indx">Judges, in patriarchial days, <a href="#Page_75">75</a>, <a href="#Page_76">76</a>.</li>
+
+<li class="indx">Judges, servants of king, in old England, <a href="#Page_91">91</a>.</li>
+
+<li class="indx">Judges, liability of, in England, <a href="#Page_95">95</a>.</li>
+
+<li class="indx">Judicial recall, <a href="#Page_74">74</a>, <a href="#Page_108">108</a>.</li>
+
+<li class="indx">Judicial tenure in American colonies, <a href="#Page_98">98</a>.</li>
+
+<li class="indx">Judgment in <i>peine forte et dure</i>, <a href="#Page_172">172</a>, <a href="#Page_173">173</a>.</li>
+
+<li class="indx">Jury trials under King Alfred, <a href="#Page_151">151</a>.</li>
+
+<li class="indx">Jury trials used instead of battle, under Edward III., <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Justice, King, the fountain of, in England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Justice, sale of, in ancient England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Justices, itinerant, in England, <a href="#Page_91">91</a>.</li>
+
+<li class="indx">Justinian’s definition of marriage, <a href="#Page_12">12</a>.</li>
+
+<li class="ifrst">K</li>
+
+<li class="indx">Katherine, of Aragon, will of, <a href="#Page_321">321</a>.</li>
+
+<li class="indx">Kent, Chancellor, on common-law marriages, <a href="#Page_23">23</a>.</li>
+
+<li class="indx">Kentucky, clergy claimed, in, <a href="#Page_241">241</a>.</li>
+
+<li class="indx">King, the fountain of justice, in England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">King Alfred’s courts, <a href="#Page_89">89</a>, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">King’s bench, court of, in England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Knighthood, effect upon trial by battle, <a href="#Page_113">113</a>, <a href="#Page_114">114</a>.</li>
+
+<li class="ifrst">L</li>
+
+<li class="indx">Lamech, established polygamy, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Law, wager of (See <a href="#Wager_of_law">wager of law</a>), <a href="#Page_196">196</a>, <a href="#Page_220">220</a>.</li>
+
+<li class="indx">Law suits under Hammurabi, <a href="#Page_80">80</a>.</li>
+
+<li class="indx">Legitimacy, of mantle-children, <a href="#Page_18">18</a>, <a href="#Page_19">19</a>.</li>
+
+<li class="indx">Leo, Emperor, law against concubinage, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Littleton, on benefit of clergy, <a href="#Page_230">230</a>.</li>
+
+<li class="indx">Littleton, law of dower, by, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">London, charter of, exempting trials by battle, <a href="#Page_119">119</a>.</li>
+
+<li class="indx">Longfellow, presents case of Giles Cory, <a href="#Page_187">187</a>, <a href="#Page_189">189</a>.</li>
+
+<li class="indx">Louis le Debonnaire, abolished ordeal of the cross, <a href="#Page_148">148</a>.</li>
+
+<li class="indx">Luther, marriage ceremony, by <a href="#Footnote_87">(note), 36</a>.</li>
+
+<li class="indx">Law, of marriage, <a href="#Page_12">12</a>, <a href="#Page_44">44</a>.</li>
+
+<li class="ifrst">M</li>
+
+<li class="indx">Maiden-rent, <a href="#Page_30">30</a>.</li>
+
+<li class="indx">Majestas, under Roman Republic, <a href="#Page_88">88</a>.</li>
+
+<li class="indx">Mantle-children, law of, <a href="#Page_18">18</a>, <a href="#Page_19">19</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_342"></a>[342]</span>Marriage, laws and customs of, <a href="#Page_12">12</a>, <a href="#Page_44">44</a>.</li>
+
+<li class="indx">Marriage, definition of, <a href="#Page_12">12</a>.</li>
+
+<li class="indx">Marriage, three forms of, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Marriage, Biblical theory concerning, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">Marriage, under Mosaic law, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">Marriage, <i>per verba de praesenti</i>, at common law, <a href="#Page_23">23</a>.</li>
+
+<li class="indx">Marriage, <i>in facie ecclesiae</i>, <a href="#Page_23">23</a>.</li>
+
+<li class="indx">Marriage, by sale, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Marriage, by rape, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Marriage, by capture, <a href="#Page_13">13</a></li>
+
+<li class="indx">Marriage, Morganatic <a href="#Footnote_17">(note), 17</a>.</li>
+
+<li class="indx">Marriage, putative, <a href="#Page_26">26</a>.</li>
+
+<li class="indx">Marriage, retroactive, <a href="#Page_26">26</a>.</li>
+
+<li class="indx">Marriage, required to be celebrated by clergy, in 1753, <a href="#Page_24">24</a>.</li>
+
+<li class="indx">Marriage, a civil contract, under English law of 1836, <a href="#Page_24">24</a>.</li>
+
+<li class="indx">Marriage, within Levitical degree prohibited, <a href="#Page_17">17</a>.</li>
+
+<li class="indx">Marriage, between uncles and nieces, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Marriage, between aunts and nephews, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Marriage banns, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Marriage dowry, origin of, <a href="#Page_31">31</a>.</li>
+
+<li class="indx">Marriage, not a religious ordinance, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Marriage, religious ceremony required in 1563, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Marriage, legitimates, mantle-children, <a href="#Page_18">18</a>, <a href="#Page_19">19</a>.</li>
+
+<li class="indx">Marriage-ring, origin of, <a href="#Page_33">33</a>.</li>
+
+<li class="indx">Marriage, forms of, by Roman law, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Marriage, under Twelve Tables, of Romans <a href="#Footnote_38">(note), 21</a>.</li>
+
+<li class="indx">Marriage, exalted by Roman law, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Marriage, by hand, in ancient Rome, <a href="#Page_17">17</a>.</li>
+
+<li class="indx">Marriage, a partnership, by Roman law, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Marriage, among Gauls, Caesar’s reference to, <a href="#Page_32">32</a>.</li>
+
+<li class="indx">Marriage, in Pericles’ time, <a href="#Page_27">27</a>.</li>
+
+<li class="indx">Marriage, appertained to spiritual forum, in 12th century, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Marriage, in Glanville’s time, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Marriage, by infants, <a href="#Page_28">28</a>.</li>
+
+<li class="indx">Marriage, in United States, <a href="#Page_23">23</a>.</li>
+
+<li class="indx">Marriage, form of, in Persia, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Marriage, among Hungarians, <a href="#Page_29">29</a>.</li>
+
+<li class="indx">Marriage, at gallows, <a href="#Page_41">41</a>.</li>
+
+<li class="indx">Marriage, in a “shift”, <a href="#Page_37">37</a>, <a href="#Page_42">42</a>.</li>
+
+<li class="indx">Marriage, between Shechem and Dinah, proposal of, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">Marriage, between Claudius and Agrippina, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">Marriage of Richard de Anesty, in 1143, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Marriage between John of Gaunt and Catherine Swinford, <a href="#Page_19">19</a>.</li>
+
+<li class="indx">Marriage between Duke Richard and Gunnora, <a href="#Page_19">19</a>.</li>
+
+<li class="indx">Marriage laws, in England, in 7th century, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Marshal, trial for treason must be before, <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Marshall, Chief Justice, on independence of courts, <a href="#Page_101">101</a>.</li>
+
+<li class="indx">Marshall, Chief Justice, probable recall of, <a href="#Page_100">100</a>.</li>
+
+<li class="indx">Marshall, will of Chief Justice, <a href="#Page_327">327</a>.</li>
+
+<li class="indx">Mary, Queen, law against witches, in Scotland, <a href="#Page_56">56</a>.</li>
+
+<li class="indx">Mary, Queen, sanctuary, under, <a href="#Page_259">259</a>.</li>
+
+<li class="indx">Massachusetts, clergy claimed in, <a href="#Page_239">239</a>.</li>
+
+<li class="indx">Massola, punishment by, <a href="#Page_293">293</a>, <a href="#Page_294">294</a>.</li>
+
+<li class="indx">Meinhold’s “Amber Witch”, <a href="#Page_71">71</a>.</li>
+
+<li class="indx">Menu, institutes of, on marriage <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">“Middle Law”, wager by, in 14th century, <a href="#Page_204">204</a>.</li>
+
+<li class="indx">Millis case, <a href="#Page_24">24</a>, <a href="#Page_25">25</a>.</li>
+
+<li class="indx">Milton’s idea of the devil, <a href="#Page_69">69</a>.</li>
+
+<li class="indx">Minnesota, clergy claimed in, <a href="#Page_241">241</a>.</li>
+
+<li class="indx">Minority alone protected by the courts, <a href="#Page_103">103</a>.</li>
+
+<li class="indx">“Minstrelsy of Scottish Border”, ordeal of bier, in, <a href="#Page_166">166</a>.</li>
+
+<li class="indx">Mischief of recall in Athens, <a href="#Page_86">86</a>.</li>
+
+<li class="indx">Molay, persecution of, under charge of witchcraft, <a href="#Page_52">52</a>.</li>
+
+<li class="indx">Monogamy, definition of, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Monogamy, best suited to civilization, <a href="#Page_15">15</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_343"></a>[343]</span>Monogamy, in ancient Greece and Rome <a href="#Footnote_17">(note), 16</a>.</li>
+
+<li class="indx">Morganatic marriages, <a href="#Page_17">17</a>.</li>
+
+<li class="indx">Mosaic code, sanctuary traced to, <a href="#Page_244">244</a>.</li>
+
+<li class="indx">Mosaic code, wager of law, under, <a href="#Page_196">196</a>.</li>
+
+<li class="indx">Mosaic conception of judicial functions, <a href="#Page_75">75</a>, <a href="#Page_76">76</a>.</li>
+
+<li class="indx">Mosaic law, against witchcraft, <a href="#Page_46">46</a>.</li>
+
+<li class="indx">Mosaic law, requiring marriage to brother’s widow, <a href="#Page_35">35</a>.</li>
+
+<li class="indx">Moses, law of marriage, <a href="#Page_14">14</a>.</li>
+
+<li class="indx">Moses, advice to judges, <a href="#Page_75">75</a>, <a href="#Page_76">76</a>.</li>
+
+<li class="indx">Moses, warning, of, in rendering judgment, <a href="#Page_101">101</a>.</li>
+
+<li class="ifrst">N</li>
+
+<li class="indx">Narada, institutes of, <a href="#Page_145">145</a>.</li>
+
+<li class="indx">Nazarene, delivery of, to multitude, <a href="#Page_122">122</a>.</li>
+
+<li class="indx">Neck-verse, in benefit of clergy, <a href="#Page_229">229</a>.</li>
+
+<li class="indx">Necromancy in mediaeval times, <a href="#Page_49">49</a>.</li>
+
+<li class="indx">Neilson, trial by battle by, <a href="#Page_129">129</a>.</li>
+
+<li class="indx">“New England Tragedies”, case of Giles Cory, in, <a href="#Page_187">187</a>, <a href="#Page_189">189</a>.</li>
+
+<li class="indx">New Zealand, marriages, in <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx"><i>Nil debit</i>, wager or law, in cases of, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Norfolk, battle with Hereford, <a href="#Page_130">130</a>.</li>
+
+<li class="indx">Normans, introduced battle, into England, <a href="#Page_114">114</a>.</li>
+
+<li class="indx">Northampton, assize of, <a href="#Page_154">154</a>.</li>
+
+<li class="indx">North Carolina, clergy claimed in, <a href="#Page_240">240</a>.</li>
+
+<li class="indx">Nuns, entitled to clergy, <a href="#Page_228">228</a>.</li>
+
+<li class="indx">Nurse, Rebecca’s trial for witchcraft, <a href="#Page_67">67</a>.</li>
+
+<li class="ifrst">O</li>
+
+<li class="indx">Oath-helpers, in wager of law, <a href="#Page_205">205</a>, <a href="#Page_207">207</a>.</li>
+
+<li class="indx">Oil, ordeal by, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, trial by, <a href="#Page_141">141</a>, <a href="#Page_170">170</a>.</li>
+
+<li class="indx">Ordeal, definition of, <a href="#Page_141">141</a>.</li>
+
+<li class="indx">Ordeal, antiquity of, <a href="#Page_141">141</a>.</li>
+
+<li class="indx">Ordeal of the bier, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by the corsned, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by red hot iron, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by the Eucharist, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by fire, <a href="#Page_142">142</a>, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by the cross, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, of the bier, as presented in Richard III., <a href="#Page_166">166</a>.</li>
+
+<li class="indx">Ordeal, by balance, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by poison, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by water, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, by hot oil, <a href="#Page_143">143</a>.</li>
+
+<li class="indx">Ordeal, influence of Church on trials by, <a href="#Page_168">168</a>, <a href="#Page_169">169</a>.</li>
+
+<li class="indx">Ordeal, under Ine, <a href="#Page_149">149</a>.</li>
+
+<li class="indx">Ordeal, trials, under Richard I., <a href="#Page_163">163</a>.</li>
+
+<li class="indx">Ordeal, trials, reported by Palgrave, <a href="#Page_163">163</a>, <a href="#Page_164">164</a>.</li>
+
+<li class="indx">Ordeal, of bier, as presented in “Minstrelsy of Scottish Border”, <a href="#Page_166">166</a>.</li>
+
+<li class="indx">Ordeal, of bier, in “Fair Maid of Perth” <a href="#Footnote_374">(note), 166</a>.</li>
+
+<li class="indx">Ordeal, to establish paternity of children, <a href="#Page_159">159</a>.</li>
+
+<li class="indx">Ordeal, under Athelstan, <a href="#Page_149">149</a>.</li>
+
+<li class="indx">Ordeal, under Canute, <a href="#Page_152">152</a>.</li>
+
+<li class="indx">Ordeal, under Edward the Elder, <a href="#Page_152">152</a>.</li>
+
+<li class="indx">Ordeal, under Edward the Confessor, <a href="#Page_152">152</a>.</li>
+
+<li class="indx">Ordeal, under William Rufus, <a href="#Page_156">156</a>.</li>
+
+<li class="indx">Ordeal, under Charlemagne, <a href="#Page_147">147</a>, <a href="#Page_148">148</a>.</li>
+
+<li class="indx">Ordeal, under William the Conqueror, <a href="#Page_153">153</a>.</li>
+
+<li class="indx">Ordeal, under Henry II., <a href="#Page_154">154</a>, <a href="#Page_155">155</a>.</li>
+
+<li class="indx">Ordeal, in time of Glanville, <a href="#Page_155">155</a>.</li>
+
+<li class="indx">Ordeal, abolished by Henry III., <a href="#Page_157">157</a>.</li>
+
+<li class="indx">Ostracism, in ancient Greece, <a href="#Page_81">81</a>.</li>
+
+<li class="indx">Otho, established trial by battle, in 983 A. D., <a href="#Page_112">112</a>.</li>
+
+<li class="ifrst">P</li>
+
+<li class="indx">Partnership, marriage, a, by Roman law, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Palgrave’s record of ordeal trials, <a href="#Page_163">163</a>, <a href="#Page_164">164</a>.</li>
+
+<li class="indx">Parson’s, Chief Justice, on marriages at common law, <a href="#Page_23">23</a>.</li>
+
+<li class="indx">Paynel, William and Margaret’s case, in 1302, <a href="#Page_26">26</a>.</li>
+
+<li class="indx" id="Peine"><span class="pagenum"><a id="Page_344"></a>[344]</span><i>Peine forte et dure</i>, <a href="#Page_172">172</a>, <a href="#Page_195">195</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, definition of, <a href="#Page_172">172</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, proceeding in, <a href="#Page_174">174</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, judgment in, <a href="#Page_172">172</a>, <a href="#Page_173">173</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, applied in 1215 <a href="#Footnote_388">(note), 174</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of, in 1219, <a href="#Page_178">178</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, statute of Westminster on, <a href="#Page_178">178</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, under Edward I., <a href="#Page_175">175</a>, <a href="#Page_176">176</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, under Henry III., <a href="#Page_178">178</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, under Edward III., <a href="#Page_179">179</a>, <a href="#Page_180">180</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i> during Bracton’s time, <a href="#Page_179">179</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, under Henry IV., <a href="#Page_180">180</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, under Henry VII. <a href="#Footnote_402">(note), 180</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, cases of, in 1221, <a href="#Page_179">179</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, from 15th to 18th century, <a href="#Page_177">177</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, from 16th to 17th century, <a href="#Page_184">184</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, abolished in 1772, <a href="#Page_189">189</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, in United States, <a href="#Page_187">187</a>, <a href="#Page_190">190</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, abolished by act of Congress, in U. S., in 1825, <a href="#Page_191">191</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Giles Cory, in 1692, <a href="#Page_187">187</a>, <a href="#Page_189">189</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Walter Calverly, <a href="#Page_184">184</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Margaret Clitherow, <a href="#Page_180">180</a>, <a href="#Page_183">183</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of John Durant, in 1734, <a href="#Page_187">187</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of John Felton, in 1628 <a href="#Footnote_407">(note), 185</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Anthony Arrowsmith, <a href="#Page_183">183</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Burnworth, in 1726, <a href="#Page_186">186</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Phillips, in 1720, <a href="#Page_186">186</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Nathaniel Hawes, in 1721, <a href="#Page_186">186</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, illustrations of, from Shakespeare, <a href="#Page_192">192</a>, <a href="#Page_193">193</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Sir Richard Weston, in 1615, <a href="#Page_184">184</a>, <a href="#Page_185">185</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Major Strangeways, in 1657, <a href="#Page_185">185</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Juliana Quick, <a href="#Page_180">180</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, case of Cecelia Rygeway, <a href="#Page_180">180</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, in 1827, <a href="#Page_190">190</a>.</li>
+
+<li class="indx"><i>Peine forte et dure</i>, conclusions regarding, <a href="#Page_193">193</a>, <a href="#Page_195">195</a>.</li>
+
+<li class="indx">Penn, William’s trial of witches, <a href="#Page_62">62</a>.</li>
+
+<li class="indx">Penn, will of William, <a href="#Page_328">328</a>.</li>
+
+<li class="indx">Pericles, marriage under, <a href="#Page_27">27</a>.</li>
+
+<li class="indx">Perjury, battle established to prevent, <a href="#Page_112">112</a>.</li>
+
+<li class="indx">Persia, form of marriages in, <a href="#Page_34">34</a>, <a href="#Page_35">35</a>.</li>
+
+<li class="indx">Petalism, law of repealed, 452 B. C., <a href="#Page_87">87</a>.</li>
+
+<li class="indx">Petalism, in Syracuse, <a href="#Page_86">86</a>.</li>
+
+<li class="indx">Phillips, of Newgate, case of, in 1720, <a href="#Page_186">186</a>.</li>
+
+<li class="indx"><i>Piepoudre</i> courts, under Anglo-Saxons, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Plato, will of, <a href="#Page_310">310</a>.</li>
+
+<li class="indx">Poetic wills, <a href="#Page_330">330</a>, <a href="#Page_333">333</a>.</li>
+
+<li class="indx">Poison, ordeal by, <a href="#Page_143">143</a>, <a href="#Page_146">146</a>.</li>
+
+<li class="indx">Pelagius I., Pope, case of law wager, in 6th century, <a href="#Page_209">209</a>.</li>
+
+<li class="indx">Poland, capture-marriages in <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Political methods, trial of judges by, in Greece, <a href="#Page_105">105</a>.</li>
+
+<li class="indx">Polygamy, definition of, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polygamy, established by Lamech, among Hebrews, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polygamy, among Hebrews, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polygamy, prohibited by Diocletian, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Polygamy, in Persia, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polygamy, in Turkey, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polygamy, in Rome, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polyandry, definition of, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Polyandry, origin of, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Polyandry, practiced in India, Thibet and Ceylon, <a href="#Page_16">16</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_345"></a>[345]</span>Preators, recalled in Rome, <a href="#Page_87">87</a>.</li>
+
+<li class="indx">Precipitation, punishment by, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Pressing to death (See <a href="#Peine"><i>peine forte et dure</i></a>), <a href="#Page_172">172</a>, <a href="#Page_195">195</a>.</li>
+
+<li class="indx">Primogeniture, effect of, on law of wills, <a href="#Page_317">317</a>.</li>
+
+<li class="indx">Priscot, C. J., on trial by battle for treason, <a href="#Page_118">118</a>.</li>
+
+<li class="indx">Privilege of sanctuary (See <a href="#Sanctuary">sanctuary</a>), <a href="#Page_244">244</a>, <a href="#Page_272">272</a>.</li>
+
+<li class="indx">Procedure of recall, in Athens, <a href="#Page_82">82</a>.</li>
+
+<li class="indx">Property rights of wife, by Roman law, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Property, protected by courts, alone, <a href="#Page_103">103</a>.</li>
+
+<li class="indx" id="Punishment">Punishment, as viewed by Beccaria, <a href="#Page_274">274</a>.</li>
+
+<li class="indx">Punishment, definition of, <a href="#Page_273">273</a>.</li>
+
+<li class="indx">Punishment, by Chatelet, of Paris, <a href="#Page_289">289</a>, <a href="#Page_292">292</a></li>
+
+<li class="indx">Punishment, by beheading, <a href="#Page_276">276</a>.</li>
+
+<li class="indx">Punishment, by Bilboes, <a href="#Page_303">303</a>.</li>
+
+<li class="indx">Punishment, by blinding, <a href="#Page_295">295</a>.</li>
+
+<li class="indx">Punishment, by boiling in oil, <a href="#Page_285">285</a>.</li>
+
+<li class="indx">Punishment, by branding, with hot iron, <a href="#Page_297">297</a>.</li>
+
+<li class="indx">Punishment, by crank, <a href="#Page_305">305</a>.</li>
+
+<li class="indx">Punishment, by burning to death, <a href="#Page_276">276</a>.</li>
+
+<li class="indx">Punishment, by burying alive, <a href="#Page_282">282</a>.</li>
+
+<li class="indx">Punishment, by crucifixion, <a href="#Page_280">280</a>.</li>
+
+<li class="indx">Punishment, by cutting off ears, <a href="#Page_296">296</a>.</li>
+
+<li class="indx">Punishment, by drawing and quartering, <a href="#Page_283">283</a>, <a href="#Page_284">284</a>.</li>
+
+<li class="indx">Punishment, by drowning, <a href="#Page_277">277</a>.</li>
+
+<li class="indx">Punishment, by ducking, <a href="#Page_303">303</a>.</li>
+
+<li class="indx">Punishment, by exposure to wild beasts, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Punishment, by flaying, <a href="#Page_300">300</a>.</li>
+
+<li class="indx">Punishment, by guillotine, <a href="#Page_293">293</a>.</li>
+
+<li class="indx">Punishment, by hanging, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Punishment, by inquisition, <a href="#Page_286">286</a>, <a href="#Page_288">288</a>.</li>
+
+<li class="indx">Punishment, by Massola, <a href="#Page_293">293</a>, <a href="#Page_294">294</a>.</li>
+
+<li class="indx">Punishment, by plucking off the hair, <a href="#Page_299">299</a>.</li>
+
+<li class="indx">Punishment, by precipitation, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Punishment, by rack, <a href="#Page_304">304</a>.</li>
+
+<li class="indx">Punishment, by sawing asunder, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Punishment, by scourging with thorns, <a href="#Page_302">302</a>.</li>
+
+<li class="indx">Punishment, by stocks, <a href="#Page_304">304</a>.</li>
+
+<li class="indx">Punishment, by strangling, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Punishment, by stoning to death, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Punishment, by wheel, <a href="#Page_301">301</a>.</li>
+
+<li class="indx">Punishments (See <a href="#Ancient_punishments">ancient punishments</a>), <a href="#Page_273">273</a>, <a href="#Page_306">306</a>.</li>
+
+<li class="indx">Purchase of justice, in England, <a href="#Page_91">91</a>.</li>
+
+<li class="indx">Putative marriages, <a href="#Page_26">26</a>.</li>
+
+<li class="ifrst">Q</li>
+
+<li class="indx" id="Quaint">Quaint and curious wills (See <a href="#Wills">wills, quaint and curious</a>), <a href="#Page_307">307</a>, <a href="#Page_334">334</a>.</li>
+
+<li class="indx">Quick, Juliana, case of, <a href="#Page_180">180</a>.</li>
+
+<li class="ifrst">R</li>
+
+<li class="indx">Rack, punishment, by, <a href="#Page_304">304</a>.</li>
+
+<li class="indx">Rape-marriages, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Recall of judges, <a href="#Page_74">74</a>, <a href="#Page_108">108</a>.</li>
+
+<li class="indx">Recall of judges, meaning, of, <a href="#Page_74">74</a>.</li>
+
+<li class="indx">Recall, among Medes and Persians <a href="#Footnote_166">(note), 78</a>.</li>
+
+<li class="indx">Recall, effect of, in Babylon and Greece, <a href="#Page_103">103</a>, <a href="#Page_104">104</a>.</li>
+
+<li class="indx">Recall, established by Cleisthenes, in Greece, <a href="#Page_82">82</a>.</li>
+
+<li class="indx">Recall, in ancient Greece, <a href="#Page_81">81</a>.</li>
+
+<li class="indx">Recall, in Athens, explained by Aristotle, <a href="#Page_82">82</a>.</li>
+
+<li class="indx">Recall, discarded in Athens, <a href="#Page_86">86</a>.</li>
+
+<li class="indx">Recall, in ancient Rome, <a href="#Page_87">87</a>.</li>
+
+<li class="indx">Recall, by Augustus Caesar, <a href="#Page_88">88</a>.</li>
+
+<li class="indx">Recall, by King, in England, <a href="#Page_94">94</a>.</li>
+
+<li class="indx">Recall, by “false-judgment” trials, in England, <a href="#Page_93">93</a>.</li>
+
+<li class="indx">Recall, in case of Rebecca Nurse, <a href="#Page_102">102</a>.</li>
+
+<li class="indx">Re-hearings, none, under Hammurabi’s code, <a href="#Page_78">78</a>.</li>
+
+<li class="indx">Retroactive marriages, <a href="#Page_26">26</a>.</li>
+
+<li class="indx">Rice, an emblem of fruitfulness, <a href="#Page_35">35</a>.</li>
+
+<li class="indx">Rice-throwing, <a href="#Page_34">34</a>.</li>
+
+<li class="indx">Richarda, Empress, trial of, by ordeal, <a href="#Page_159">159</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_346"></a>[346]</span>Richard de Anesty’s marriage, in 1143, <a href="#Page_21">21</a>.</li>
+
+<li class="indx">Richard, Duke of, and Gunnora, <a href="#Page_19">19</a>.</li>
+
+<li class="indx">Richard I., ordeal trials under, <a href="#Page_163">163</a>.</li>
+
+<li class="indx">Richard III., ordeal of bier, as presented in, <a href="#Page_166">166</a>.</li>
+
+<li class="indx">Right, writ of, procedure in battle under, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Ring, in marriages, origin of, <a href="#Page_33">33</a>.</li>
+
+<li class="indx">Roland, song of, <a href="#Page_135">135</a>.</li>
+
+<li class="indx">Roman forms of marriage, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Roman marriage laws basis of our own, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Roman marriage exalted, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Roman marriage a partnership relation, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">Romans, wager of law, under, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Rome, recall of judges in ancient, <a href="#Page_87">87</a>.</li>
+
+<li class="indx">Rome, sanctuary in, <a href="#Page_247">247</a>.</li>
+
+<li class="indx">Ruth and Boaz, espousal of, <a href="#Page_36">36</a>.</li>
+
+<li class="ifrst">S</li>
+
+<li class="indx">Sabines, rape of the <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Saint Louis, abolished trial by battle, in France, in 1260, <a href="#Page_134">134</a>.</li>
+
+<li class="indx">Sale-marriages, <a href="#Page_13">13</a>.</li>
+
+<li class="indx">Sale-marriages, in Cnut’s time, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Sale-marriages, recognized by church, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Salem witch trials, <a href="#Page_62">62</a>, <a href="#Page_68">68</a>.</li>
+
+<li class="indx">Sale, of justice in old England, <a href="#Page_90">90</a>.</li>
+
+<li class="indx">Samuel, Mother, persecution of, <a href="#Page_56">56</a>.</li>
+
+<li class="indx" id="Sanctuary">Sanctuary, privilege of, <a href="#Page_244">244</a>, <a href="#Page_272">272</a>.</li>
+
+<li class="indx">Sanctuary, definition of, <a href="#Page_244">244</a>.</li>
+
+<li class="indx">Sanctuary, how claimed, <a href="#Page_258">258</a>, <a href="#Page_259">259</a>.</li>
+
+<li class="indx">Sanctuary, under Mosaic code, <a href="#Page_244">244</a>.</li>
+
+<li class="indx">Sanctuary, in Greece and Rome, <a href="#Page_247">247</a>.</li>
+
+<li class="indx">Sanctuary, under Alfred, <a href="#Page_251">251</a>.</li>
+
+<li class="indx">Sanctuary, under Constantine, <a href="#Page_248">248</a>.</li>
+
+<li class="indx">Sanctuary, under Anglo-Saxons, <a href="#Page_249">249</a>.</li>
+
+<li class="indx">Sanctuary, under Athelstan, <a href="#Page_252">252</a>.</li>
+
+<li class="indx">Sanctuary, under Ina, <a href="#Page_251">251</a>.</li>
+
+<li class="indx">Sanctuary, under Edward the Confessor, <a href="#Page_254">254</a>.</li>
+
+<li class="indx">Sanctuary, under William the Conqueror, <a href="#Page_252">252</a>.</li>
+
+<li class="indx">Sanctuary, abjuration of realm, in, <a href="#Page_250">250</a>.</li>
+
+<li class="indx">Sanctuary, under Edward I., <a href="#Page_256">256</a>.</li>
+
+<li class="indx">Sanctuary, in reign of Henry IV., <a href="#Page_259">259</a>.</li>
+
+<li class="indx">Sanctuary, under Henry VII., <a href="#Page_257">257</a>, <a href="#Page_262">262</a>.</li>
+
+<li class="indx">Sanctuary, curtailed by Henry VIII., <a href="#Page_267">267</a>.</li>
+
+<li class="indx">Sanctuary, repealed by James I., <a href="#Page_268">268</a>.</li>
+
+<li class="indx">Sanctuary, in Scotland, <a href="#Page_265">265</a>.</li>
+
+<li class="indx">Sanctuary, under Queen Mary, <a href="#Page_259">259</a>.</li>
+
+<li class="indx">Sanctuary, claimed by Queen Elizabeth, <a href="#Page_260">260</a>.</li>
+
+<li class="indx">Sanctuary, at Hexham, <a href="#Page_253">253</a>.</li>
+
+<li class="indx">Sanctuary, in literature, <a href="#Page_269">269</a>, <a href="#Page_270">270</a>.</li>
+
+<li class="indx">Sawing asunder, punishment by, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Saxons, sanctuary under, <a href="#Page_249">249</a>.</li>
+
+<li class="indx">Saxons, wager of law, under, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Scipio, trial by battle before, <a href="#Page_126">126</a>.</li>
+
+<li class="indx">Scotland, persecutions for witchcraft in, <a href="#Page_57">57</a>.</li>
+
+<li class="indx">Scotland, sanctuary, in, <a href="#Page_265">265</a>.</li>
+
+<li class="indx">Scott, Sir Walter’s references to trial by battle, <a href="#Page_137">137</a>, <a href="#Page_138">138</a>.</li>
+
+<li class="indx">Scott’s “Minstrelsy of Scottish Border”, <a href="#Page_166">166</a>.</li>
+
+<li class="indx">Scourge, recall known as, in Athens, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Scourging, with thorns, punishment, by, <a href="#Page_302">302</a>.</li>
+
+<li class="indx">Selden, gives origin of marriage-ring, <a href="#Page_33">33</a>.</li>
+
+<li class="indx">Selden, on trial by battle, <a href="#Page_111">111</a>.</li>
+
+<li class="indx">Selden, procedure of trial by battle by, <a href="#Page_122">122</a>, <a href="#Page_124">124</a>.</li>
+
+<li class="indx">Sennacherib, will of, <a href="#Page_310">310</a>.</li>
+
+<li class="indx">Shakespeare’s reference to trial by battle, <a href="#Page_136">136</a>, <a href="#Page_137">137</a>.</li>
+
+<li class="indx">Shakespeare’s reference to maiden-rent <a href="#Footnote_62">(note), 30</a>.</li>
+
+<li class="indx">Shakespeare, mention of the gemmal ring, by <a href="#Footnote_81">(note), 35</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_347"></a>[347]</span>Shakespeare, illustrations of <i>peine forte et dure</i>, by, <a href="#Page_192">192</a>, <a href="#Page_193">193</a>.</li>
+
+<li class="indx">Shakespeare’s reference to sanctuary, <a href="#Page_269">269</a>.</li>
+
+<li class="indx">Shakespeare’s will, <a href="#Page_324">324</a>.</li>
+
+<li class="indx">Shechem’s negotiation for Dinah, <a href="#Page_31">31</a>.</li>
+
+<li class="indx">Shells, used for votes on Athenian recall, <a href="#Page_82">82</a>.</li>
+
+<li class="indx">Shoe, custom of throwing, <a href="#Page_35">35</a>.</li>
+
+<li class="indx">Sisamnes, recall of <a href="#Footnote_166">(note), 78</a>.</li>
+
+<li class="indx">Smock-marriages, <a href="#Page_37">37</a>, <a href="#Page_42">42</a>.</li>
+
+<li class="indx">Solomon, polygamy of, <a href="#Page_15">15</a>.</li>
+
+<li class="indx">Sorcery, law of, <a href="#Page_45">45</a>, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">Spartans, marriages by capture, among <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Stafford, Humphrey, sanctuary claimed by, <a href="#Page_262">262</a>.</li>
+
+<li class="indx">St. Cunigundi, trial of, by ordeal, <a href="#Page_159">159</a>.</li>
+
+<li class="indx">Standing mute (See <a href="#Peine"><i>peine forte et dure</i></a>), <a href="#Page_172">172</a>, <a href="#Page_195">195</a>.</li>
+
+<li class="indx">Standing mute, plea of not guilty, for, in 1827, <a href="#Page_190">190</a>.</li>
+
+<li class="indx">Stedinger, persecutions of, <a href="#Page_51">51</a>.</li>
+
+<li class="indx">Stocking-throwing, <a href="#Page_34">34</a>, <a href="#Page_37">37</a>.</li>
+
+<li class="indx">Stocks, punishment, by, <a href="#Page_304">304</a>.</li>
+
+<li class="indx">Stone’s case of clergy, <a href="#Page_232">232</a>.</li>
+
+<li class="indx">Stoning to death, punishment by, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Strangeways, case of Major, in 1657, <a href="#Page_185">185</a>.</li>
+
+<li class="indx">Strangling, punishment by, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Surgeons, under Hammurabi, <a href="#Page_81">81</a>.</li>
+
+<li class="indx">Sweden, trial by battle in, <a href="#Page_111">111</a>.</li>
+
+<li class="indx">Syracuse, the recall in, <a href="#Page_86">86</a>.</li>
+
+<li class="ifrst">T</li>
+
+<li class="indx">Tartars, marriages by <a href="#Footnote_6">(note), 13</a>.</li>
+
+<li class="indx">Templars, persecutions of, <a href="#Page_52">52</a>.</li>
+
+<li class="indx">Testimony, value of, in time Henry II., <a href="#Page_154">154</a>.</li>
+
+<li class="indx">Teutberga, trial of, by ordeal, <a href="#Page_161">161</a>, <a href="#Page_162">162</a>.</li>
+
+<li class="indx">Themistocles, recall of, <a href="#Page_83">83</a>.</li>
+
+<li class="indx">Testament (See <a href="#Wills">wills, quaint and curious</a>), <a href="#Page_307">307</a>, <a href="#Page_334">334</a>.</li>
+
+<li class="indx">Thackeray’s references to trial by battle, <a href="#Page_139">139</a>.</li>
+
+<li class="indx">Theodosius, law against marriages by, <a href="#Page_17">17</a>.</li>
+
+<li class="indx">Thibet, polyandry in, <a href="#Page_16">16</a>.</li>
+
+<li class="indx">“Third Law”, wager by, in 14th century, <a href="#Page_204">204</a>.</li>
+
+<li class="indx">Thomas A’Becket, and benefit of clergy, <a href="#Page_226">226</a>.</li>
+
+<li class="indx">Treason, battle could be stopped during trial of, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Treason, benefit of clergy did not extend to, <a href="#Page_228">228</a>.</li>
+
+<li class="indx">Trent, Council of, requiring religious ceremony, <a href="#Page_20">20</a>.</li>
+
+<li class="indx">Trials in ancient Babylon, <a href="#Page_79">79</a>.</li>
+
+<li class="indx">Trial by battle, <a href="#Page_109">109</a>, <a href="#Page_140">140</a>.</li>
+
+<li class="indx">Trial by ordeal, <a href="#Page_141">141</a>, <a href="#Page_170">170</a>.</li>
+
+<li class="indx">Trial of witches, <a href="#Page_60">60</a>, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">Tudor, Owen, claimed sanctuary, <a href="#Page_260">260</a>.</li>
+
+<li class="ifrst">U</li>
+
+<li class="indx">Unclergyable crimes, <a href="#Page_233">233</a>.</li>
+
+<li class="indx">Uncles and nieces, marriages between, <a href="#Page_18">18</a>.</li>
+
+<li class="indx">United States, clergy claimed in, <a href="#Page_239">239</a>, <a href="#Page_241">241</a>.</li>
+
+<li class="indx">United States, clergy abolished in, in 1790, <a href="#Page_236">236</a>.</li>
+
+<li class="indx">United States, cases of <i>peine forte et dure</i>, in, <a href="#Page_187">187</a>, <a href="#Page_190">190</a>.</li>
+
+<li class="indx">United States, abolished <i>peine forte et dure</i>, by act of Congress, in 1825, <a href="#Page_191">191</a>.</li>
+
+<li class="indx">United States, punishment by ducking, in, <a href="#Page_303">303</a>, <a href="#Page_304">304</a>.</li>
+
+<li class="indx">United States, law wager in, <a href="#Page_219">219</a>.</li>
+
+<li class="indx">Upton, trial by battle of, <a href="#Page_130">130</a>.</li>
+
+<li class="indx"><i>Usus</i>, marriage by, under Roman law, <a href="#Page_16">16</a>.</li>
+
+<li class="ifrst">V</li>
+
+<li class="indx">Varus, Quintilius’ observations on trial by battle, <a href="#Page_110">110</a>.</li>
+
+<li class="indx">Virgil, will of, <a href="#Page_311">311</a>.</li>
+
+<li class="indx">Vladimir, his espousal of the daughter of Raguald, <a href="#Page_36">36</a>.</li>
+
+<li class="indx">Votes, in Athenian recall, <a href="#Page_82">82</a>.</li>
+
+<li class="ifrst">W</li>
+
+<li class="indx" id="Wager_of_law">Wager of law, <a href="#Page_196">196</a>, <a href="#Page_220">220</a>.</li>
+
+<li class="indx">Wager of law, definition of, <a href="#Page_196">196</a>.</li>
+
+<li class="indx">Wager of law, origin of, <a href="#Page_199">199</a>.</li>
+
+<li class="indx">Wager of law, procedure in, <a href="#Page_197">197</a>, <a href="#Page_198">198</a>.</li>
+
+<li class="indx">Wager of law, in ancient Babylon, <a href="#Page_197">197</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_348"></a>[348]</span>Wager of law, under Mosaic code, <a href="#Page_196">196</a>.</li>
+
+<li class="indx">Wager of law, under Alfred, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Wager of law, under Wihtraed, <a href="#Page_200">200</a>.</li>
+
+<li class="indx">Wager of law, description of, by Bracton, <a href="#Page_201">201</a>, <a href="#Page_202">202</a>.</li>
+
+<li class="indx">Wager of law, compurgators in, <a href="#Page_198">198</a>.</li>
+
+<li class="indx">Wager of law, by oath-helpers, <a href="#Page_205">205</a>, <a href="#Page_207">207</a>.</li>
+
+<li class="indx">Wager of law, observations of Coke, on, <a href="#Page_200">200</a>.</li>
+
+<li class="indx">Wager of law, in cases of <i>Nil debit</i>, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Wager of law, kinds of, in criminal cases, <a href="#Page_204">204</a>.</li>
+
+<li class="indx">Wager of law, in debt and detinue <a href="#Footnote_478">(note), 207</a>.</li>
+
+<li class="indx">Wager of law, trial of churchmen by, <a href="#Page_210">210</a>.</li>
+
+<li class="indx">Wager of law, case of Pope Pelagius I., in 6th century, <a href="#Page_209">209</a>.</li>
+
+<li class="indx">Wager of law, under Saxons, <a href="#Page_197">197</a>.</li>
+
+<li class="indx">Wager of law, under Glanville, <a href="#Page_200">200</a>.</li>
+
+<li class="indx">Wager of law, irrational nature of procedure in, <a href="#Page_208">208</a>.</li>
+
+<li class="indx">Wager of law, and assize of Clarendon, in 1166, <a href="#Page_209">209</a>.</li>
+
+<li class="indx">Wager of law, under Edward III., <a href="#Page_202">202</a>.</li>
+
+<li class="indx">Wager of law, under Henry VI., <a href="#Page_206">206</a>, <a href="#Page_207">207</a>, <a href="#Page_212">212</a>.</li>
+
+<li class="indx">Wager of law, under Henry VIII., in 1527 <a href="#Footnote_499">(note), 213</a>.</li>
+
+<li class="indx">Wager of law, statute of Elizabeth on, <a href="#Page_208">208</a>.</li>
+
+<li class="indx">Wager of law, abolished in England, in 1833, <a href="#Page_208">208</a>.</li>
+
+<li class="indx">Wager of law, in United States, <a href="#Page_219">219</a>.</li>
+
+<li class="indx">Wager of law, case of Gregory of Tours, <a href="#Page_209">209</a>.</li>
+
+<li class="indx">Wager of law, trial of Alice Colynbourgh, by, in 1435, <a href="#Page_211">211</a>.</li>
+
+<li class="indx">Wager of law, Slade’s case, <a href="#Page_213">213</a>.</li>
+
+<li class="indx">Wager of law, case of Robert Welby, in 1492, <a href="#Page_213">213</a>.</li>
+
+<li class="indx">Wager of law, miscellaneous cases of, <a href="#Page_203">203</a>, <a href="#Page_204">204</a>.</li>
+
+<li class="indx">“Waking” witches, <a href="#Page_59">59</a>.</li>
+
+<li class="indx">Waldenses, persecution of the, <a href="#Page_53">53</a>.</li>
+
+<li class="indx">Warbois, witches of, <a href="#Page_56">56</a>.</li>
+
+<li class="indx">Washington, will of General, <a href="#Page_327">327</a>.</li>
+
+<li class="indx">Water, ordeal by, <a href="#Page_143">143</a>, <a href="#Page_144">144</a>, <a href="#Page_149">149</a>.</li>
+
+<li class="indx">Webster, Daniel, plea of law wager by, <a href="#Page_219">219</a>, <a href="#Page_220">220</a>.</li>
+
+<li class="indx">Welby, case of Robert, in law wager, in 1492, <a href="#Page_213">213</a>.</li>
+
+<li class="indx">Wenham, Jane’s’ trial for witchcraft, <a href="#Page_61">61</a>.</li>
+
+<li class="indx">Westminster, statute of, on <i>peine forte et dure</i>, <a href="#Page_178">178</a>.</li>
+
+<li class="indx">Weston, Sir Richard, case of, in 1615, <a href="#Page_184">184</a>.</li>
+
+<li class="indx">Wheel, punishment, by, <a href="#Page_301">301</a>.</li>
+
+<li class="indx">Wild beasts, punishment by exposure to, <a href="#Page_279">279</a>.</li>
+
+<li class="indx">Will, definition of, <a href="#Page_307">307</a>.</li>
+
+<li class="indx">William Rufus, ordeals under, <a href="#Page_156">156</a>.</li>
+
+<li class="indx">William the Conqueror, ordeals, under, <a href="#Page_153">153</a>.</li>
+
+<li class="indx">William the Conqueror, sanctuary, under, <a href="#Page_252">252</a>.</li>
+
+<li class="indx">William III., judges under, <a href="#Page_94">94</a>.</li>
+
+<li class="indx">William IV., abolished wager of law, in 1833, <a href="#Page_208">208</a>.</li>
+
+<li class="indx">Will, of Jacob, <a href="#Page_309">309</a>.</li>
+
+<li class="indx">Will, of Sennacherib, <a href="#Page_310">310</a>.</li>
+
+<li class="indx">Will, of Aristotle, <a href="#Page_310">310</a>.</li>
+
+<li class="indx">Will, of Plato, <a href="#Page_310">310</a>.</li>
+
+<li class="indx">Will, of Virgil, <a href="#Page_311">311</a>.</li>
+
+<li class="indx">Will, of Henry II., <a href="#Page_315">315</a>.</li>
+
+<li class="indx">Will, of John of Gaunt, <a href="#Page_320">320</a>.</li>
+
+<li class="indx">Will, of Katherine of Aragon, <a href="#Page_321">321</a>.</li>
+
+<li class="indx">Will, of Shakespeare, <a href="#Page_324">324</a>.</li>
+
+<li class="indx">Will, of Jeremy Bentham, <a href="#Page_324">324</a>.</li>
+
+<li class="indx">Will, of William Penn, <a href="#Page_328">328</a>.</li>
+
+<li class="indx">Will, of Benjamin Franklin, <a href="#Page_326">326</a>.</li>
+
+<li class="indx">Will, of Chief Justice Marshall, <a href="#Page_327">327</a>.</li>
+
+<li class="indx">Will, of General Washington, <a href="#Page_327">327</a>.</li>
+
+<li class="indx" id="Wills">Wills, quaint and curious (See <a href="#Quaint">quaint and curious wills</a>), <a href="#Page_307">307</a>, <a href="#Page_334">334</a>.</li>
+
+<li class="indx">Wills, in ancient Egypt, <a href="#Page_309">309</a>.</li>
+
+<li class="indx">Wills, under Cnut, <a href="#Page_312">312</a>.</li>
+
+<li class="indx">Wills, in Anglo-Saxon, days, <a href="#Page_312">312</a>.</li>
+
+<li class="indx">Wills, during Glanville’s time, <a href="#Page_313">313</a>.</li>
+
+<li class="indx">Wills, under Edward IV., <a href="#Page_317">317</a>.</li>
+
+<li class="indx"><span class="pagenum"><a id="Page_349"></a>[349]</span>Wills, under Edward VI., <a href="#Page_318">318</a>.</li>
+
+<li class="indx">Wills, effect of primogeniture on, <a href="#Page_317">317</a>.</li>
+
+<li class="indx">Wills, effect of church’s influence, on, <a href="#Page_314">314</a>.</li>
+
+<li class="indx">Wills, of 14th century, <a href="#Page_319">319</a>.</li>
+
+<li class="indx">Wills, with charitable objects, <a href="#Page_323">323</a>.</li>
+
+<li class="indx">Wills, to animals, <a href="#Page_322">322</a>.</li>
+
+<li class="indx">Wills, poetic, <a href="#Page_330">330</a>, <a href="#Page_333">333</a>.</li>
+
+<li class="indx">Wills, in fiction, <a href="#Page_332">332</a>.</li>
+
+<li class="indx">Wisdom of independent judiciary, <a href="#Page_106">106</a>.</li>
+
+<li class="indx">Witch, definition of, <a href="#Page_45">45</a>.</li>
+
+<li class="indx">Witchcraft, law of, <a href="#Page_45">45</a>, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">Witchcraft, under Mosaic law, <a href="#Page_46">46</a>.</li>
+
+<li class="indx">Witchcraft, under Constantine, <a href="#Page_48">48</a>.</li>
+
+<li class="indx">Witchcraft, law of Charlemagne against, <a href="#Page_50">50</a>.</li>
+
+<li class="indx">Witchcraft, prohibited by Anglo-Saxon laws, <a href="#Page_49">49</a>.</li>
+
+<li class="indx">Witchcraft, persecution of the Stedinger under law of, <a href="#Page_51">51</a>.</li>
+
+<li class="indx">Witchcraft, in England, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">Witchcraft, laws against in England, <a href="#Page_57">57</a>, <a href="#Page_58">58</a>.</li>
+
+<li class="indx">Witchcraft, in France, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">Witchcraft, in Scotland, <a href="#Page_57">57</a>.</li>
+
+<li class="indx">Witchcraft, in Scotland, under Queen Mary, <a href="#Page_56">56</a>.</li>
+
+<li class="indx">Witchcraft, persecutions of the Templars, <a href="#Page_52">52</a>.</li>
+
+<li class="indx">Witchcraft, authorities upon, <a href="#Page_70">70</a>.</li>
+
+<li class="indx">“Witch of Walkerne”, <a href="#Page_61">61</a>.</li>
+
+<li class="indx">“Witch-finder General”, <a href="#Page_59">59</a>.</li>
+
+<li class="indx">Witches, trial of by Hammurabi’s code, <a href="#Page_46">46</a>.</li>
+
+<li class="indx">Witches, trial of by Mosaic law, <a href="#Page_46">46</a>.</li>
+
+<li class="indx">Witches, trial of by law of Twelve Tables, <a href="#Page_47">47</a>.</li>
+
+<li class="indx">Witches, punishment of, <a href="#Page_59">59</a>.</li>
+
+<li class="indx">Witches, of Warbois, <a href="#Page_56">56</a>.</li>
+
+<li class="indx">Witch-mania in Europe, <a href="#Page_54">54</a>, <a href="#Page_59">59</a>.</li>
+
+<li class="indx">Witch-trials, at Salem, <a href="#Page_62">62</a>, <a href="#Page_68">68</a>.</li>
+
+<li class="indx">Witnesses, compurgation by, <a href="#Page_158">158</a>.</li>
+
+<li class="indx">Writ of right, procedure in battle under, <a href="#Page_116">116</a>.</li>
+
+<li class="indx">Writ of right, procedure under, in full, <a href="#Page_120">120</a>, <a href="#Page_122">122</a>.</li>
+
+</ul>
+
+<div style='text-align:center'>*** END OF THE PROJECT GUTENBERG EBOOK 75835 ***</div>
+</body>
+</html>
+
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+This book, including all associated images, markup, improvements,
+metadata, and any other content or labor, has been confirmed to be
+in the PUBLIC DOMAIN IN THE UNITED STATES.
+
+Procedures for determining public domain status are described in
+the "Copyright How-To" at https://www.gutenberg.org.
+
+No investigation has been made concerning possible copyrights in
+jurisdictions other than the United States. Anyone seeking to utilize
+this book outside of the United States should confirm copyright
+status under the laws that apply to them.
diff --git a/README.md b/README.md
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+Project Gutenberg (https://www.gutenberg.org) public repository for
+book #75835 (https://www.gutenberg.org/ebooks/75835)