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 reasoning of Chief Justice Taney in the Merryman case, was published in the newspapers and received a wide circulation. In the spring term of 1862, while on the bench at Easton, he was arrested by J. L. McPhail, deputy provost-marshal of Baltimore. Refusing to recognize the authority of the provostmar-shal, and resisting arrest, he was taken by force and beaten about the head and face. After confinement for a time in Fort McHenry, he was transferred to Fort Lafayette, and then to Fort Delaware. He constantly demanded that he be furnished with a copy of the charges against him or be brought to trial. Neither was ever done, but he was unconditionally released on December 4, 1862, and as his place on the bench had not been filled, he returned to his duties. Undaunted by his experiences, he again charged the grand jury to bring indictments against the instruments of these arrests, but the vigorous action of the United States authorities had convinced the people that opposition was useless, and the grand jury returned no indictments. Judge Carmichael, disappointed at this lack of spirit, resigned his position and retired to his farm. Another case of interest was that of Mrs. Rose O'Neal Greenhow, the charming widow of Robert Greenhow, who was arrested on the 23d of August, 1861, on the charge of being a spy, confined for a time in her own house, and then transferred to the Old Capitol. After being confined until June 2, 1862, she was released and sent within the Confederate lines, after taking an oath that she would not return. With her were sent Mrs. Augusta Morris and Mrs. C. V. Baxley, against whom similar charges had been brought. In 1862, a partisan character began to be attached to the arrests. It was charged that many were arrested purely on account of politics. In some of the Western States these arrests influenced the elections of the year. In Ohio, an old man of seventy, Dr. Edson B. Olds, formerly a member of the United States House of Representatives for six years,
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