Joseph P. Bradley since the "Hans" doctrine is entirely based on judicial activism and, as Bradley admitted in his opinion, not supported by the text of the Constitution. As an individual Supreme Court Justice, Bradley decided "In re Guiteau", a petition for habeas corpus filed on behalf of Charles Guiteau, the assassin of President James A. Garfield. Guiteau's lawyers argued that he had been improperly tried in the District of Columbia because, although Guiteau shot Garfield in Washington, D.C., Garfield died at his home in New Jersey. Bradley denied the petition in a lengthy opinion and Guiteau was executed. Bradley is best remembered
1880 United States presidential election for months, eventually declining to return either man to the Senate. Before that result was known, however, tragedy struck as Charles Guiteau, a mentally unstable man disappointed at being unable to secure a patronage appointment, shot Garfield on July 2, 1881. Garfield lingered for two-and-a-half months before dying on September 19, 1881. Vice President Chester A. Arthur, the New York Stalwart, was sworn in as president that night. Garfield's murder by a spoilsman inspired the nation to reform the civil service—and Arthur, erstwhile member of the Conkling machine, joined the cause. In 1883, a bipartisan majority in Congress passed the