Document Type

Trial Proceeding

Publication Date


Article Footnote

Article 1, footnote 47

Book Footnote



In the spring of 1767, Anna Foss left her husband Zachariah Foss on account of alleged maltreatment and sought refuge in the house of her son, John Adams. Zachariah might have brought a habeas action against John requiring him to produce Anna, which would have resulted in an equitable ruling by the bench.

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