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
Charles J. Guiteau probing the wound with unwashed hands and non-sterilized instruments, Garfield died on September 19, eleven weeks after being shot. Most modern physicians familiar with the case state that Garfield would have easily recovered from his wounds with sterile medical care, which was common in the United States a decade later, while Candice Millard argues that Garfield would have survived Guiteau's bullet wound had his doctors simply left him alone. However, Garfield's biographer Allan Peskin stated that medical malpractice did not contribute to Garfield's death; the inevitable infection and blood poisoning that would ensue from a deep bullet wound resulted in