Several district and circuit court rulings followed Taney's opinion. However, according to historian Harold Hyman, most northern lawyers accepted Lincoln's view that Taney's opinion in "Merryman" was "ultimately reversible by political processes", and Taney's opinion in that case "convinced no other justices and few lower federal judges". However, Taney's "Merryman" opinion was adopted by some lower courts, such as the United States District Court for the Southern District of New York and the Supreme Court of Wisconsin. See, e.g., Ex parte McQuillon, 16 F. Cas. 347, 348 (S.D.N.Y. 1861) (No. 8294) (Betts, J.) ("Betts would, however, follow out that case ["Merryman"], but would express no opinion whatever, as it would be indecorous on his part to oppose the [Justice. He would therefore decline taking any action on the writ at all."); In re Kemp, 16 Wis. 359, 1863 WL 1066, at *8 (1863) (Dixon, C.J.) ("I deem it advisable, adhering to the precedent set by other courts and judges under like circumstances, and out of respect to the national authorities, to withhold habeas relief until they shall have had time to consider what steps they should properly take in the case"). Just as Taney chose not to grant John Merryman relief at the termination of litigation, Betts and Dixon also refused to grant the litigants before them, who were situated similar to Merryman, release from imprisonment.