In 1873, also in North Carolina, the judge in "State v. Oliver" ruled, "We assume that the old doctrine that a husband had the right to whip his wife, provided that he used a switch no larger than his thumb, is not the law in North Carolina". These latter two cases were cited by the legal scholar Beirne Stedman when he wrote in a 1917 law review article that an "old common law rule" had permitted a husband to use "moderate personal chastisement on his wife" so long as he used "a switch no larger than his thumb".