The University of Texas at Austin

Law in Popular Culture collection

Legal Studies Forum
Volume 16, Number 3 (1992)
reprinted by permission Legal Studies Forum

The LAW IN SPOON RIVER

JOHN V. ORTH
University of North Carolina School of Law*

     On May 29, 1914, Reedy "s Mirror carried the first installment of Spoon
River Anthology by "Webster Ford," the pseudonym of Chicago attorney Edgar
Lee Masters.1 The following year the serialized poems, rearranged and aug-
mented by fifty others, appeared between hard covers, bearing the author's
right name.2 Its title was a learned allusion to the Greek Anthology, a medieval
miscellany of ancient epigrams and poems, then in vogue among the classically
educated.3 The place name "Spoon River," with its mundane and even comic
connotations, was not meant to invite mocking comparisons with Greek city-
states but was simply the name of  Masters' fictional small town, a composite
of Petersburg and Lewistown, Illinois, where he grew up, near an actual stream
of that name.4 The classic reference was not, however, misplaced: in his poems
Masters wanted to write about life in general while describing one small town,
or as he put it, in words that were almost Greek, to "draw the macrocosm by
portraying the microcosm."5 To this end, he selected a huge cast of characters,
more even than in a Russian novel: over 243 in number, all drawn from the
town cemetery.6  Speaking from beyond the grave, each in a single brief poem
reflects on the meaning of life. As rearranged for publication in book form, the
epitaphs were placed in ascending order: "the fools, the drunkards, and the 
failures came first, the people of one-birth minds got second place, and the
heroes and the enlightened spirits came last"; Masters himself called it "a sort
of Divine Comedy."7  The somber dignity and sense of cosmic fatality in many
of the poems do lend a classic air; even the occasional examples of posthumous
gaiety seem poignant.
     Yet death has not brought resignation to those "sleeping on the hill."8
Furious passions rage through many of the poems, setting up tensions that still
vivify the book. Beneath the classic surface lie intense emotions, pathos, vio-
lence, and morbidity - preoccupations of romanticism, classicism's antithesis.
So raw and heartfelt are these emotions that they must express the author's
own deepest feelings. Neither has death conferred omniscience on the "under
tenants of the earth."9 Only the reader, connecting poem and poem, can see
the whole, a theatric device that imparts considerable momentum. From their
necropolis on the hill the deceased citizens of Spoon River, wittingly and
unwittingly, present a stark picture of small-town America as it was late in the
nineteenth century. With little change, one could apply to the Anthology the
line that Sinclair Lewis used only a few years later to be in Main Street: "This

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is America - a town of a few thousand, in a region of wheat and corn and
dairies and little groves."" 10
    Masters himself thought the First World War "destroyed the era out of 
which Spoon River came."11 In historical perspective, other and earlier forces 
such as urbanization and industrialism appear more active agents of destruction.
Chicago, which had been smaller than Spoon River in 1833, had a population
of over a million when Masters arrived there in 1892.12 More searing to many
Americans than war and social change was the collapse of small-town values as
the basis of American culture. By 1920 only an ironist would describe America
as "a town of a thousand," when it was plainly a city of a million. While the
urban professional classes, to which Masters belonged, were busily engaged in
creating a new American ethos,13 the reading public was ready for literary reas-
sessments of small-town life. "The Republic thunders past," as Whitman pro-
claimed, leaving Americans looking over their shoulders, trying to understand
what they had left behind. Spoon River was an instant best-seller, but it did not
satisfy the public's appetite for fictional re-creations and send-ups of small
towns. Winesburg, Ohio in 1919, as Sherwood Anderson recalled, was triggered
by Spoon River,14 and Gopher Prairie, Minnesota, immortalized in Main Street
in 1920, was on the same part of the map. By the time Thornton Wilder pro-
duced Our Town in 1938, during the Depression and on the eve of the Second
World War, turn-of-the-century, small towns, this time epitomized by Grover's
Corners, New Hampshire (complete with its cemetery on the hill), were bathed
in a nostalgic sunset glow.
     It is not surprising that law and lawyers figure in reconstructions of
small-town America. Since colonial days Americans had been known for
litigiousness, and law was the chosen career of many sons of the farm, as it had
been for Masters' father. As expected, lawyers are among those sleeping on the
hill above Spoon River. In fact, they are thick on the ground: eight practicing
lawyers and five judges out of a spirit population of about 250. The number
of  legal professionals may be even higher since careers are not identified in all
epitaphs.15 Of course, law was still a man's job in Spoon River, so only half
the population was eligible. (Actually less than a quarter of the poems are
about women, and the percentage of women falls significantly the "higher" one
rises.16) Illinois had in fact admitted its first woman to practice in 1873, but
the number of female lawyers remained negligible.17 The strength of the legal
community in Spoon River emerges clearly by comparison with the numbers
in other professions (also all male): three doctors18 and six clergymen.19
     Compared to Spoon River, Winesburg, Ohio is almost innocent of
lawyers. Joe Welling, the man of ideas," is the son of a deceased lawyer who
had served in the state legislature in Columbus.20 Tom Foster, who got drunk
one night, rooms in a little frame building owned by Old Rufus Whiting who

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had used it as a law office but who is now "too feeble and forgetful for the
practice of his profession."21 George Willard, the hero of the piece, once
soliloquized vaguely about law:
There is a law for armies and for men too .... The law begins with
little things and spreads out until it covers everything. In every little
thing there must be order, in the place where men work, in their
clothes, in their thoughts. I myself must be orderly. I must learn that
law. I must get myself into touch with something orderly and big that
swings through the night like a star. In my little way I must begin to
learn something, to give and swing and work with life, with the law.22
Law in Winesburg is a cloudy concept, charged with metaphysics, and lawyers
are relegated to the margins, dead or decrepit.
     Much the same is true of Main Street. Carol Kennicott's deceased father,
"the smiling and shabby, the learned and teasingly kind," had been a judge;23
he puts in a brief posthumous appearance late in the novel, not as an angry 
wraith, but as "the gray reticent judge who was divine love, perfect under-
standing."24 Carol herself, whose unhappy marriage to Doctor Will Kennicott
of Gopher Prairie is the theme of the novel, rejected her first suitor Steward
Snyder who planned to be "a big lawyer, maybe a judge."25 As if to underline
the turn away from law, there was also an unnamed "young lawyer" at the
gathering where Carol first met her future husband.26 While the doctor boost-
ed his hometown, the narrator even asked parenthetically: "(Why was she
thinking about Stewart Snyder?).27 Once settled in Gopher Prairie, Carol has
a brief flirtation with Guy Pollock, a colorless lawyer - he was once observed
in the Bon Ton Store "tentatively buying a modest gray scarf"28 - who is said
to write "regular poetry."29 Pollock seems to share the town's legal business
with the old Yankee Julius Flickerbaugh, "who handled more real estate than
law, and more law than justice,"30 and the once-mentioned A. Tennyson
O'Hearn, "the shyster lawyer."31  Gopher Prairie's lawyers are literally invisi-
ble from Main Street. In Carol's ten-minute tour of downtown she saw an
assortment of stores, the post office, the school, and a couple of banks; she saw
the sign for her husband's second-story office, but she saw no indication of any
law offices.32 Guy Pollock's chambers, we come to learn, are above the gro-
cery store.33 As Carol quickly realized, Gopher Praire is not even the county
seat.34 (Nor, it might be added, is Winesburg.35)
     Authors may of course include or exclude lawyers from their fiction for
many reasons: personal background, the demands of the story, sheer happen-
stance. A considerable number of works of fiction exploit the dramatic possi-
bilities of trials; Masters himself later varied the usual approach in his long
dramatic poem Domesday Book (1920), confining the action to the inquest
conducted by a coroner and six Crime, its detection, prosecution and

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punishment, is the subject of a specialized body of literature, both highbrow
and lowbrow. Points of law occasionally enter into the plots of novels and
plays.36 Yet law is more central to some artistic visions than others.  While
it may be idealized as the rneans to social harmony, it probably appeals more
to writers for whom conflict and the social need to resolve or at least contain
it are uppermost. If law is associated with conflict, it may also explain its
absence from certain works. Can it be an accident that law and lawyers are
missing altogether from Our Town?37
     Masters' background helps to explain why law would figure prominent-
ly in his art. "In his canon, in fact," as Charles E. Burgess has observed, "the
law is perhaps second only in weight of influence to the locale of his boyhood
and young manhood in central Illinois."38 Masters was the son of a lawyer,
was destined by his parents to a career in law, read law in his father's law
office, even formed a brief partnership with his father in Lewistown.39  In
Chicago he practiced law for over twenty years, during eight of which he was
Clarence Darrow's law partner.40 While famous for defending social underdogs
like strikers and anarchists, the firm of Darrow, Masters and Wilson was one
of the most successful in town, clearing from $25,000 to $35,000 a year for each
partner. Generally Masters wrote the briefs and organized the cases while
Darrow presented the oral arguments, but in at least one notable case concern-
ing free speech Masters himself argued before the US. Supreme Court.41 Even
after the breakup of the firm, Masters continued to prosper as a lawyer. His
eldest son Hardin recalled his parents' bourgeois life-style: a comfortable house
on Chicago's South Side with a full complement of servants, a cook and second
maid,  yardman, and chauffeur.42
     Masters was active in the Democratic Party, being drawn to its populist
and anti-imperialist wing. His hero was Thomas Jefferson and his enemies, Jef-
ferson's enemies: Alexander Hamilton and John Marshall. He published an
article attacking Chief Justice Marshal43 who, he later explained, "was then
being much celebrated since he had expounded the implied powers of the
Constitution and thus paved the way for America to seize the Philippines" in
the Spanish-American War of 1898.44 In 1901 the centenary of Marshall's
appointment to the chief justiceship was observed - in orthodox quarters by
the publication of laudatory sketches and the reprinting of famous decisions.45
Masters was personally acquainted with William Jennings Bryan, whom he
supported while the Peerless Leader was "athletic and radical" and not yet
theological and dour,"46 and on Woodrow Wilson's election to the presidency
in 1912 was actively considered for a federal court of appeals judgeship.47
When Masters was passed over, he was, as.he recollected, "freed to write Spoon
River."48 Although the partnership with Darrow had broken up, Masters
continued to represent labor unions. In 1914 thousands of Chicago waitresses
had gone on strike. Their employers sought an injunction against picketing,

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and Masters was hired to defend them - at a "satisfactory fee," he later compla-
cently recalled.49 Spoon River was written "all in the midst of the case for the
waitresses."50  The book's subsequent success freed Masters from his law prac-
tice - and gave him the opportunity to break out of his unhappy marriage.
Hilary Masters, his son by his second wife, recently speculated about his fa-
ther's career:
If the lightning had not struck, if there had been no epitaphs in a
country graveyard, he might have continued to practice law, to write
poetry under different pseudonyms - his lack of courage to acknowl-
edge the poetry suggests something about his character if not an uncon-
scious evaluation of the verse - and - to pay to have it published, a
pathetic, seedy amorist moving through the salons of Chicago, one
more bourgeois husband enduring a marriage that had become stale and
boring.51


      Masters' career affected his poetry in many ways, from the superficial
to the profound. Although many of the names in the Anthology are compound-
ed of boyhood memories, he confessed that he had devised some of the "curi-
ous" ones by recombining names he found "in lists of signers of the consti-
tution of Illinois and in other places."52 Reminiscing about his boyhood in
Lewistown, he recalled: "The courtroom was my drama and my movie the-
ater."53 Law and particularly the common law with its ingrained adversarial
process entered into his view of life: "My law studies, my natural cast of mind
made me see both sides of everything . . . ."54 Indeed, there is a sense in which
Spoon River reads more like a volume of the Illinois Reports than the Greek
Anthology: a vivid glimpse of life, often confronted by an opposing view, then
'with the turn of a page a glimpse of another aspect of life - all stereotyped
within a rigid form.
     Hilary's memoirs reveal how lawyerlike his father remained, long after
the active practice of law was over. The first view of the poet is in a nursing
home. "How are you doing?" Hilary asks. "Better. Much better," his father
replies sternly; the son's impression: "Masters, the lawyer, advising a client,
briefing a jury."55 Hilary, himself a writer, likened his father's poetry to "law
briefs in blank verse."56 He guessed that some of his father's many female
companions thought their intimate confidences would be looked on with a
poet's compassionate eye when actually they were recorded by "an attorney's
cool mind."57 In old age the poet even passed the time "making notes on some
of his old law cases."58 In another memory of his father, somewhat earlier,
Hilary remembers him repeating himself "like a patient attorney leading a dull
Witness."59
     Law marked the man; it also scarred him. Law was not Masters' chosen
career; it was chosen for him. From boyhood he had favored literature, so his

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legal education was later recalled as those "hard days when I was leaving my
beloved studies for the law."60 His years in Chicago were occupied in "doing
that in a business which destroyed every imaginative impulse, and took all my
strength and all my time."61 In short, "the law business tortured me."62 Mas-
ters still cherished the Horatian ideal of literary retreat, long a common refuge
of American lawyer-poets, but in Chicago he found himself  "not pursuing the
life of a contemplating poet, but the life of a drudging lawyer."63 He learned
the hard way that his high school teacher "spoke truth when she wrote me that
the law and literature were oil and water."64 Later reflecting on his life - and
unintentionally perhaps punning on his name - he concluded: "I feel that I
twisted my genius, my nature when I went into the law, and set my will to
master the law, and did master it."65
    Throughout his career as a lawyer, perhaps throughout his long life as
a poet, Masters' response to his profession was a mixture of submission and
rebellion. As a student in Lewistown, he was "all day in the law office reading
Chitty on Pleading and Greenleaf on Evidence."66 As a lawyer in Chicago, he
composed a long (unpublished) digest of Illinois cases on torts.67 So discrimi-
nating a critic as Darrow admired Masters objective legal mind and piercing
briefs.68 Yet the poet struggled to assert himself. Aware that his literary
ambitions disturbed his father, young Masters resorted to subterfuge: "In the
office, especially when I really began to read law under his tutorship, I often
had behind a lawbook some work of poetry or fiction or philosophy; so that
if he entered the office suddenly he would not catch me with Locke or Shel-
ley."69 The poet-behind-the-law-book was one strategy. At other times the
young Masters sought an acceptable compromise: "Somewhere I saw that
Byron had read Blackstone; and I thought I might do so, if Byron did, as a
matter of general culture. So I took to Blackstone, and enjoyed the Commen-
taries immensely. I then bought an abridged Blackstone, and finally committed
to memory all the definitions found in the full text."70 Perhaps by a special
alchemy oil and water could be made to mix. In Chicago the poet adopted a
different mentor: "I expected to write along the way, consoling myself with
Walter Scott's example, who wrote under a pseudonym while he was a lawyer
and a sheriff."71 Thus Webster Ford owed something to the author of Waver-
ley.
     The small-town lawyers of Lewistown and Petersburg, of Spoon River
in other words, who practiced law alone or in ephemeral partnerships, were
waning with the small towns they served. Masters remarked on their passing
in a memorial he wrote at the time of his father's death in 1925:
An era of the law business passed with him. It is not stories now, and
not speeches, and not first principles and originality, and not justice
coming out of the thought and feeling of a democracy gathered into a
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box of twelve men; but it is a system in legal mechanics, as a part of
the vast machinery which runs the imperial commerce of the world.72
Although still only a fraction of the profession, big-town lawyers organized in
rapidly growing law firms or employed in legal departments of corporations
represented the future. The sea change began during Masters' active career. At
the turn of the century, Chicago's largest law firms - both of them - had
seven lawyers apiece.73 Again Masters' response was mixed, at once boastful
and secretly envious. "I met the hard, shrewd, money-grabbing corporation and
business lawyers on their own ground, and fought them toe to toe."74 While
representing society's underdogs and campaigning for Bryan and populism,
Masters was drawn to the rich and powerful. In his autobiography he almost
admits that he married his first wife in hopes that her father, a Republican and
president of a local railroad, would find him lucrative preferment.75 He was
certainly bitterly disappointed when his father-in-law failed him, and lost his
own place to boot. In a revealing passage, Masters confessed: "I did not ap-
prove of what the corporations were doing, or what they required their lawyers
to do at times. Yet I thought I could work for one as a lawyer and retain my
integrity. I meant to do that, I think I could have done it; but I never had the
chance to work for one at all. They didn't want me."76
     For all his efforts to submit and succeed, Masters never quenched the
fire of his rebellion. Oil and water would not mix after all. In an extraordi-
nary passage in his autobiography, Masters describes himself as he was in the
spring of 1911 - in pain, the victim of violence, tortured, deformed, and also
full of self-pity. The passage must be set out in full:
Far back in the Lewistown days when I was reading Plato and Shelley
my father called me a "daydreamer;" now after eighteen years of the
law, what was I? Scientists can bombard the fruit fly with X rays and
alter its germ plasm until its offspring turn up with white eyes instead
of red, and with smaller wings. Cyclopean eyes can be created in frogs
by chemicals, and the development of frogs arrested by chemicals until
their mature specimens are no larger than bees. The law had been an
X ray to me, and many kinds of chemicals; the law, and my contacts
with so many varieties of people. And now imagine a human being
with one great eye in the center of his forehead with which he saw
everything with realistic clearness; but suppose him in retention of his
two normal eyes, which in their normality saw beauty where it was
not, and truth where it had never been. That was I who saw through
people with penetration, who could weigh arguments and facts judicial-
ly, but who with dreaming eyes looked down paths without seeing the
tangles all in all, Pyrrhonist as I was about life and success.77
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     The pain and barely repressed anger made the poet a difficult man and
a handicapped lawyer. He could not charm a jury. Darrow's biographer
described his subject's experience with Masters as "the only tragic relationship
of his life."78 Masters in his autobiography refused even to name his famous
partner; -while listing sixteen love affairs -with women identified by first name;
Masters referred to Darrow only as "a criminal lawyer,"79  "the head of our
firm,"80 my former law partner."81 Personal relations too were difficult
Hilary Masters thought his father harbored a lasting grudge against his parents,
especially his mother, for frustrating his literary career and forcing him into law
practice.82
     The lawyers of Spoon River reflect Masters' own experiences and
resentments. First comes Judge Somers. Despite what appears to be a judicial
title, Somers figures only as a lawyer.83 He singles out his achievement in
writing "a brief that won the praise of Justice Breese." (Despite a name that
seems too good to be true, Justice Sidney Breese was a real-life and respected
member of the Illinois Supreme Court.84)  For present purposes the point is
that a brief is the characteristic product of a practicing lawyer, not a sitting
judge. Penniwit, the Artist, Spoon River's photographer, later tells an equally
revealing anecdote about Judge Somers, whom he calls "attorney at law."
Peniwi prided himself on penetrating to the soul of his sitters, seeing perhaps
with a Cyclopean eye. One of Somers' natural eyes was crossed, and in order
to catch him as he truly was, Penniwit had to resort to stratagem. The photog-
rapher waited until the "Judge" got his cross-eye straight, then yelled "over-
ruled" (a truly judicial prerogative) and Somers' eye "turned up" in surprise.
Penniwit exulted: it was "the very best picture I ever took .... I caught him
just as he used to look / When saying 'I except"' - the latter, a lawyer's
phrase. Without pursuing the collateral issue of whether Penniwit's camera was
really penetrating to the soul or only recording the surface, one is reinforced
in the conviction that Somers is no more than a lawyer, a judge in name only,
not unlike another judge manque, Masters himself.
     Aside from the ambiguity of his career, Somers is most notable for
erudition coupled with neglect. His library, as we learn from the later epitaph
of Imanuel Ehrenhardt, was well stocked with philosophical works: Sir Wil-
liam Hamilton's lectures, Dugald Stewart, John Locke on the Understanding,
Descartes, Fichte, Schelling, Kant, and Schopenhauer. In addition to philoso-
phy, Somers had mastered the legal classics: he "knew Blackstone and Coke /
Almost by heart." One is reminded of the young Masters who sat in his
father's law office hiding Locke behind his lawbook and memorized all the
definition in Blackstone. Like Masters, too, Somers for all his learning is
unappreciated. From beyond the grave his querulous voice is heard asking why
Chase Henry, the town drunk, has a more elaborate tombstone than he does.

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could Masters, before the success of Spoon River Antbology, have expected any
more in the way of funerary monument?
     Next to Somers lies Kinsey Keene who expresses his rage and contempt
for the powers that be in forceful terms. As with the "Judge," Keene's profes-
sion is subject to initial uncertainty. In his own epitaph he says nothing about
his career, yet a later poem places it beyond doubt. Jack McGuire was tried for
murdering Logan, the Town Marshal, while drunk and his defense attorney was
Kinsey Keene. As McGuire tells it, Keene struck an unethical deal with the
presiding judge to secure a lesser sentence for his client:
My lawyer, Kinsey Keene, was helping to land
Old Thomas Rhodes for wrecking the bank,
And the judge was a friend of Rhodes
And wanted him to escape,
And Kinsey offered to quit on Rhodes
For fourteen years for me.85
The deal was done and may help to explain Keene's lordly contempt for Spoon
River. Masters prided himself on knowing how things worked in the real
world. In a corrupt system the best one could do was to secure a just result by
corrupt means, but in the process one dirtied oneself.
     Dirt is certainly what Keene flings at the leading figures in town: the
president of the bank, the editor of the principal paper, the pastor of the
leading church, the Prohibitionist mayor, the members of the "Social Purity
Club." In an elaborate insult, the lawyer recalls for them the last stand of the
Old Guard at Waterloo; he reminds them of the English colonel's gentlemanly
call, "Surrender, brave Frenchmen!"; then he takes his stand with the heroic
remnant of Napoleon's army. What Cambronne replied to the offer of surren-
der, "ere the English fire made smooth the brow of the hill / Against the
sinking light of day," Keene says "to you, and all of you, / And to you, 0
world." He wanted le mot de Cambronne to be carved on his tombstone. With
contempt, he disdains even to mention it: Merde! Shit!86
     If Judge Somers' earthly achievements were neglected after his death,
the lawyer in the next grave was denied even that transitory success. Unlike
the indomitable Kinsey Keene, hurling epithets from beyond the grave, Benja-
min Pantier died a defeated man, "broken, indifferent." He had enjoyed youth-
ful promise: "In the morning of life I knew aspiration and saw glory," but was
then snared (like Masters) by an unhappy marriage. Mrs. Benjamin Pantier,
buried by his side, recalled his earlier high spirits, expressed by constant quota-
tions of jingling verse.(ironically, the example given was from William Knox's
popular poem "Mortality": "Oh, why should the spirit of mortal be proud?"87)
Mrs. Pantier, a self-described lady of "delicate tastes," found her husband repul-
sive, physically as well as spiritually. Although she confessed to thinking of

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"the marital relation" every time she saw him - indeed, as we shall see she
thought of it even when she saw a studhorse - the idea of having relations
with him filled her "with disgust." In terms of poetic taste, her superiority was
expressed in her preference for Wordsworth's "Ode." (The full title of the
poem is not given, just as Knox's poem is unnamed, yet the "Ode to Immortali-
ty" and "Mortality" form a neat contrast and generate multiple ironies in the
graveyard context.) So Pantier ended up living in a dingy room back of his
dingy office, in partnership with Nig, his faithful dog, with whom he is buried
"Our story," he says, "is lost in silence." While Kinsey Keene curses the leading
citizens of Spoon River including the Social Purity Club (of which Mrs. Pantier
was president88), Benjamin Pantier seeks only oblivion: "Go by, mad world!,,
     Another lawyer and broken man in Spoon River is State's Attorney
Fallas. While Kinsey Keene was a defense attorney, Fallas was a prosecutor,
self-identified as nemesis:
I, the scourge-wielder, balance-wrecker,
Smiter with whips and swords;
I, hater of the breakers of the law;
I, legalist, inexorable and bitter ....
He recalls one of Spoon River's sensational murder trials in which he prosecut-
ed Barry Holden, for the hatchet slaying of his pregnant wife. Justice miscar-
ried in People v. Holden, as Fallas later learns, because he drove the jury to hang
one who was really not guilty by reason of insanity. A higher justice caught
up with the State's Attorney though, through the malpractice of another
professional: "Steel forceps fumbled by a doctor's hand / Against my boy's
head as he entered life / Made him an idiot." The experience led Fallas to
study the science of mental illness and to abandon his former career: "the
world of those whose minds are sick / Became my work in life, and all my
world." In conclusion Fallas attributes to his son, "poor ruined boy," all his
"deeds of charity."
     So far the legal community in Spoon River is cast in the traditional
mold: solo practitioners, so far as we can see, whose business is the familiar
one of prosecuting and defending criminals. With John M. Church the first
example of the new style corporate lawyer appears, and the legal business shifts
from the criminal to the civil side. Church characteristically represented a
railroad and an insurance company; the railroad, the principal means of trans-
portation in the nineteenth century and the "most powerful single initiator" of
industrial development,89 and insurance, the means by which corporations
converted damages caused by their wrongs into a predictable cost of doing
business. Church's client insured the owners of a mine at which some unde-
scribed catastrophe maimed or killed many miners. On behalf of his client, the
lawyer "pulled the wires with judge and jury / And the upper courts, to beat

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the claims / Of the crippled, the widow and orphan" - the latter, of course,
the special care of the church in another sense. There is no indication whether
the wire-pulling in question involved corrupt means, such as tampering with
judge and jury, or simply pro-business legal doctrines, with which contempo-
rary American law was well stocked. Masters, labor lawyer and tort law
specialist, was professionally aware of all the possibilities. By whatever means
Church won, it earned him, he claimed, a personal fortune as well as the praise
of the bar association. But fate caught up with corporate-lawyer Church as it
had caught up with State's Attorney Fallas. The deceased reported that figura-
tively, as well apparently as literally, "the rats devoured my heart / And a
snake made a nest in my skull!" It was this fate, of course, that Masters knew
awaited "the hard, shrewd, money-grabbing, corporation and business lawyers,"
a fate he thought he could have avoided if he had been in their place.
     Jefferson Howard is another of Spoon River's lawyers whose career is
not obvious from his epitaph. Thanks only to Judge Selah Lively is Howard's
place at the bar made known. Howard suffers the fate of other legal profession-
als in Spoon River: neglect and abandonment. Named after Jefferson, Masters'
populist hero, he is a native of Virginia whom fate brought to Spoon River.
It is difficult to resist the idea that the poet is sympathetic to lawyer Howard.
He fights Masters' enemies: "Republicans, Calvinists, merchants, bankers;" he
is the "foe of the church with its charnel dankness," the "friend of the human
touch of the tavern." And in the end he is betrayed by everyone, family
included. Like Benjamin Pantier, Howard is left "facing the silence - facing
the prospect / That no one would know of the fight I made" - the very pros-
pect Masters himself faced before the lightning struck and the success of Spoon
River Anthology freed him from marriage and career.
     W. Lloyd Garrison Standard, named for the famous abolitionist, was a
believer in causes. In a parody of nineteenth-century enthusiasms, Standard
lurched from one extreme to another:
Vegetarian, non-resistant, free-thinker, in ethics a Christian . . .
Carnivorous, avenger, believer and pagan;
Continent promiscuous, changeable, treacherous, vain ....
Using an image reminiscent of corporate lawyer Church, whose heart was
devoured by rats and whose skull was a snake's nest, Standard confessed to
having a "heart cored out by the worm of theatric despair." Yet a mysterious
epiphany was reserved for him, associated with his practice of law. In an
obscure episode, some "patriot scamps" including one with a telltale name, Silas
Demerit, burned down the old courthouse so that a new and presumably
modern one would have to be built. Standard who represented the arsonists
pleaded them guilty, and Demerit, at least, spent time in the state penitentiary
at Joliet. In some undisclosed connection with that case, the profane Kinsey

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Keene, Standard's fellow lawyer, "drove through / The card-board mask of
life with a spear of light." After this revelation, whatever it was, Standard was
forced to admit the truth about himself. "The pyramid of my life was nought
but a dune, / Barren and formless, spoiled at last by the storm."
     The final lawyer in Spoon River, Harmon Whitney, repeats and rein-
forces many of the characteristics already seen. Like Benjamin Pantier, Whit-
ney blames his marriage for his unhappy life, his soul's "wound gangrened / By
love for a wife who made the wound, / With her cold white bosom, treason-
ous, pure and hard, / Relentless to the last . . . ." A lover of poetry like
Pantier, Whitney is left "spouting to gaping yokels pages of verse, / Out of the
lore of golden years." Filled with self-pity, he sees himself "gifted with tongues
and wisdom, / Sunk here to the dust of the justice court, / A picker of rags in
the rubbage of spites and wrongs." A curious insight into the "rubbage" is
provided in a later epitaph. Felix Schmidt began with a two-room house and
five acres of land to shelter and support his large family.
One day lawyer Whitney came along
And proved to me that Christian Dallman,
Who owned three thousand acres of land
Had bought the eighty that adjoined me
In eighteen hundred and seventy-one
For eleven dollars, at a sale for taxes,
While my father lay in his mortal illness.
So the quarrel arose and I went to law.
In court it was proved, notwithstanding what lawyer Whitney had "proved" to
Schmidt, that Dallman's title under the tax deed was good, and a survey showed
that the deed even covered the five acres on which Schmidt lived. Humbly and
without recrimination, Schmidt accepted dispossession ("It served me right for
stirring him up.") and went to work as Dallman's tenant.
     In his own epitaph Whitney makes no mention of Schmidt v. Dallman.
(Indeed, if the "justice court" to which he had sunk was the court of the justice
of the peace, then the case was probably not among the rubbage picked over
there: jurisdiction was limited to what we would now call small claims.)
Pursuing instead his theme of great literature, the lawyer regrets that his soul
could not react to his marital unhappiness "like Byron's did, in song, in some-
thing noble." Masters, who had earlier followed Byron's example in reading
Blackstone, was transmuting his own unhappiness, marital and professional,
into the bitter songs of the Anthology. Whitney's final image, recalling his
fellow lawyers Church and Standard, as well as Masters' own horrific image of
animals deformed by X rays, is of his soul "turned on itself like a tortured
snake."

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      The lawyers of Spoon River are so many facets of Edgar Lee Masters'
own experience in his profession. They are alter egos created out of distinct
emotions and given a poetic life of their own. Their most remarkable charac-
teristic is the confusion surrounding their career. Is Judge Somers a judge?
With Kinsey Keene and Jefferson Howard one must look elsewhere to learn
their roles. Neither Garrison Standard nor Harmon Whitney are unequivocally
identified as lawyers in their own epitaphs. Clarity is reserved only for the
defeated Benjamin Pantier, the humbled State's Attorney Fallas, and the despica-
ble John M. Church. The lawyers of Spoon River are largely fools, drunkards,
or failures, buried together in the first third of the cemetery. The practice of
law is contaminating, preventing those engaged in it from aspiring to higher,
spiritual levels; inevitably involved with crime and corruption, lawyers are
weighed down, "of the earth, earthy." Few are endowed with even "one-birth
minds," meriting burial in the second third of the cemetery. While Masters'
comparison of Spoon River with the Divine Comedy should not be pushed too
far, it suggests that Jefferson Howard, Garrison Standard, and Harmon Whitney
rose the highest. But the latter two - one with a worm-eaten heart, the other
with a soul like a tortured snake - surely do not belong above the middle
rounds of purgatory, if not actually down below.
     The Spoon River judges are no better than the lawyers they presided
over. Justice Arnett is the first to speak, and he describes his death in a re-
markable courtroom accident. The iron-bound docket book, kept on a shelf
above his head, was jarred loose and dealt him the fatal blow. What jarred it
loose was an explosion at the canning works, which (as we shall see) led to a
lawsuit by an injured workman, Butch Weldy. The suit was lost because of one
of those pro-business rules that insurance lawyer Church may have relied on,
so the judge's death in what he calls "the seat of justice" may be a form of
poetic retaliation, if not justice. The judge himself, of course, could not make
the moral connection, only the causal one. As he lay dying, he was aware of
the leaves of the docket fluttering around him.
Those are not leaves [he said],
Why, can't you see they are days and days
And the days and days of seventy years?
And why do you torture me with leaves
And the little entries on them?
In the context of the poem Arnett's plea may arouse sympathy, but in the
larger context of Spoon River it is patently ironic. Arnett was probably a
justice of the peace, his court the "justice court" to which lawyer Whitney had
sunk. Its jurisdiction included minor criminal cases - the "rubbage of spites
and wrongs" - such as Curl Trenary's case against Knowlt Hoheimer for the
theft of hogs and the repeated prosecutions of Daisy Fraser, the town prosti-

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tute. Daisy provided her own comment on the quality of justice in Spoon
River. Comparing her situation with the hypocrisy and compromises of the
town's leading citizens, she contrasted their stinginess in supporting the town
with her own forced contributions: she "never was taken before Justice Arnett
/ Without contributing ten dollars and costs / To the school fund of Spoon
River!" The docket book recorded such judgments, yet in a larger sense the
"little entries" in the death-dealing docket included cases like Schmidt v. Dall-
man, Butch Weldy's case, the claims of "the crippled, the widow and orphan",
beaten by lawyer Church, and the murder trials like People v. McGuire and
People v. Holden. Justice Arnett was not the only person in Spoon River to be
tortured with the leaves of the docket.
     It was the nameless Circuit Judge who heard the case filed by Butch
Weldy. After he "got religion and steadied down," Butch was hired by the
Spoon River Canning Company; he later sued his employer in tort for injuries
caused by an industrial accident. The defendant company was part of Thomas
Rhodes' financial empire, which included the water works, the store, and the
wagon works, in addition to the bank. Henry Phipps, the Sunday school
superintendent, was the "dummy president" of the Canning Company, but it
was Rhodes' son, Ralph, who was the prime mover. Butch states the facts of
his case succinctly:
... every morning I had to fill
The tank in the yard with gasoline,
That fed the blow-fires in the sheds
To heat the soldering irons.
And I mounted a rickety ladder to do it,
Carrying buckets full of the stuff.
One morning, as I stood there pouring,
The air grew still and seemed to heave,
And I shot up as the tank exploded,
And down I came with both legs broken,
And my eyes burned crisp as a couple of eggs
For someone left a blow-fire going,
And something sucked the flame in the tank.90
Today Weldy's injuries would be covered by a state workers' compensation
statute; indeed, as Masters wrote, Illinois was moving to such a system,91 but
under the ancien regime of tort liability Weldy had to prove the company's
fault in order to recover.
     Since the first half of the nineteenth century, in other words since the
beginning of the Industrial Revolution in America, the legal doctrine of corn-
mon employment had blocked efforts by workers to make their masters pay
the costs of injuries incurred in their service. First enunciated in the leading

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English case of Priestley v. Fowler (1837)92 and popularized in America by
Massachusetts Chief Justice Lemuel Shaw in Farwell v. Boston and Worcester
R.R. (1842),93  the doctrine meant that an employer was not liable to an em-
ployee for injuries caused by the fault of a fellow employee engaged in the
common employment. Closely associated was the doctrine of assumption of
the risk; employees were presumed to accept the ordinary risks of their employ-
ment. Between them, the two doctrines were potent in preventing the victims
of industrial accidents from reducing corporate profits. John M. Church
probably used one or both of them on behalf of the insurance company to beat
the claims of "the crippled, the widow and orphan." In Weldy v. Canning Co.
the Circuit Judge ruled that whoever left the blow-fire going was Butch's
"fellow-servant," so."Old Rhodes's son didn't have to pay." Butch records his
own feeble protest:
I sat on the witness stand as blind
As Jack the Fiddler, saying over and over,
"I didn't know him at all."
In the poetic universe of Spoon River the worker got this much revenge on the
law: Justice Arnett had been sitting in the "seat of justice" when the shock
waves from the explosion dislodged the iron-bound docket book that killed
him.
     With a vision posthumously cleared, the Circuit judge confesses that he
earned "the anger of the wronged, / The curses of the poor" by "deciding cases
on the points the lawyers scored, / Not on the right of the matter." Like
State's Attorney Fallas, he was a "legalist." Voicing his regret he instances,
however, not the injustices he did to the maimed, the widows and orphans, but
the death sentence he passed on the murderer Hod Putt. Since Putt is buried
in the first grave in Spoon River, we know something of the particulars of his
crime. "Grown tired of toll and poverty," particularly as others grew rich from
ill-gotten gains, Putt "robbed a traveler one night near Proctor's Grove,
Killing him unwittingly while doing so." Putt seems resigned to his fate, yet
the man who presided over People v. Putt is tortured by the feeling that the
murderer "was innocent in soul compared with me." Is this any more than a
legal version of Calvinist breast-beating over sin and unworthiness? Would any
self-respecting legal system want to exonerate Hod Putt, however hard put
upon he was, for robbing and killing an innocent traveler? Far better to lament
the actual miscarriages of justice. So confused is the moral universe of Spoon
River's judges that when one has any qualms of conscience at all, he strains at
g nats while swallowing camels. Legalist that he is, he cannot draw the distinc-
tions necessary for practical justice.
     Unlike the Circuit Judge, County Judge Selah Lively is unrepentant
even after death. He is the archetypal self-made man, triumphant and vengeful.

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He had begun as a grocery clerk who studied law at night. He was regular, and
doubtless ostentatious, in church attendance and became the personal attorney
of Thomas Rhodes, the bank president whose malfeasances were later pursued
 - up to a point - by Kinsey Keene. The crowning achievement of Lively's
career was his election as County Judge, presumably with support from
Rhodes. It is indeed likely that he was the unnamed judge, "a friend of
Rhodes," who did the deal with Keene concerning Jack McGuire. For Judge
Lively, his personal success was all the sweeter because he stood only five feet
two inches tall. From his perspective, "all the giants," like Jefferson Howard,
Kinsey Keene, and Harmon Whitney, had jeered at his size; now they were
"forced to stand / Before the bar and say 'Your Honor."' His soul as cramped
as his body, Judge Lively gloated: "Well, don't you think it was natural that
I made it hard for them?"
     Brief mention may suffice for Hamilton Greene, who added judicial
office to his other attainments: "judge, member of Congress, leader in the
State." Given Masters' enmity for Alexander Hamilton,"94 Thomas Jefferson's
archenemy, it was only to be expected that the poet would reserve some horri-
ble fate for his namesake in Spoon River. In fact, Greene is assigned the mild
punishment of complacent self-delusion. With filial piety he attributes all his
good qualities to his parents:
From my mother I inherited
Vivacity, fancy, language;
From my father will, judgment, logic.
All honor to them
For what service I was to the people!
The irony is that Hamilton Greene like the greater Hamilton before him was
in fact illegitimate; Spoon River's Hamilton being the bastard son of Thomas
Greene and Elsa Wertman, the Greene's German-born maid. Mrs. Greene
helped her husband to conceal the fact and quietly adopted the child; as Elsa
with peasant bluntness put it:  "He gave her a farm to be still." Elsa herself got
nothing, except the thrill of watching her unacknowledged son climb the ladder
of success. Unknown to Hamilton, he lies in the grave next to his natural
mother.
     The last legal figure to speak in Spoon River, Granville Calhoun, is like
the first, Judge Somers, a judge manque. Calhoun had indeed long been the
County Judge, "But my friends left me and joined my enemies, / And they
elected a new man," apparently the obnoxious Selah Lively. So intent on
revenge was ex-Judge Calhoun that he raised his sons to desire only power and
money, a fate that one at least, Henry C. Calhoun, buried next to his father,
came to regret. The elder Calhoun, made speechless by a stroke, spent his
declining years at his bedroom window, "looking at the court-house window

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/ Of the county judge's room." Masters, who had himself been passed over for
judgeship, narrowly avoided a comparable fate.
    Spoon River's judiciary are no better than the members of the bar
appearing before them. Legalistic, vengeful, and obsessive at worst, they are
doddering and deluded at best. Not fools or drunkards so far as we can see and
by definition not failures in career terms, the judges of Spoon River are no
more than "one-birth minds"; none rises to the second tier - lawyer Masters'
revenge on the judiciary. When they do not actually corrupt the system, they
merely administer it: a system of rules for punishing the innocent, like the
insane Barry Holden, and for denying justice to the wronged and the poor.
     Lawyers and judges are overrepresented among those sleeping on the
hill, and their life stories illustrate the seamy side of the law. Much the same
can be said about the legal issues that appear in the Anthology. Not limited to
legal biographies, law and its abuse form a consistent theme of the work. Hod
Putt, the murderer sentenced to death by the Circuit Judge, is the first character
to speak.95 His very first words implicate law and crime and the confusion of
the two:
Here I lie close to the grave
Of Old Bill Piersol,
Who grew rich trading with the Indians, and who
Afterwards took the bankrupt law
And emerged from it richer than ever.
Since the epitaphs are undated, one cannot be sure which "bankrupt law" Old
Bill took. There were short-lived laws adopted in 1800 and 1841, but the prime
candidates would be the bankruptcy act of 1867 (repealed in 1878) and its
successor in 1898, which forms the basis of modern law.96 Masters, who began
his legal career in Chicago as a bill collector for the Edison Company, 97 would
doubtless have been familiar with the subject. Generally regarded as a humane
and efficient measure, permitting individuals as well as corporations to petition
for relief from a hopeless accumulation of debt, the bankruptcy act figures in
the opening line of Spoon River's first epitaph as a shield for wrongdoing.
Piersol seems to have used the law to shuck off rightful claims, only to emerge
"richer than ever."
     Anterior to taking the bankrupt law was, of course, Old Bill's ill-gotten
gains "trading with the Indians." The unequal bargains made with North
America's aboriginal inhabitants have haunted the literary conscience. In The
Pioneers (1823) James Fenimore Cooper imagined a past in which the Indians
voluntarily gave away their land to a white man, while in The House of the
Seven Gables (1851) Nathaniel Hawthorne described a deed from Indian sachems
for the vast tract of land in Maine claimed by the Pyncheons.98 A desperate
need to forge - in both senses of the word - the first link in the chain of title

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to America lies behind such imaginings. Actually Masters' archenemy Chief
Justice John Marshall was far more candid about the source of title. In Johnson
v. McIntosh, decided the very year Cooper published The Pioneers, Marshall
wrote in the United States Reports: "Conquest gives a title which the courts of
the conqueror cannot deny. .  .  ."99 Shady deals with the Indians are a persis-
tent mark of moral turpitude in American fiction. Marian Forrester, the "lost
lady" of Willa Cather's 1923 novel, plumbs the depths when in a desperate
attempt to regain economic independence she entrusts what little money she
has to the despicable Ivy Peters to invest for her in Wyoming land. "He gets
splendid land from the Indians some way, for next to nothing." "I've no doubt
it's crooked,"100 she confesses. Old Bill Piersol merely reenacted on a small
scale the history of America, growing rich trading with the Indians, but when
Hod Putt tried to follow the precedent of primordial wrong, he was con-
demned. His own wry comment is far more apt than the Circuit Judge's
misplaced moralizing: "That was my way of going into bankruptcy."
     Two graves away from Hod Putt lies the hardware store owner and
inventor, Robert Fulton Tanner. His invention of a better mousetrap proves
his undoing: "I was bitten by a rat / While demonstrating my patent trap."
Tanner goes on to turn his invention into a bitter metaphor of the human
condition. A man is lured by some bait, "a woman with money you want to
marry, / Prestige, place, or power in the world," then caught in the trap set by
the monstrous ogre Life," who torments the victim "until your misery bores
him." Tanner's property in the design of his trap, his patent, is a creature of
statute. As with the bankrupt law, so with patents: a generally benign provi-
sion is shown to work hardship. Not only did Bill Piersol escape his lawful
creditors, but Hod Putt in trying to follow his example killed an innocent
traveler and is himself hanged. Tanner's death-dealing invention is literally a
trap: he himself is killed and his design becomes a figure of  malign fate.
     The federal Constitution puts in only one sorry appearance in the
Anthology. At the time of writing, long before the "due process revolution,"
the expansive powers of the organic law were exploited most often in the
interests of business. Ida Chicken, meek student of the French language,
encountered the Constitution twice in one day. In Peoria to secure a passport,
she was required to swear to support and defend the Constitution.
That very morning
The Federal Judge, in the very next room
To the room where I took the oath,
Decided the constitution
Exempted Rhodes from paying taxes
For the water works of Spoon River!
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The Rhodes in question was Thomas Rhodes, bank president and Spoon River's
leading citizen, father of Ralph Rhodes who ran the canning works. Ida had
seen him on the train that morning. The ground on which Rhodes was ex-
empted from taxes is not expressed but was probably that he had secured a
provision in the water works' corporate charter exempting it from state taxes.
Such provisions were not uncommon in the last half of the nineteenth centu-
ry.101 Intended to promote desirable improvements, they were subject to
obvious abuse in an era of corrupt legislatures, documented elsewhere in Spoon
River. When the state attempted to revoke its favor, the beneficiary could
claim the protection of the Contracts Clause: "No State shall.... pass any ... Law
impairing the Obligation of Contracts."102 Years earlier in the famous Dart-
mouth College Case,103 Chief Justice Marshall had equated corporate charters
with contracts, thus making them unalterable. just as Old Bill Piersol "took
the bankrupt law," so Old Rhodes "took" the Constitution, and both came out
"richer than ever."
     Legal personalities and issues are pervasive in Spoon River. Lawyers
and judges are thick on the ground, and legal issues appear in numerous poems.
Law cases, both civil and criminal frequently crop up. An unusual number of
homicides are reported. As we have seen, Hod Putt and Barry Holden were
convicted of murder and executed, while Jack McGuire got only fourteen years
because of Kinsey Keene's corrupt deal with the judge. Rosie Roberts wrote
the Chief of Police in Peoria and confessed to murdering the son of a "mer-
chant prince" in a brothel. The crime would otherwise have gone unpunished
because the newspapers "lied like the devil to hush up scandal, / For the bribe
of advertising": they reported that "he killed himself / In his home while
cleaning a hunting gun." In Spoon River itself Searcy Foote murdered his rich
Aunt Persis and got away with it: "the coroner / Said she died of heart failure
A joke on you, Spoon River?" Mrs. Merritt and her teenage lover
Elmer Karr were convicted of murdering Tom Merritt. Elmer got fourteen
years like Jack McGuire, and Mrs. Merritt (apparently judged the guiltier of the
two) died in Joliet penitentiary after serving thirty years, although she main-
tained her innocence even in the grave.
     The detection and punishment of crime in Spoon River were haphazard
affairs. While there was a police chief in Peoria and presumably an organized
constabulary to back him up, the village still relied on such antediluvian officers
as the Night Watch and the Town Marshal,104 as well as on the small town's
resources of private detection. Clarence Fawcett, a clerk in Thomas Rhodes'
store, stole blankets in order to raise money "to pay a doctor's bill for my little
girl." Rhodes suspected and offered mercy in return for a confession, then had
Fawcett arrested. "And every paper, except the Clarion, / Wrote me up as a
thief / Because old Rhodes was an advertiser / And wanted to make an example

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of me." Petty larceny by a necessitous thief was ruthlessly punished, while the
grander larcenies of the town's leading citizen were ignored. Kinsey Keene, as
we have seen, while defending Jack McGuire, "was helping to land / Old
Thomas Rhodes for wrecking the bank, / And the judge [Selah Lively?] was a
friend of Rhodes / And wanted him to escape." Keene "quit on Rhodes" in
return for fourteen years for McGuire. Nicholas Bindle later recalled that the
pipe-organ he had given the church "played its christening songs when Deacon
Rhodes, / Who broke the bank and all but ruined me, / Worshipped for the
first time after his acquittal." (George Reece, although only the cashier, was
sent to jail.)
     With Old Rhodes' undeserved acquittal may be compared the ironic
result in the prosecution of Roy Butler for the rape of Mrs. Richard Bandle.
The truth in People v. Butler was that the defendant was innocent:
Richard Bandle and I had trouble over a fence,
And my wife and Mrs. Bandle quarreled
As to whether Ipava was a finer town than Table Grove.
I awoke one morning with the love of God
Brimming over my heart, so I went to see Richard
To settle the fence in the spirit of Jesus Christ,
I knocked on the door, and his wife opened;
She smiled and asked me in; I entered -
She slammed the door and began to scream,
"Take your hands off, you low down varlet!"
just then her husband entered.
I waved my hands, choked up with words.
He went for his gun, and I ran out.
In the local trial court, however, Butler was convicted: "A jury, of neighbors
mostly, with 'Butch' Weldy / As foreman, found me guilty in ten minutes
And two ballots." Casting Butch Weldy, the cannery workman, as foreman of
the jury in a rape case suggests the first set of ironies. The Butler Case, al-
though reported later, was clearly before Weldy's injury. Back then, Butch was
one of the town toughs and was himself guilty of an unreported rape. (His
victim, Minerva Jones, later died during an abortion performed by Doctor
Meyers, who was promptly indicted.) Butch's feelings during the trial are not
reported. Did he vote against the accused rapist because he knew the ways of
the world and what kind of stories would be told? Or did he vote to convict
Butler in order to protect himself from suspicion? Or had Butch already "got
religion" in the Spoon River sense of the word and, now pharisaically pure,  was
ready to cast the first stone? In any event, his role shifts the equities somewhat
in his own subsequent suit against the Canning Company.

[320]

     The final irony in People v. Butler is that Roy's conviction was reversed
on appeal, apparently because the Supreme Court did not believe Mrs. Bandle's
testimony: "neither the Supreme Court nor my wife / Believed a word she
said." Ordinarily the credibility of a witness is left to the jury, and facts found
at trial are not reviewable on appeal. But, as Masters well knew, it is always
possible to find some technical defect as a basis for reversal and that may have
been what happened here. Even Roy marveled at his acquittal:
If the learned Supreme Court of Illinois
Got at the secret of every case
As well as it does a case of rape
It would be the greatest court in theworld.
Because in the context of the Anthology we must believe Roy's testimony, we
are faced with a legal judgment that is just but inadequately explained. To
Roy's contemporaries lacking our posthumous perspective, it must have seemed
as if just another rapist got off.
     In People v. Butler the legal forms may have been manipulated to pro-
duce a just result, but in People v. Bloyd the manipulation had a sinister pur-
pose. Wendell P. Bloyd was a thorn in the side of Spoon River's Christian
population. He preached an anti-Gospel of a malevolent God:
I said God lied to Adam, and destined him
To lead the life of a fool,
Ignorant that there is evil in the world as well as good.
And when Adam outwitted God by eating the apple.
And saw through the lie,
God drove him out of Eden to keep him from taking
The fruit of immortal life.
To make matters worse, Bloyd added as an afterthought:
(The reason I believe God crucified His Own Son
To get out of the wretched tangle is, because it
sounds just like Him.)
To the pious it seemed that there ought to be a law against such scandalous
utterances; so Bloyd was charged with the catchall offense of disorderly con-
duct,105 "there being no statute on blasphemy." Even this seems to have failed
- he only reports being charged not convicted - so the powers that be fell
back on the perennial favorite in dealing with dissidents and locked him up as
"insane." In a twist that is in keeping with the moral economy of Spoon River,
Bloyd was finally "beaten to death by a Catholic guard." Informal justice - or,
rather injustice in this case - is meted out in disregard of the legal forms. It
is furthermore a "guard," one legally charged with the safekeeping of inmates,
who is the cause of his death.

[321]

     Trials are exercises in finding facts, but the criminal trials in Spoon
River inspire no confidence. The truly insane Barry Holden was convicted of 
first degree murder, a result even the State's Attorney came to see was unjust. 
Thomas Rhodes was acquitted with help from the judge. Neither Mrs. Merritt 
nor Roy Butler could convince a jury of their innocence, although the latter got
off on a dubious technicality. Wendell Bloyd was civilly committed when his
criminal prosecution failed. Yet part of the feeling of dissatisfaction is caused
by the literary technique of the Anthology itself. Since the vantage point is a
cemetery, the trials are necessarily in the past. The "facts" are presented in
juxtaposition with the trials, not as their products. Given this approach, it is
almost inevitable that the fact-finding process will look bad. The only question
will be how close it can get to "reality." A similar effect is produced in Theo-
dore Dreiser's An American Tragedy (1925), in which Clyde Griffith's murder
of Roberta Alden is portrayed as inevitable, making his subsequent trial seem
merely vindictive. Unless Clyde's whole life can be introduced into evidence,
judgment is rendered on an incomplete record.106 For an omniscient narrator,
even one without a determinist outlook, to describe a trial is inevitably to make
it look like a mere approximation. Unless an author is prepared to exercise the
rigorous self-restraint of Henry James, confining himself to a single viewpoint,
there are always other "facts," unknown or unproven in court, to contaminate
the result.107 Only by limiting one's perspective to that of the fact finder,
confronted by a host of conflicting claims, can one hope to do justice to the
process, as James Gould Cozzens did in his legal novel The Just and the Unjust
(1942).108
     Civil suits too are common in Spoon River and equally unsatisfying.
The bankrupt law and the fellow-servant rule we have already seen, and
Schmidt v. Dallman, stirred up by lawyer Whitney, turned on the effect of a tax
deed. In addition, one old-fashioned suit for breach of promise of matrimony
is reported. Ida Frickey, penniless and newly arrived in Spoon River, had a
hunger-induced vision as she stared at the McNeely mansion: "I saw a giant
pair of scissors / Dip from the sky, like the beam of a dredge, / And cut the
house in two like a curtain." Later at the hotel where she went seeking work,
Ida was "winked at" by Wash McNeely's son: "He proved the link in the chain
of title / To half my ownership of the mansion, / Through a breach of promise
suit.
     Law pervades Spoon River in a deeper sense as well. When Ida Frickey
first saw the McNeely mansion, she saw the visible marks of ownership: long-
continued possession - not only was the house "old," it appeared to her of
venerable antiquity, "a castle of stone 'mid walks and gardens"; and the inten-
tion to exclude others - "with workmen about the place on guard." But she
sensed something deeper as well, an invisible aspect of ownership: "the County

[322]

ind State upholding it / For its lordly owner." Here Ida penetrated to the
essence. " Property, legally speaking, is not a thing, not even a person's relation-
ship to a thing, but a person's relationship to other persons in respect to a
thing. In legal analysis, the mansion was McNeely's not because of possession
and intention to exclude but because of title, a uniquely legal abstraction. As
Justice Oliver Wendell Holmes so forcefully put it while Spoon River was still
on the best-seller list: "for legal purposes, a right is only the hypostasis of a
prophecy - the imagination of a substance supporting the fact that the public
force will be brought to bear upon those who do things said to contravene it
.... 109 From this positivist perspective, law does not enforce or even rein-
force a right, it creates it by an act of legal imagination. Just as Robert Fulton
Tanner held the patent on his trap, so McNeely held title to his mansion -
until the legal scissors appeared and cut the house in two.
     Spoon River is itself a product of the legal imagination, in a sense other
than the obvious one. Unlike European villages or even older New England
towns, Spoon River is not an organic community; it is a legal artifact. When
Mrs. Benjamin Pantier as head of the Social Purity Club objected to keeping a
studhorse in town - in the McNeely barn, to be exact - she went to the
"Village trustees" and asked them to order Jim Brown to remove the stud to
a barn "outside the corporation." Just as McNeely's claim to his mansion is up-
held by the County and State, so too Spoon River is a village only by lawful
authority. Just as the water works exists by virtue of its corporate charter, so
too the Village of Spoon River is a municipal corporation chartered by the
State. And th'is legal description is apt: the village is no more than an accumu-
lation of immigrants from other regions, not unlike shareholders bound togeth-
er only by a temporary economic motive. The "dominant forces" were "drawn
from New England, / Republicans, Calvinists, merchants, bankers," - the
forces abominated by Jefferson Howard (and by Edgar Lee Masters) - but to
these were added many from other towns, like Ida Frickey from Summum (an
actual Illinois town); other regions, like Howard himself from Virginia; even
other countries, like Elsa Wertman, Hamilton Greene's unacknowledged moth-
er, from Germany. In this regard Spoon River resembles Gopher Prairie where
the original New England settlers, still the social elite, were later outnumbered
by newcomers from elsewhere.110
     Spoon River is a legal community, and it is precisely because the legal
order is bad that Spoon River is bad. In one sense the law in Spoon River does
not constitute an order at all; in fact practicing law is not once but twice
equated with gambling:
I never saw any difference
Between playing cards for money
And selling real estate,
[323]

Practicing law, banking, or anything else
                "Ace" Shaw
*    *     *
I was a lawyer like Harmon Whitney
Or Kinsey Keene or Garrison Standard,
For I tried the rights of property
[like the title to Schmidt's farm?] ...
In that poker room ....
                 Tom Beatty
But if law is a game in Spoon River, it is likely to be a crooked one. Harry
Carey Goodhue charged "the bank and the courthouse ring" with "pocketing
the interest on public funds" and fought the water works - protected by the
Constitution from paying taxes - "for stealing streets and raising rates." Daisy
Fraser asked rhetorically: "Did you ever hear of the Circuit Judge / Helping
anyone except the Q railroad, / Or the bankers?" Sexsmith the Dentist asked
in turn:
Do you think that Daisy Fraser
Had been put out and driven out
If the canning works had never needed
Her little house and lot?
Adam Weirauch, Spoon River's representative in the state legislature, sold his
vote to Charles T. Yerkes, the real-life financier whose career provided Theo-
dore Dreiser with material,111 while Lambert Hutchins, Spoon River's repre-
sentative in Congress, chose the railroad as his paymaster. Rosie Roberts
confessed to a murder because she was "mad / At the crooked police, and the
crooked game of life." Henry Phipps, Sunday school superintendant and
"dummy president" of the canning factory, contemplating the bankrupt bank,
imagined he saw a wrecked machine and, among the wreckage "only the hopper
for souls fit to be used again / In a new devourer of life, when newspapers,
judges and money-magicians / Build over again." The very last mention of
lawyers in Spoon River comes in a heartfelt sermon preached by Aaron Hat-
field, modeled on Masters' beloved grandfather,112 reminding the congregation
of  "the peasant youth / Of Galilee who went to the city / And was killed by
bankers and lawyers."
     That blind chance would be better than the blind goddess of justice was
made graphically - even disgustingly - plain in Spoon River's one honest
newspaper, the Clarion, edited by Carl Hamblin. On the day the anarchists
were hanged in Chicago for their part in the Haymarket Riot - on November
11, 1887, in other words113 - the editor published the following vision:

[324]

I saw a beautiful woman with bandaged eyes
Standing on the steps of a marble temple.
Great multitudes passed in front of her,
Lifting their faces to her imploringly.
In her left hand she held a sword.
She was brandishing the sword,
Sometimes striking a child [an orphan?], again a laborer
[Butch Weldy?]
Again a slinking woman [a widow?], again a lunatic
[Barry Holden?].
In her right hand she held a scale;
Into the scale pieces of gold were tossed.
By those who dodged the strokes of the sword
[Thomas Rhodes?].
A man in a black gown [the Circuit Judge?] read from a manuscript:
'She is no respecter of persons.'
Then a youth wearing a red cap
Leaped to her side and snatched away the bandage.
And lo, the lashes had been eaten away
From the oozy eye-lids;
The eye-balls were seared with a milky mucus;
The madness of a dying soul
Was written on her face -
But the multitude saw why she wore the bandage.
Judge Somers is only cross-eyed; Justice herself is worse than blind. Hamblin's
revelation suggests a grim retribution for Butch Weldy's eyes, "burned crisp as
a couple of eggs." In its association of violence and vision it recalls Masters'
own revelation of the "Cyclopean eye" burned in his forehead by the law.
     As a piece of imaginative literature, Spoon River Anthology lives by the
law, just as Edgar Lee Masters lived by it while writing. The energy that still
surges though these Todeslieder was unleashed in the torture chambers of the
poet's professional career. Paradoxically it is precisely because of its death-
dealing character that law evoked so vital a response in its practitioner and
victim. For all his attempts at a classic air of fatalistic repose, it is Masters'
heroic and romantic rebellion against his personal fate that continues to vivify
the Anthology. Though he suffered as an individual, the poet is in some sense
Representative Man. His anguished cries rise above the particularities of his
own case and reach us across the years.
     The Anthology is very much a lawyer's view of Spoon River. Legal
professionals abound, legal issues are numerous, legal terms are handled with
confidence. One need only contrast the lawyers with the doctors and clergy-

[325]

men to see the difference. Medical malpractice is limited to forms known to
laymen: a bungled delivery, a fatal abortion. The detail brought to Dr. Will
Kennicott's Main Street practice (not to mention Arrowsmith later on) is strik-
ingly absent. What is true of medicine is true also of religion. While "The
Church in Spoon River" could be the subject of another study, it would not be
so long as this one. Clerical life is not presented with any more particularity
than informs the portrayal of the medical profession. A clergyman counsels
against divorce, rails against intemperance and impurity, occasionally preaches
an inspiring sermon. But the lawyer's life - and, worse, corruption - is time
and again shown in graphic detail. Spoon River is full of crime: murder, rape,
arson (of the courthouse, no less!); as well as of civil litigation: bankruptcy,
personal injury, even breach of promise. Far more than abuse of religion, it is
abuse of. law that expresses the sinfulness of Spoon River.
     Spoon River Anthology would not have been the stunning success it was
if it had not appealed to its audience's sense of something wrong. America was
ready for its vivisection of small-town verities, and the law, too, was ripe for
radical scrutiny. The legal system fit for an America of small towns was
inadequate to cope with the urban industrial state; it was too easily exploited
by crafty lawyers on behalf of their corporate clients. Populism, Masters'
political heritage, perceived the problem only darkly and offered no way
forward. Before the Progressives with their faith in bureaucratic solutions,
before the New Deal and its legal Brain Trust, before the civil rights revolution,
it was hard to idealize American law. It was this macrocosmic reality that
Masters caught forever in the microcosm of Spoon River.

[326]

ENDNOTES

* For support while preparing this article, the author is indebted to the Law Center
Board, University of North Carolina at Chapel Hill.

1. Max Putzell, The Man in the Mirror: William Marion Reedy and His Magazine (1963),
200. Masters had earlier had two volumes of poems printed (but not published) using the pseud-
onym Webster Ford: Songs and Sonnets (1910), Songs and Sonnets. Second Series (1912). 
SeeEdgar Lee Masters: An Exhibition in Commemoration of the Centenary of His Birth: 
Catalogue and Checklist of Books, comp. Frank K. Robinson (1970), 11, 59 (exhibition 
Aug. 30 - Nov. 30, 1968  the Academic Center, University of Texas at Austin). Although 
Masters never explained his choice of pseudonym, it is - whether coincidentally or not - a com-
pound of the surnames of two Elizabethan dramatists, John Webster and John Ford, one of 
whom (Webster) used legal themes in his plays. See Richard A. Posner, Law and Literature: 
A Misunderstood Relation (1988), 6, 79.

2.  Edgar Lee Masters, Across Spoon River: An Autobiography (1936), 359. (Masters'
autobiography is hereafter cited as ASR.) The Nov. 20, 1914 issue of Reedy's Mirror had an-
nounced Masters as the author of the poems. ASR, 351.

3. See Select Epigrams From the Greek Anthology (trans. J.W. Mackail, 1906). This seems
to have been the edition read by Masters. See Catalogue, comp. Robinson, 15. For a discus-
sion of  Masters and the classics, see Willis Barnstone's introduction to The New Spoon River 
(1968, 1st ed. 1924).

4. Although Masters had first had the idea of calling his collection "Spoon River Anthology,"
he later came to prefer "Pleasant Plains Anthology," but William Marion Reedy fortunately
convinced him to remain true to his original inspiration. Edgar Lee Masters, "The Genesis of
Spoon River," American Mercury 28 (1933):38, 49.

5.  ASR, 339.

6. There are 243 individual characters (including one joint epitaph, "William and Emily"),
not counting those in the Spooniad and the Epilogue. In addition, there is one epitaph for
'Many Soldiers."

7.  Masters, "Genesis," 50.

8. Edgar Lee Masters, "The Hill", Spoon River Anthology (New York: Collier Books,
1962), 23. All references are to this edition of Spoon River Anthology, in which the table of 
contents lists the poems alphabetically by the subjects' last names.

9.  See "Percival Sharp" and "Samuel Gardner."

10. Sinclair Lewis, Main Street (1920), epigraph.

11. ASR, 342.

12. For Chicago's population see Bessie Louise Pierce, A History of Chicago, 3 vols. (1937-
57), vol. 2, 3; vol. 3, 20. For the date of Masters' arrival in Chicago see his "Introduction to
Chicago," American Mercury 31 (1934):49.

13. See Robert H. Wiebe, The Search for Order, 1877-1920 (1967), chap. 5, "A New 
Middle Class."

14. See William L. Phillips, "How Sherwood Anderson Wrote Winesburg, Ohio," American
Literature 23 (1951): 16-17.

15. Another lawyer, for example, is William H. Herndon, a real-life figure; he appears,
however, not in his professional character but as the biographer of his famous law partner,
Abraham Lincoln. (I am indebted to Charles E. Burgess for reminding me of Herndon's calling.)

16. Of the 243 individual characters 188 are male, 55 female. There are 23 women among
the first 81 epitaphs, 18 among the second 81, and 14 among the third.

17. Lawrence M. Friedman, American Law (1984), 239. The first woman licensed to
practice law in Illinois was Alta M. Hulett. Myra Bradwell, who had been denied admission to
the bar there in 1869, unsuccessfully challenged her exclusion by appeal to the US. Supreme
Court. Bradwell v. Illinois, 83 US. 130 (1873).

18. Doctor Meyers, Doc Hill, Dr. Siegfried Iseman. A fourth doctor, Dr. Duval, is referred
to by Barry Holden; he was tried "for the murder of Zora Clemens," his lover and the victim
apparently of a bungled abortion. See William J. Ford, "Sickness and Health in Spoon River,"
Quarterly Bulletin of the Northwestern University Medical School 23 (1949):248.

19. Rev. Lemuel Wiley, Rev. Abner Peet, Amos Sibley, Ezra Bartlett, Father Malloy, Le
Roy Goldman ("revivalist "). J. Milton Miles lists five Protestant denominations in Spoon 
River: Presbyterian, Methodist, Christian, Baptist, and Congregational. There was also a Roman
Catholic church, see Father Malloy. Godwin James seems to have been an ex-minister, and 
Aaron Hatfield may have been a lay preacher.

20. Sherwood Anderson, Winesburg, Ohio (1919), "A Man of Ideas."

21. Id., "Drink."

22. Id., "An Awakening."

23. Lewis, Main Street, chap. 1, iii

24. Id., chap. 29, iv.

25. Id., chap. 1, v.

26. Id., chap. 2, i.

27. Id.

28. Id., chap. 10, iv.

29. Id., chap. 2, ii. See also id., chap. 5, v ("Guy Pollock, the much-praised lawyer, the
poetic bachelor").

30. Id., chap. 16, ii. On Flickerbaugh's Yankee origins, see id., chap. 4, iv.

31. Id., chap. 32, iv.

32. Id., chap. 4, ii.

33. Id., chap. 12, iii; chap. 13, i.

34. Id., chap. 4, ii.

35. Anderson, Winesburg, "The Thinker." Seth Richmond's widowed mother became a
court stenographer and traveled by train to the county seat each morning during sessions of
court.

36. See J. H. Wigmore, "A List of One Hundred Legal Novels," 17 Illinois Law Review
26 (1922); see also Karen L. Kretschman, Legal Novels.- An Annotated Bibliography (1976)
(reprinting and updating Wigmore).

37. Actually there is one mention of lawyering in Our Town. Speaking of weddings, the
Stage Manager says: "You know how it is: you're twenty-one or twenty-two and make some
decisions, then whissh! you're seventy: you've been a lawyer for fifty years, and that white-
haired lady at your side has eaten over fifty thousand meals with you." Act II.
There is incidentally a mocking reference to Spoon River in Our Town. The Stage
Manager:
It's like what one of those Middle West poets said: You've got to love life to have life,
and you've got to have life to love life
It's what they call a vicious circle.
Act II. The reference is to "Lucinda Matlock": "It takes life to love life."
38. Charles E. Burgess, "Edgar Lee Masters: The Lawyer as Writer," in John E. Hallwas
and Dennis J. Reader, eds., The Vision of This Land:  Studies of Vachel Lindsay, Edgar Lee
Masters, and Carl Sandburg (1976), 55.

39. For a recent sociological study of law practice from 1870 to 1960 in Menard County,
Illinois (county seat: Petersburg), see Stephen Daniels, "Continuity and Change in Patterns of
Case Handling: A Case Study of Two Rural Counties," 19 Law and Society Review 381 (1985)
(covering Menard and Bond Counties). Conditions in Fulton County (county seat: Lewistown)
would have been comparable to those in Menard, where Masters had spent several years of his
boyhood and where his father had earlier practiced law. (I am indebted for this reference to
Professor Beverly A. Smith of Illinois State University.)

40. Irving Stone, Clarence Darrow (1941), 162.

41. United States ex rel. Turner v. Williams, 194 US. 279 (1904). Masters lost, and the
Court upheld the constitutionality of a 1903 statute making ineligible for United States citizen-
ship those who believed in anarchy or the violent overthrow of the government. See Zechariah
Chafee, Jr., Free Speech in the United States (1941), 228-31 (noting Masters' role in the case).

42. Hardin Wallace Masters, Edgar Lee Masters: A Biographical Sketchbook About a 
Famous American Author (1978), 52.

43. "John Marshall," first published in the Chicago Chronicle, ASR, 255, reprinted in The
New Star Chamber and Other Essays (1904), 37-50.

44. ASR, 255.

45. See Constitutional Decisions of John Marshall, ed. J.R Cotton (1905); John Marshall:
Complete Constitutional Decisions, ed. J.M. Dillon (1903).

46. ASR, 282.

47. ASR, 326-27.

48. ASR, 333.

49. ASR, 334.

50. ASR, 339.

51. Hilary Masters, Last Stands: Notes From Memory (1982), 97. Hilary Masters' memoir
is hereafter cited as LS.

52. ASR, 343. The Illinois Constitution of 1870 (in force at the time Masters was writing)
seems to have supplied the names Silas Dement and John M. Church among others.

53. ASR, 99.

54. ASR, 312.

55. LS, 28-29.

56. LS, 100.

57. LS, 149.

58. LS, 175.

59. LS, 188.

60. ASR, 128.

61. ASR, 209.

62. ASR, 213.

63. ASR, 278.

64. ASR, 288.

65. ASR, 398.

66. ASR, 127. Chitty's Treatise on Pleading and Parties to Actions traced to an 1808 first
edition in England by Joseph Chitty Sr. By 1876 it had reached a seventh English edition by
Henry Greening and a sixteenth American edition by J. C. Perkins. Greenleaf's Treatise on the
Law of Evidence was indigenous to America, being first produced in 1842 by Simon Greenleaf,
a Professor at the Harvard Law School. In 1883 it reached a fourteenth edition by Simon 
Greenleaf Croswell.

67. ASR, 191.

68. Stone, Darrow, 160.

69. ASR, 78.

70. ASR, 93.

71. ASR, 249.

72. Quoted in Hardin Masters, Sketchbook, 99.

73. Friedman, American Law, 235.

74. ASR, 399.

75. See, e.g., ASR, 237, 244, 253.

76. ASR, 271.

77. ASR, 317-18.

78. Stone, Darrow, 159.

79. ASR, 270.

80. ASR, 275.

81. ASR, 384.

82. LS, 103.

83. There is a possible exception in the epitaph for Mrs. Charles Bliss. Rev. Wiley and
Judge Somers advised her not to divorce her husband "for the sake of the children." The
unhappy marriage proved a poor environment for child rearing, reminding Mrs. Bliss of poor
conditions for raising plants:
Now every gardener knows that plants grown in cellars
Or under stones are twisted and yellow and weak 
Yet preachers and judges advise raising souls
Where there is no sunlight, but only twilight,
No warmth, but only dampness and cold -
Preachers and judges!
Of course, Mrs. Bliss may have been reacting only to an honorific title.

84. Sidney Breese (1800-1878), a justice of the Illinois Supreme Court from 1857 until his
death in 1878, was "one of the leading jurists of America during a period when the rapid expan-
sion of litigation witnessed the increase of the Illinois reports from the eighteenth to the eighty-
ninth volume." Dictionary of American Biography.
     In a law review article Masters himself praised Justice Breese's "scholarly dissent" in
Hammond v. People, 32 Ill. 446, 83 Am. Dec. 286 (1863). "Suspension of the Writ of Habeas
Corpus," 7 Illinois Law Review 15, 24 (1912).

85. In the epitaph for the Town Marshall, one hears another version of what happened.
in People v. McGuire: Logan himself had earlier killed a man while drunk and appeared in a
dream to one of the jurymen and told him "the whole secret story."  "Fourteen years," he
concludes, "were enough for killing me."

86. Bergen Evans, Dictionary of Quotations (1968), 735.

87. William Knox, "Mortality," stanza 1:
Oh why should the spirit of mortal be proud?
Like a fast-flitting meteor, a fast-flying cloud,
A flash of the lightning, a break of the wave,
He passes from life to his rest in the grave.
88. See Jim Brown.

89. W. W. Rostow, The Stages of Economic Growth (2d ed. 1971), 55, 223-30.

90. Burgess has noted that Weldy's case recalls a fire in Lewistown in the early 1890s that
destroyed a canning factory controlled by a local bank and that the details of the accident are
similar to those in a case that Masters litigated, Luckowitz v. Eagle Brewing Co., 235 Ill. 246, 85
N.E. 213 (1908). 'The Lawyer as Writer," 68.

91. Ill. Workers' Compensation Act of 1951, Ill. Ann. Stat. ch. 48, S 138.1 ff. (Smith-Hurd).
The original Illinois Workmen's Compensation Act was passed in 1911; it was repealed and
rcplaced in 1913 by the ancestor of the current act.

92. 3 M. & W, 1, 150 Eng. Rep. 1030 (Exch. 1837). See William S. Holdsworth, A History
of English Law, 17 vols. (1903-72), vol. 8, 480-82; Comment, "The Creation of a Common Law
Rule: The Fellow Servant Rule, 1837-1860," 132 University of Pennsylvania Law Review 579
(1984).

93. 35 Mass. (4 Metc.) 49 (1842). See Leonard W, Levy, The Law of the Commonwealth
and Chief Justice Shaw: The Evolution of American Law, 1830-1860 (1957), chap. 10; 
Christopher L. Tomlins, "A Mysterious Power: Industrial Accidents and the Legal Construction of 
Employment Relations in Massachusetts, 1800-1850," 6 Law and History Review 375 (1988). 
Illinois accepted the fellow-servant rule in Honner v. Illinois Cent. R.R., 15 111. 550 (1854).

94. See Masters' essay on "Alexander Hamilton," in The New Star Chamber, 65-77.

95. Although the Spoon River epitaphs that appeared in Reedy's Mirror were rearranged
before publication in book form, Hod Putt holds indisputable pride of place. His epitaph was
first in the Mirror and first (after the prefatory poem "The Hill") between hard covers.

96. See Charles Warren, Bankruptcy in United States History (1935). The bankruptcy 
system was revised in 1938 and again in 1978. For the present system see US.C. Title 11.

97. ASR, 150-52.

98. For a sensitive discussion of the land transfers from the Indians in these two novels see
Brook Thomas, Cross-Examinations of Law and Literature: Cooper, Hawthorne, Stowe, and
Melville (1987), 36-37, 72-73.

99. 21 US. (8 Wheat.) 543, 588 (1823).

100. Willa Cather, A Lost Lady (1923), Pt. 2, III

101. See Charles Fairman, Mr. Justice Miller and the Supreme Court, 1862-1890 (1939), chap.
9, "The Mortgaged Generation"; Benjamin Fletcher Wright, Jr., The Contract Clause of the
Constitution (1938), chap. 7, "Tax Exemption"; Thomas M. Cooley, A Treatise on the Constitu-
tional Limitations Which Rest Upon the Legislative Power of the States of the American 
Union (2d ed. 1871), 126-27, 280-81.

102. U.S. Const. art. 1, sec. 10, cl. 1.

103. 17 U.S. (4 Wheat.) 518 (1819).

104. On the office of marshal and night watch see Samuel Walker, Popular Justice: A History
Of American Criminal Justice (1980), 20.

105. See, e.g. The Revised Statutes of the State of Illinois, 1905, chap. 38, §55: "Whoever
shall be guilty of open lewdness, disorderly conduct, or other notorious act of public indecency,
tending to debauch the public morals, shall be fined not exceeding $200."  Today use of a statute
on disorderly conduct (or the related offense of breach of the peace) to punish the expression 
of unpopular religious opinions would be held to violate the federal Constitution. See, e.g.
Cohen v. California, 403 U.S. 15 (1971).

106. For a sensitive discussion of the effect of narrative technique in literary portrayals of
trials, including a discussion of An American Tragedy, see John P. McWilliams, Jr., "Innocent
Criminal or Criminal Innocence: The Trial in American Fiction," in Carl S. Smith et al., Law
and American Literature (1983), 45-124.
     One of the Spoon River epitaphs is for Dreiser, "Theodore the Poet," although he lived
long after its publication. See Catalogue, comp. Robinson, 18. Theodore is depicted watching
"for men and women / Hiding in burrows of fate amid great cities, / Looking for the souls of
them to come out . . . ."

107. See John V. Orth, "Doing Legal History," 14 Irish Jurist 114, 118-19 (1979) (example
from murder trial in Elizabeth Gaskell's Mary Barton (1848).

108. See Morris H. Wolff, "The Legal Background of Cozzens' The Just and the Unjust',"
Journal of Modern Literature 7 (1979): 505-518.

109. Oliver Wendell Holmes, "Natural Law," 32 Harvard Law Review 40, 42 (1918).

110. Lewis, Main Street, chap. 4, iv.

111. Theodore Dreiser, The Financier (1912). Dreiser had met Masters while doing research
on Yerkes, ASR, 329-30.

112. Masters, "Genesis," 39.

113. Henry David, History of the Haymarket Affair (1936), chap. 21. Burgess has pointed
out that Masters had argued cases before Judge Joseph E. Gary who had sentenced the anarchists
to death. "The Lawyer as Writer," 58.