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 had been legally insane at the time of the shooting (because God had taken away his free will), he was not really medically insane, which was one of the major causes of the rift between him and his defense lawyers. Edward Charles Spitzka, a leading alienist, testified as an expert witness. Spitzka had stated that it was clear "Guiteau is not only now insane, but that he was never anything else." While on the stand, Spitzka testified that he had "no doubt" that Guiteau was both insane and "a moral monstrosity". Spitzka came to the conclusion that Guiteau had "the