Table of Contents
A. Study of Law
2. A.A. Jackson
5. Edith Prouty
F. Feminism
II. Death
III. Leads
VI. Timeline
V. Bibliography
I. Kate Kane Rossi: Militant Lawyer
Kate Kane Rossi has proven the most formidable of sea-serpents. While I have unearthed only tidbits to date, I am convinced that late-nineteenth and turn-of-the-century mid-western newspapers published numerous items about this "the most talked about woman lawyer in Chicago." While Ms. Kane does not appear to have distinguished herself as a great legal talent, she was truly a character whose story is worthy of the hunt.
In 1876, at the age of twenty-two, Kate Kane began her legal education at the Ann Arbor University of Michigan. It is as yet unknown why Ms. Kane chose to study at Michigan Law School. She may or may not have lived in the state of Michigan at the time of her election. Regardless, its law school was known "as a popular institution for ladies to study law in."1
By 1890, Michigan Law School had more women graduates than any other law school in the country.2 However, Kate Kane does not figure among them. After one year of study, Ms. Kane moved to Wisconsin where she apprenticed with attorney A.A. Jackson of Janesville.3
Why Kate Kane chose not to complete her legal education at Michigan and instead apprentice with A.A. Jackson is at this point unknown.4 One biographer speculates that she went to Janesville because another of A.A. Jackson's female initiates, Lavinia Goodell, had successfully been admitted to the Janesville bar in 1877, becoming Wisconsin's first woman lawyer.5
1. Janesville & Milwaukee, Wisconsin
Kate Kane was admitted to the Circuit Court of Rock Creek County on September 6, 18 78.6 Not only was she admitted to the bar in Janesville, as Lavinia Goodell had been, Kane was soon thereafter admitted in Milwaukee, becoming the state of Wisconsin's second and Milwaukee's first woman lawyer.7
In 1884, Mrs. Martha Louise Rayne authored WHAT CAN A WOMAN DO: OR, HER POSITION IN THE BUSINESS AND LITERARY WORLD, which included a chapter on women entering the legal profession.8 At the time of her writing, Rayne estimated that there were at least thirty women practicing law in the U nited States.9 Without mentioning Kane's having been admitted to the Illinois Bar that year, Rayne notes only that "Miss Kate Kane ha[d] the honor of being the first lady lawyer to whom permission ha[d] been granted to practice in a Milwaukee court."10 Kane practiced law in Milwaukee for five years and, in 1883, moved to Chicago, Illinois where she again took up active practice.11
For reasons unknown, Kate Kane moved from Milwaukee, Wisconsin to Chicago, Illinois in 1883. One account notes that she gained admission to the Illinois bar that same year.12 However, another, perhaps more reliable source, dates her admission as March 24, 1884, and identifies her as the thirteenth woman to have been admitted to the Illinois bar.13 As of its publication, Kane had been practicing in Chicago for sixteen years.
Flouting Justice Bradley's increasingly toothless assertion that "[t]he natural and proper timidity and delicacy which belongs to the female sex evidently unfits it for many of the occupations of civil life,"14 Kate Kane devoted herself to the practice of criminal law in the municipal courts.15 She enjoyed practicing as a trial lawyer and, sympathetic to the "under dog," comfortably prosecuted civil suits16 and defended the criminally accused.17
In a letter to Lelia Robinson, the first woman lawyer to gain entrance to the Massachusetts bar, Ms. Kane wrote "that in criminal law she ha[d] either prosecuted or defended in every crime known to modern times except treason and piracy; that she ha[d] represented clients from every quarter of the globe, over every hue and every religion except the followers of Zoroaster and Mahomet."18
2. Admission to the Supreme Court
Robert G. Ingersoll sponsored Kate Kane for admission to the Supreme Court of the United States. One of few women who had enjoyed that honor,19 Ms. Kane was considered along with her contemporary, Lavinia Goodell. Unlike Ms. Goodell, however, Kate Kane was not admitted to the Supreme Court bar.20
D. Associations with other Women Lawyers
Famous is the story of Myra Bradwell, the pioneering woman who studied law in her husband's Chicago office, passed the bar examination, but was denied the right to practice by the highest court in Illinois and by the United States Supreme Court.21 Mrs. Bradwell, who might otherwise have been the first woman lawyer in the whole of the United States, nonetheless worked to attain fair property rights for women, the right to serve on juries, and admission to law school. She also founded the Chicago Legal News, "a weekly publication designed to provide up-to-date case law and legal information to lawyers and also to improve everything connected with the practice of law."22 In the year 1900, Bradwell's husband James contributed to his wife's publication by authoring a piece entitled "Women Lawyers of Illinois." Kate Kane appears as the thirteenth of the eighty-nine women lawyers he catalogued.
Questions: (1) How did James Bradwell know (of) Kate Kane? Were they acquainted? If so, did they become acquainted before or after Ms. Kane moved from Milwaukee, Wisconsin to Chicago, Illinois, where Mr. Bradwell maintained a law office? (2) Did Myra Bradwell know Ms. Kane through her efforts to attain the woman's right to serve on juries?
During the years that both practiced in Wisconsin, Kate Kane and Lavinia Goodell were known to have worked on at least one case together. However, they did not form a partnership. A Miss Angie J. King who was admitted to the Circuit Court of Rock County in 1879, one year after Kane was admitted in both Janesville and Milwaukee, sustained a partnership with Goodell until the latter's untimely death in 1880.23
Before leaving Wisconsin, Kane worked on a case with both Goodell and King. It was a criminal defense case involving a man named Thomas Ingalls who stood accused of stealing clothing from a tailor's shop. Denied the opportunity to use evidence of the defendant's intoxication as proof that he couldn't have committed the crime, Goodell lost the case.24 Other than having assisted in the preparation for the defense, Kate Kane's contribution is as yet unknown.
In compiling materials for her 1890 article on women lawyers in the United States, Massachusetts attorney Lelia Robinson sent queries to every woman attorney known to her, including Kate Kane. The whole text of Kane's reply was not reproduced in Robinson's article, for wont of adequate space. How Robinson met or from whom she learned of Kate Kane is as yet unknown. Perhaps the two corresponded on more than this one occasion. If the letter can be found, their relationship might be better explained.
Both Kate Kane Rossi and Ellen A. Martin attended Michigan Law School, "where more lady lawyers have graduated th an anywhere else."25 And both practiced law in Chicago. Martin went on to publish an article in the Chicago Law Times discussing the admission of women to the bar in which Ms. Kane appears.26
Miss Edith M. Prouty, of Humboldt, Iowa, also wrote about Kate Kane,27 yet Prouty studied at the Law Department of the University of Iowa more than five years after Ms. Kane was admitted to the Illinois bar and was to have continued her studies in the office of her father, J.N. Pr outy, Esq., with an eye toward active practice.28 How Prouty came to know (of) Kate Kane is, at present, unknown.
It may be that Kate Kane was acquainted and/or had the opportunity to work with Charlotte E. Ray, the first African American woman lawyer and perhaps the first woman lawyer in our nation's capital. New York City-born Charlotte E. Ray graduated from Howard University's law department in February of 1872 and opened a law office there in Washington, D.C. Twenty- five years later, looking back on Ray's career, Kate Kane Rossi commented, "Miss Ray . . . although a lawyer of decided ability, on account of prejudice was not able to obtain sufficient legal business and had to give up . . . active practice."29
This connection between Kate Kane Rossi and Charlotte E. Ray is intriguing, given Kane's resolute unladylike comportment inside the courtroom and out.30 As an African American sleuthing information on this "militant lady lawyer" it strikes me that a black woman lawyer would not have enjoyed the positive reception and high regard afforded Ms. Kane.
E. Character Traits & Reputation
Of Kate Kane "[i]t is said . . . that she is a bright, spirited, and fine looking woman of unimpeachable moral character and indomitable will. Her reception in [the Milwaukee] court almost partook an ovation, being invited inside of the bar and introduced to the judge, sheriff, clerk, and principal lawyers, by all of whom she was warmly welcomed."31
Kane's initial reception foreshadowed a career of much notoriety. Her "indomitable will" earned her the title "militant woman lawyer." One account relates that "[i]t was she who struck the opposing counsel over the head with her umbrella in the heat of argument one day in court."32 Another said of her: "Mrs. Rossi is always a lawyeress militant, and her appearance in the justice court is usually followed by a lively and exhilarating time."33 And a third reported that "'[s]he was a good looking woman, high strung, and had a temper like a hyena when aroused, though generally she was as mild and good natured as a kitten.' He then recalled an incident where Kane grew angry with a judge, throwing a glass of water at his head. The glass did no damage, and the judge 'called a bailiff to help Miss Kane to an armchair, where she nearly fainted from fright.'"34
One might expect her "unladylike" militancy to have thrown her into disrepute. Perhaps it was her "fine" appearance that sustained her high regard.
Kate Kane has also been described as a woman of intelligence with "sturdy qualities;" a "vivid[,] colorful personality, outspoken and somewhat pugnacious in her attitude toward her opponents; but tender and warm-hearted to those she defended from criminal prosecutions."35 She was "full of the pioneer spirit, fire, and ready to face any situation courageously,"36 and was reportedly "a woman of ability, a good speaker, and [was] ever ready to defend her rights in or out of court."37
Kate Kane did not wish to be referred to as a "woman," "lady," or "female" lawyer and in a sarcastic style all her own, admonished a Chicago paper demanding that its legal reporter not do so when writing about her. "My mother," she wrote, "finished the business at the christening services when she called me Kate instead of John, and if your reporter had any supplement to add, he should have been there at the time."38 Perhaps John Clerk, a Chicago contemporary who walked with a limp, would have sympathized. To a passerby who had remarked, "That is the famous John Clerk, the lame lawyer," Clerk retorted, "You lie ma'am! I am a lame man, but not a lame lawyer."39
2. Women in Government Service
Women on Juries. Kate Kane is reputed to have supported the effort to place women on juries, having worked together with Esther Dunshee Bower and Catherine Waugh McCulloch who was admitted to the Illinois bar in November, 1886 and was an early leader in the suffrage movement.40 Bower and McCulloch headed the effort to introduce to the state legislature a bill that pushed for the woman's right to serve. Introduced in 1920, the Women's Jury Bill was finally signed into law in 1939.
Myra Bradwell and Lelia Robinson also labored for the cause,41 but no research efforts have yet linked either to Kate Kane.
Women as Police Matrons. Apart from her work on the Women's Jury Bill, James Bradwell writes that "Mrs. Rossi" worked to have matrons appointed for Chicago's police stations.42
Kate Kane was born in 1854. I know not where and have little on which to base speculation. She studied law in Michigan and Wisconsin and then settled in Chicago, Illinois, but no accounts of her study or practice explain her geographical choices with any certainty. Furthermore, no information is as yet forthcoming as to Ms. Kane's childhood, parents, or family. Given Kate Kane's unique constitution and style of practice,43 an understanding of her childhood, family, and early education undoubtedly would prove illuminating. Referred to as a militant lady lawyer, she was something of an oxymoron in her day. Ladies were expected to have "fine, delicate feminine instincts" and "make delightful homes, happy wives, and the best of mothers."44 And lady lawyers were supposed to exact a "civilizing" influence on the courts. Kane's short and expressive temper defy all expectations.
I have almost no information as to the identity of Kane Kane's husband or her child(ren). I know only that her husbands' last name was Rossi and that, sometime before November of 1900, Kate Kane and Mr. Rossi were married and had at least one child.45 Of her life outside the courtroom I know only that she behaved as she did in her professional career: In "an altercation with an elevator boy who refused to take her baby carriage up in the elevator, [Mrs. Rossi] brought her faithful umbrella again into play and the perambulator went up."46 From this account we learn that her bellicose tactics proved successful at least this once.
Kate Kane died November 21, 1928. I know not where and no obituary has yet been found.
General Information
• Martha Louise Rayne. Apart from her book, WHAT CAN WOMEN DO, Martha Louise Rayne herself might prove worthy of investigation. If her papers have been preserved, they might contain references to or correspondence with Ms. Kane. In her book, Rayne invites her readers to contact the women named therein as they would undoubtedly "answer the questions of others of their sex anxious to learn the preparatory steps of a legal education, if corresponded with on the subject."47 Perhaps, at the very least, Rayne kept an address book or list of her subjects' names and address. An address for Kate Kane could lead to new resources.
• Catherine Waugh McCulloch. The biographical sketch that appears in Grace H. Harte's papers were purportedly written by Harte for a chapter on lawyers in a book that Catherine McCulloch was to write about eminent Illinois women. If this book was ever written (it does not appear on Socrates) it should contain information about Kate Kane above and beyond what Harte included in the sketch. Harte also wrote articles for the Women Lawyers' Association publication, Women Lawyers' Journal, which may refer to Kane. Harte was herself an Illinois lawyer, admitted in 1912.
Michigan Law School
• Did Kate Kane graduate from Michigan Law School? I have requested that the school send the contents of its Necrology File on her.
• Virginia Drachman's WOMEN LAWYERS AND THE ORIGINS OF THE PROFESSIONAL IDENTITY IN AMERICA: THE LETTERS OF THE EQUITY CLUB, 1887 TO 1890 (Ann Arbor: University of Michigan Press, 1993) is reputed to contain information about some of Michigan's early women graduates. The text is unlucky to include material about Kate Kane Rossi as the Equity Club originated at the law school in the fall of 1886, long after Ms. Kane had departed for Janesville, Wisconsin. However, while the Equity Club began as a local club for personal meetings, it became a correspondence club that offered membership to any and all women lawyers and law students and circulated an Equity Club Annual that contained letters from its members. Kate Kane may have become a member and contributor. However, Drachman's text and the Equity Club Annual (if still available) could serve as valuable background material even if Ms. Kane does not figure in either. The book is among Stanford Law Library's holdings and has been recalled from a library patron.
Janesville, Wisconsin
• A.A. Jackson. Kate Kane studied law under Janesville attorney A.A. Jackson. Jackson's papers are preserved in the Wisconsin State Archives, State Historical Society of Wisconsin, and may contain references to Ms. Kane.
• Lavinia Goodell. Goodell's sister Maria handwrote a biography of Lavinia's life that numbers more than 230 pages. The manuscript can be found in Box 16, File 6, of the William Goodell Family Papers, Hutchins Library, Berea College, Berea Kentucky. The Goodell Family Papers also include Lavinia Goodell's diaries for six of the last seven years of her life (Box 12) and letters filed by year spanning the last eleven (Boxes 15 & 16). These resources undoubtedly contain references to Kate Kane and the time she spent with Goodell in Wisconsin.
• Miss Angie King. Investigate whether she has papers archived or whether other publications discuss her association with Kate Kane.
• Robert G. Ingersoll. Investigate whether he has papers archived or whether other publications discuss his association with Kate Kane.
Milwa ukee, Wisconsin
• Local Newspapers; Court Records. What was it that inspired the ovation when Ms. Kane was admitted to the bar?48 Historical records and local newspapers might contain this information. Articles about Lavinia Goodell appear the Rock County Recorder and the Milwaukee Sentinel and it is likely that reporters also wrote about Kate Kane.
Chicago, Illinois
• Unnamed Law Journal. In her article advocating that women study law, Edith Prouty refers to an unnamed law journal entry entitled "Chicago's Leading Lady Lawyer;" a piece that is devoted to Kate Kane. If that source could be identified, more information about Ms. Kane would certainly be forthcoming.
• Adelman, Charlotte. In 1986, Charlotte Adelman, who authored `A History of Women Lawyers in Illinois`, served as the archivist of the Women's Bar Association of Illinois (WBAL). WBAL's records are preserved at the Chicago Historical Society (CHS). Adelman, the CHS, or both might be plumbed for information.
Her Practice
• Lelia Robinson. In compiling materials for her piece on women lawyers in the United States, Lelia Robinson sent queries to every woman attorney known to her, including Kate Kane. It could prove useful to investigate the papers of Lelia Robinson and see if the letter Kate Kane sent her can be found therein. In the text of her piece, Ms. Robinson confessed that she had to "omit much of genuine interest . . . and to cut down every personal mention to the fewest possible words." Ms. Kane's letter might be rich with information that Ms. Robinson hadn't the space to include. The letter from Miss Angie J. King, another woman lawyer included in Robinson's piece, might also be a good resource as Miss King worked with Kate Kane early in their careers.
• WOMEN'S BAR ASSOCIATION OF ILLINOIS 20TH ANNIVERSARY JOURNAL AND DIRECTORY (1934). Gwen McNamee of Chicago, who will author Kate Kane's entry in the First 100 Women Lawyers of Illinois project promises that there is a great quote about Kane in this publication. The Journal has been requested via Interlibrary Loan and messages have been left with the WBAL @ (312)-341-8530. McNamee can be reached by e-mail: gmcnam1@uic.edu.
Character & Reputation
• BILL HOOKE R, GLIMPSES OF AN EARLIER MILWAUKEE (MILWAUKEE JOURNAL PUBLIC SERVICE BUREAU 1929), quoted in Christine M. Wiseman, The Legal Education of Women: From "Treason Against Nature" to Sounding a "Different Voice", 74 MARQ. L. REV. 325 (1991), ought to contain more information about Kane. Wiseman's telltale use of ellipses promise as much. The source has been requested via Interlibrary Loan.
• Charlotte E. Ray. The October 23, 1897 edition of Myra Bradwell's Chicago Legal News, quoted in an anthology's entry about Ms. Ray, could contain more than just Kate Kane's reminiscence about Charlotte Ray's legal career. If nothing else, the source might flesh out Kane's attitudes regarding prejudice/racism within the practice of law. It might also prove fruitful to research Ida Platt, the first black woman lawyer admitted to practice law in Illinois (1894),49 for any connection to Kate Kane.
• Local Newspaper & Journal Accounts. Local periodicals will likely prove the richest source for information about Kate Kane. She was famous not necessarily for superb lawyering (although there are no accounts that discredit her abilities) but for her reputed "militance."50
Women on Juries
• Bower, Esther Dunshee. Kate Kane is reputed to have worked with Bower on the effort to put women on juries. According to Gwen McNamee, Bower was a member of the Women's Bar Association of Illinois. The Association's papers are preserved at the Chicago Historical Society.
• Catherine Waugh McCulloch. McCulloch worked with Bower to introduce a bill to the state legislature that would put women on juries. That bill was signed into law in 1939. Although Kate Kane died before the bill was passed, McCulloch must have known Ms. Kane and if McCulloch's papers or a draft of her book about eminent Illinois women have been preserved, either might contain useful information.
Adelman, Charlotte. A History of Women Lawyers in Illinois, 1986 ILL. B.J. 424.
Bartlett, Nancy. Reference Archivist, Bentley Historical Library, University of Michigan, 1150 Beal Avenue, Ann Arbor, Michigan 48109-2113; (313) 764-3482; bentley.ref@umich.edu (necrology file).
Bradwell, James. Women Lawyers of Illinois, 32 CHI. L. NEWS 339 (1900) (cataloguing the first eighty-nine women lawyers of Illinois ).
Cleary, Catherine. Lavinia Goodell, First Woman Lawyer in Wisconsin, 74 WIS. MAG. OF HIST. 243 (1991).
DRACHMAN, VIRGINIA. WOMEN LAWYERS AND THE ORIGINS OF THE PROFESSIONAL IDENTITY IN AMERICA: THE LETTERS OF THE EQUITY CLUB, 1887 TO 1890 (Ann Arbor: University of Michigan Press, 1993).
Development and Alumni Relations, The University of Michigan Law School, 721 South State Street, Ann Arbor, Michigan 48104-3071; (313) 998-7970 (directing historical inquiries to the Bentley Library).
Martin, Ellen A. Admission of Women to the Bar, 1 CHI. L. TIMES 79 (1887).
Mary Earhart Dillon Collection, Grace H. Harte Series, 1890-1945, n.d. Women's Studies Manuscripts Collections from the Schlesinger Library, Radcliffe College. Series 1: Women's Suffrage; Part E: The Midwest and Far West (Microfilm Series E Reel 12).
Prouty, Edith. Women in the Law: Their Past, Present and Future, UNKNOWN (Nov. X, 1900).
RAYNE, MARTHA LOUIS E. WHAT CAN A WOMAN DO: OR, HER POSITION IN THE BUSINESS AND LITERARY WORLD (1884).
Robinson, Lelia. Women Lawyers in the United States, 2 THE GREEN BAG 10 (1890).
Unknown, SAN JOSE MERCURY NEWS, Jan. 16, 1884, at 12.
Unknown, Charlotte Ray, UNKNOWN, at 121 (citing CHI. L. NEWS, Oct. 23, 1897).
Endnotes
1 M.L. RAYNE, WHAT CAN A WOMAN DO: OR, HER POSITION IN THE BUSINESS AND LITERARY WORLD 56 (1884) (Boston University is listed as another).
2 Lelia Robinson, Women Lawyers in the United States, 2 The Green Bag 10, 17 (1890).
3 Catherine Cleary, Lavinia Goodell, First Woman Lawyer in Wisconsin, 74 WIS. MAG. OF HIST. 243, 266 (1991) (noting that Kane is listed as a student with A.A. Jackson at page 87 of the Janesville City Directory 1878-79); RAYNE, supra note 1, at 55 (noting only that Ms. Kane "completed her legal education at a law office at Janesville, Wis.").
4 Lelia Robinson wrote that Kate Kane "duly graduated" from Michigan before moving to Janesville, Wisconsin. Robinson, supra note 2, at 16. However, while Michigan Law School does acknowledge that Ms. Kane was a student there, it has no record of her having graduated. Interview, Office of Alumni, Michigan Law School, Ann Arbor, Mich. ( May 9, 1997). See also Ellen A. Martin, Admission of Women to the Bar, 1 CHI. L. TIMES 76, 85 (1887) (noting that Kate Kane studied for only one year at Michigan Law School and another with A.A. Jackson at Janesville, Wisconsin before being admitted to t he Janesville Bar in 1878).
5 Cleary, supra note 3, at 243.
6 Id. at 266 n.66 (The Rock Creek County Circuit Court is in Janesville, Wisconsin).
7 RAYNE, supra note 1, at 55; Carol Sanger, Curriculum Vitae (Feminae): Biography and Early American Women Lawyers, 46 STAN. L. REV. 1245, 1246 & n.9 (1994) (citing M.L. RAYNE'S WHAT CAN WOMEN DO).
8 RAYNE, supra note 1, at 54-57.
9 Id. at 54. Rayne compared her figures to that of a "Miss Ellen A. Martin, of Chicago, who ha[d] compiled a list of them, [but gave] but twenty-six." Id. While Martin's list may have been incomplete, Kate Kane figures among them. See Martin, supra note 4, at 84.
Perhpas unsurprisingly, both women's figures were incorrect. See Christine M. Wiseman, The Legal Education of Women: From "Treason Against Nature" to Sounding a "Different Voice", 74 MARQ. L. REV. 325, 330 (1991) (noting that "by 1880, there were some 200 women lawyers in the United States) (citing RONALD CHESTER, UNEQUAL ACCESS: WOMEN LAWYERS IN A CHANGING AMERICA 8 (1985)).
10 RAYNE, supra note 1, at 55. It may be something of a misnomer to say that Kate Kane was Milwaukee's first woman lawyer as "[a]dmission to one circuit court bar entitled the person to practice in any court in the state except the supreme court . . . which made its own orders." Cleary, supra note 3, at 251. Having been admitted at Janesville, Kane should have been licensed to practice in Milwaukee automatically.
11 Mary Earhart Dillon Collection, Grace H. Harte Series, 1890-1945, n.d. Women's Studies Manuscripts Collections from the Schlesinger Library, Radcliffe College. Series 1: Women's Suffrage; Part E: The Midwest and Far West (Microfilm Series E Reel 12), at 12:0300 [Hereinafter Harte Papers]; Robinson, supra note 2, at 16.
12 Harte Papers, supra note 11, at 12:0300.
13 James Bradwell, Women Lawyers of Illinois, 41 CHI. L. NEWS 339, 340 (1900).
14 Bradwell v. Illinois, 83 U.S. 130 (1873) (Bradley, J., concurring) (supporting the majority opinion denying Myra Bradwell the right to practice law).
15 Wiseman, supra note 9, at 335 (noting that Kate Kane had a municipal law practice in the 1880s).
16 Bradwell, supra note 13, at 340.
17 Harte Papers, supra note 11, at 12:0300 .
18 Robinson, supra note 2, at 16.
19 Harte Papers, supra note 11, at 12:0300.
20 Cleary, supra note 3, at 269 & n.77 (noting that one of Goodell's diary entries read: "Went to Sup. Ct. Got admitted, but poor Miss Kane left out, which spoiled all my pleasure.").
21 Bradwell v. Illinois, 83 U.S. 130 (1873).
22 Charlotte Adelman, A History of Women Lawyers in Illinois, Ill. B.J. 424 (1986).
23 Robinson, supra note 2, at 24.
24 Cleary, supra note 3, at 267.
25 RAYNE , supra note 1, at 54.
26 Martin, supra note 4, at 84.
27 Edith Prouty, Women in the Law: Their Past, Present and Future, UNKNOWN, (Nov. __, 1900).
28 Robinson, supra note 2, at 22.
29 UNKNOWN, Charlotte Ray, UNKNOWN, at 121 (citing the CHI. L. NEWS, Oct. 23, 1897).
30 See Part I.E infra.
31 RAYNE, supra note 1, at 55.
32 Prouty, supra note 27.
33 Id. (quoting an unnamed law journal).
34 Wiseman, supra note 9, at 335 (quoting BILL HOOKER, GLIMPSES OF AN EARLIER MILWAUKEE 37 (Milwaukee Journal Public Service Bureau 1929)) (questioning whether "anyone with the temerity to throw a glass of water at a judge would faint from fright").
35 Harte Papers, supra note 11, at 12:0300.
36 Id.
37 Bradwell, supra note 13, at 340.
38 SAN JOSE MERCURY, Jan. 16, 1884, at 2.
39 Untitled, 41 CHI. L. NEWS 346 (June 2, 1900).
40 See Adelman, supra note 22, at 425; Bradwell, supra note 13, at 340.
41 See, e.g., Adelman, supra note 22, at 424 (discus sing Myra Bradwell); Lelia Robinson, Women Jurors, 1 CHI. L. TIMES 22 (1887) (discussing her experiences with mixed juries in Seattle, Washington Territory).
42 See Bradwell, supra note 13, at 340.
43 See Part E supra.
44 Robinson, supra no te 41, at 24 (describing the "ladies" who served on juries in the Washington Territories).
45 Prouty, supra note 27.
46 Id.
47 RAYNE, supra note 1, at 56.
48 See id. at 55.
49 See Adelman, supra note 22, at 425.
50 See, e.g., Prouty, supra note 27.
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