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In Re Hodsdon, Strafford County Superior Court Records 1814, Folder 38, Doc. 1 - Application For Writ Of Habeas Corpus
Documents from Making Habeas Work: A Legal History (monograph)
... “all citizens of the United States” who had “been arrested by persons claiming to act under the authority of the President of the United States,” and were being confined by Hodsdon “without colour of authority.