Subsequent citations claimed that the effect of the case was actually to impose limits on the physical punishment on slaves, rather than to express comment on legality of slavery generally. In the case of John Lilburne in 1649, the defendant's counsel relied upon "Cartwright's case" to show that the severity of a whipping received by Lilburne exceeded that permitted by law. In none of subsequent common law cases prior to Somersett's case was Cartwright's case cited as authority for the proposition that slavery was unlawful. However, those disputes predominantly concerned disputes between slave merchants (the notable exception being "Shanley v Harvey", as to which see below), for whom it would have been commercially unwise to plead that slavery was unlawful.