List of violent incidents involving Andrew Jackson

Andrew Jackson, 1819 portrait in oil paint by Samuel Lovett Waldo (Metropolitan Museum of Art object 06.197)

Duel between Gen. Jackson and Charles Dickinson, Esq. in 1806 – woodcut from one of the 1828 Coffin Handbills

Andrew Jackson stabbing Samuel Jackson with a cane-sword – woodcut from one of the 1828 Coffin Handbills

Andrew Jackson, later seventh president of the United States, was involved in a series of altercations in his personal and professional life. Jackson killed a man, was shot in a duel (in 1806), was shot in a tavern brawl (in 1813), and was charged, in separate incidents, with assault and battery (convicted), and assault with intent to kill (acquitted). In multiple incidents over several decades Jackson and his underlings reportedly brandished or deployed a wide array of weapons against their opponents, including horsewhips, knives secreted in canes, canes used as melee weapons, clubs, axes, pistols, and rifles. (Note: This list of weapons does not include weapons used in war, nor means of execution used on men he sentenced to death when he was an officer of the U.S. military or Tennessee militia, nor actions taken or not taken by the U.S. military and Indian Affairs officers during the expulsion and deportation of Indigenous people from the U.S. South.)

Physical violence of Andrew Jackson

According to historian J. M. Opal, "[Jackson's] willingness to kill, assault, or threaten people was a constant theme in his adult life and a central component of the reputation he cultivated." One writer who investigated Jackson's brief residence circa 1788–89 in what is now East Tennessee reported, "He was recognized from the first as a man who 'would fight at the drop of a hat, and drop the hat himself.'" Donald B. Cole wrote that Jackson's "violent personality emerged early and dominated his life." Per biographer Robert V. Remini, Jackson had a "vicious temper that frequently exploded into ugly language and acts," and such a temper tantrum, "so furious and startlingly sudden, intimidated his victims by its abruptness and its noisiness." Horse trainer and Congressman Baylie Peyton wrote that "nobody ever 'jawed back' at Old Hickory when he was in one of his ways."

One historian wrote of his pre-war years, "By his mingled tact and daring he soon became a power in the sparsely settled community. His temper was nothing less than volcanic. His oaths were varied, numerous, and highly effective. Yet after he reached middle life both were less frequently in evidence, and except upon extraordinary occasions were more moderate than in youth." A Methodist chaplain—who correctly intuited Jackson's inability to live in egalitarian humility, or to admit to any fault whatsoever—wrote in his journal of the Natchez Expedition, "I find the Gen. cannot bare [sic] much opposition. He is a good General but a very incorrect divine." In 1820 after British subjects in Upper Canada destroyed a wax effigy of Jackson to protest the executions of Ambrister and Arbuthnot, a wag reportedly commented, "It was well Old Hickory did not appear in the heat of the action or he would have made you know the difference between the man of whacks, and the man of wax."

It has been hyperbolically claimed that Jackson "participated in more than 100 duels over his lifetime" but that is not correct. That said, in 1828 a man named Dr. James L. Armstrong, who had been a surgeon in Jackson's militia in the War of 1812, claimed that he had started making a list of altercations involving Jackson and the final list "accumulated to nearly ONE HUNDRED FIGHTS or violent and abusive quarrels." Armstrong's published index, issued under the title General Jackson's "juvenile indiscretions" between the ages of 23 and 60, listed 14 notable instances. Shortly after the publication of this negative-campaign material, a Kentucky newspaper claimed that four men, including Archibald Yell and his law partner William Gilchrist, stopped by to "assassinate" (assault) Dr. Armstrong in Bedford County for writing anti-Jackson columns, chasing him down and clubbing him. A comment from another correspondent was appended to the report: "This is Jacksonism in its true colors such as the Hero in early times has often acted himself!" Nashville papers claimed that the beating was because Armstrong had insulted Gilchrist's father by calling him a Tory, and reported that Malcolm Gilchrist beat Armstrong with a hickory stick, while Yell and another man, Jesse Taylor, did not strike Armstrong but did hold pistols at the ready. (In 1831 President Jackson appointed Yell to be receiver of public moneys at the United States General Land Office in Little Rock, Arkansas Territory.)

Jackson's apparent propensity for physical violence was very much an issue for the anti-Jacksonians in the 1824 and 1828 presidential elections. During the 1824 presidential election, Jesse Benton, brother of U.S. Senator Thomas Hart Benton (and very much an interested party in questions of Jacksonian violence, as he was the one who shot Jackson in 1813), published a pamphlet that stated, "...it is a notorious fact, that he was scarce ever known to leave a [horse racing] round without having participated in an affray or riot, or at least a quarrel." News reports about Jackson's history of violence seem to have at least caught the attention of the voting public. In Natchez, Mississippi, which was at times the center of "an almost blind hero-worship" of Jackson, "based more on his many local acquaintances and his military record than on his position in national politics," a group of nabobs published an anti-Jackson broadside in 1828. The signatories, including Stephen Duncan, Francis Surget, Alvarez Fisk, Felix Huston, and Adam L. Bingaman, indicated that they supported Adams, attesting that they dreaded Jackson's election "as much (if possible) on account of the violence of his many adherents, as of his own peculiar unfitness for the station." One Delaware voter wrote his local newspaper to this effect:

They do not deny, that Andrew Jackson has often been engaged in the most disgraceful broils and riots in the streets and taverns of Nashville, shooting with pistols and stabbing with dirks on all hands of him. But they tell you that we have no right to investigate his private character, and that his quarrels, duels, adulteries and murders, furnish no arguments against his fitness for an office, where patience, ability and virtuous principles are indispensable requisites to the continuance of the good Government and liberties of our country.

Similarly, Thomas E. Waggaman of Washington, D.C. wrote Felix Robertson in November 1828 that he had received a letter from a "corresponding committee in Harrisburg Pa. requesting me to give them a history of the Genl's 'trading in negroes cutting off ears' and other acts of violence ascribed to him by the tools of corruption." Jackson was an interstate slave trader active for 20–25 years (c. 1789–c. 1814); whether or not he ever cut off anyone's ears is unrecorded by history, although he repeatedly threatened it. In 1827 an anti-Jacksonian pamphleteer nodded to the ear-cropping hearsay when he wrote, "Andrew Jackson, and John Quincy Adams, have placed themselves before a court of enquiry, the nation is the tribunal, every citizen is a member of the court, I am one of them. I will speak therefore, although I jeopardize my ears, or my life." In the United States this practice, called ear cropping, was one of a number of livestock-management practices—including branding, castration, chaining, and whipping—that were used against the enslaved. Ear cropping, toe removal, and castration were amongst the most extreme measures used to enforce subservience. The intent behind ear-cropping specifically was permanent, visible mutilation, and thus implied ongoing shaming and contempt of the person so mutilated. Evidence that Tennessee slave owners practiced ear-cropping appears first in an issue of the Knoxville Gazette from 1796. As summarized by the editors of American Slavery As It Is: Testimony of a Thousand Witnesses in 1839, slavery entailed a veritable panoply of violence: "The slaves are often branded with hot irons, pursued with fire arms and shot, hunted with dogs and torn by them, shockingly maimed with knives, dirks, &c.; have their ears cut off, their eyes knocked out, their bones dislocated and broken with bludgeons, their fingers and toes cut off, their faces and other parts of their persons disfigured with scars and gashes, besides those made with the lash."

In addition to threatening to cut off peoples' ears, Jackson also repeatedly menaced peoples' houses with fire: he wrote a U.S. Senator that "the wrath and indignation of our citizens will...involve Silas Dinsmore in the flames of his agency house." According to the slave narrative of "James Roberts," following the Battle of New Orleans, Andrew Jackson spoke to his soldiers and hundreds of slaves had been impressed to dig earthworks and declared (in part), "Before a slave of mine should go free, I would put him in a barn and burn him alive..." During Indian removal he told Secretary of War Eaton to tell the Chicksaw agent to tell squatters on Chickasaw land that their houses would be burned down if they did not wait to claim land until the U.S. government signaled it was time.

"Burning of the town Pilak-li-ka-ha by Gen. Eustis" during the Second Seminole War; Pilaklikaha, Florida was one of the Black towns in Florida; "Negro Abram" founded Peliklakaha, also known as Many Ponds and Abraham's Old Town, which in 1826 was home to 100 people who grew "fields of rice, beans, melons, pumpkins, and peanuts" and managed herds of cattle and horses

Despite Jackson's presence in the Southern theater of the American Revolutionary War, close association with American commanders of the Cherokee–American wars, and leadership of militia in the War of 1812, the Creek War, and the Seminole War, historians have found that "there is no explicit account of his actually firing at an enemy in standard battle." As one Indigenous historian, Albert Bender, wrote in 2021, "Jackson moved to Nashville in 1788, at a time when battles between white settlers and allied Cherokees and Creeks were raging in the area. But there is no record of his having fought any Indians at all during this period. This seems somewhat odd in light of his later advocacy." Nonetheless, the violence of military personnel under his command (not currently included on this list) "was considerable." Jackson's use of violence against other wealthy White men may also be informative about his use of violence against slaves: "Jackson [had] rage to spare as he considered dueling Thomas Hart Benton, John Sevier, Henry Clay and others whom society viewed as his equals. It is difficult to believe that he would interact with an insolent enslaved man or woman on better terms than he would these esteemed gentlemen. It is also inconceivable that he would allow anyone to beat any of the horses he owned 300 times." Smithsonian magazine wrote of American dueling in 2004, "Formal dueling, by and large, was an indulgence of the South's upper classes, who saw themselves as above the law—or at least some of the laws—that governed their social inferiors...Dueling was...an expression of caste—the ruling gentry deigned to fight only its social near-equals" (and thus duelling eventually died with the defeat of the South in the Civil War as "the caste whose conceits it had spoken to had been fatally injured by the disastrous war it had chosen.")

Jackson was packaged as a little-d democrat, supposedly speaking and acting on behalf of the average working white man, but in point of fact was one of the largest slaveholders in Tennessee and the south, which meant he was one of the wealthiest men in the country. According to the scholarship of Bertram Wyatt-Brown, Jackson was acutely self-conscious of the role of violence in creating both his public identity and position in an under-construction national class and race hierarchy, and thus acutely sensitive to overt acts that questioned his status.. His intense focus on the political–symbolic use of violence is evidenced by a remark he made about his perceived enemy Thomas Jefferson, upon hearing that Jefferson had toasted Jackson's victory at New Orleans: "I am glad the old gentleman has plucked up courage enough to at least attend a banquet in honor of a battle."

Hickory

Jackson's nickname Old Hickory, or Ol' Hickory, may have been a play on words hinting at his predilection for violence. The Oxford English Dictionary definition for hickory oil (sense 2) is "U.S. figurative corporal punishment using a hickory switch or similar instrument, viewed as a treatment for bad behaviour (now rare); During the first half of the nineteenth cent., the phrase was also used to refer to the administration of U.S. President Andrew Jackson, nicknamed Old Hickory (see Old Hickory n.), which may have influenced the development of sense (b)." The "hickory oil" treatment was sarcastically "celebrated for its efficacy in removing idleness." In November 1815, Jackson's adjutant Robert Butler wrote him with an update about the enslaved community at the Hermitage: "Your wenches as usual commenced open war and they have been brought to order by Hickory oil." A banquet toast made in Pennsylvania during the 1828 election saluted, "Hickory oil, an infallible remedy for the Quincy epidemic." There are no known accounts of Jackson himself dispensing "hickory oil," but Rev. William Leftwich, grandson of Jabez Leftwich, was given to his uncle as a young boy and put to work in the cotton fields of northern Alabama, and the 1830s he wrote a testimony to the American Anti-Slavery Society that mentioned "hickory" as a weapon: "My uncle was his own overseer. For punishing in the field, he preferred a large hickory stick; and wo to him whose work was not done to please him, for the hickory was used upon our heads as remorselessly as if we had been mad dogs. I was often the object of his fury, and shall bear the marks of it on my body till I die. Such was my suffering and degradation, that at the end of five years, I hardly dared to say I was free. When thinning cotton, we went mostly on our knees. One day, while thus engaged, my uncle found my row behind; and, by way of admonition, gave me a few blows with his hickory, the marks of which I carried for weeks."

Fights, duels, beatdowns, and attempts at same

• Duel with Waightstill Avery, 1788; the challenge from Jackson read "Sir, when amans feelings & charector are injured...it is consistant with the charector of agentleman when he Injures aman to make aspedy reparation." Both men fired into the air. The cause seems to have been Avery ridiculing a legal argument made by Jackson in court, with one variation being "that Jackson had ridiculed Avery's pet authority—Bacon's Abridgment, and Avery's reply was "sarcastic...intimating that Jackson had much to learn before he would be competent to criticize any law book whatever." Avery reportedly gave Jackson a fatherly lecture after the duel was over and kept the written challenge filed amongst his myriad papers as "Challenge from Andrew Jackson." John Adair was Avery's second.
• Duel with unidentified opponent near Jonesboro, Tennessee, probably 1789, but sometime before November 1790, "'in the long meadow,' as it was then called (formerly the 'hollow'), on the north side of town, and they all asserted that the duel with Avery was fought on the hill on the south side...He said that Jackson hit his man, but he was not seriously wounded, and soon recovered and left the community; that Jackson was not touched."
• Allegedly, in approximately 1797, while Jackson was serving as a Representative to Congress, Founding Father, former North Carolina governor, and U.S. Senator Alexander Martin mentioned Jackson's brother-in-law Stockley Donelson's connection to North Carolina's Glasgow land frauds (just for one thing Donelson was married to a daughter of James Glasgow), in response to which Jackson "charged the Legislature, Executive and Citizens of North-Carolina, at a public dining table, with being a set of Rogues and Rascals, and challenged the Governor to a duel." Martin verbally deescalated the situation.
• Allegedly, according to an Adams-aligned paper in 1826, while Jackson was a judge (between 1798 and 1804), "it so happened that a man, with whom he had previously been at variance, and who had insulted him, made his appearance in the Court Room. The Judge, on recognising him, threw off his coat, assailed him with a cow-hide, and whipped him to his heart's satisfaction!"
• Roadside standoff in 1803 between Jackson and John Sevier, pistols and a sword were drawn but to no effect; Remini speculated that "with all this dallying it is possible that neither man really wanted to risk his life and career on a duel but that both wished to stigmatize the other with a refusal to fight. Perhaps it should be pointed out that Sevier had eighteen children."
• February 13, 1804 - "Assaulted John C. Henderson"
• January 13, 1806 - Jackson beat Virginia attorney Thomas Swann with a cane at a tavern, part of the long lead-up to the fatal-for-Dickinson Jackson–Dickinson duel.
• January 27, 1806 - "Found guilty of assault and battery upon Thomas Baird"
• May 30, 1806 - Duel with Charles Dickinson, Jackson killed Dickinson; Dickinson hit Jackson first, and Jackson may have later suffered lead poisoning as a result of the unremoved bullet, but "concealed his own injury from Dickinson's associates to spite Dickinson in his death."
• March 6, 1807 - Jackson chased down fellow land speculator Samuel Dorsey Jackson in the street over an unpaid debt, S. Jackson was evidently unarmed but reached for a rock to defend himself, and A. Jackson deployed a knife hidden inside a cane. Jackson was tried and acquitted on charges of assault with intent to kill against Samuel Jackson (no relation, as far as historians can tell). S. Jackson was not seriously injured, if at all, and the pair later did business with one another. The indictment, written by future U.S. Senator Jenkin Whiteside, stated that the stab wound was .5 inches (13 millimeters) across and 4 inches (100 millimeters) deep. The exact language was that Andrew Jackson "an assault did make in & upon one Samuel Jackson, in the peace of the State then and there being, and that the said Andrew Jackson, with a certain drawn Sword which he said Andrew Jackson in his right hand then & there had & held in and upon the Left side of him the said Samuel Jackson above the Short ribs of him the said Samuel did Strike & thrust, giving to the Said Samuel Jackson then & there with the Sword aforesaid in & upon the aforesaid left side of him the said Samuel above the short ribs of him the said Samuel a wound of the breadth of half an Inch and of the depth of four inches with an Intent him the said Samuel Jackson then & there feloniously wilfully and of his malice aforethought, to kill & murder, and other wrongs & enormities to Said Samuel Jackson then and there did to the great damage of the said Samuel Jackson and against the peace & dignity of the State."
• According to various reliable sources, threatened a federal agent in 1812. One description has it that "when he approached the Agency, he armed his negroes with axes, hired some half breed Indians with their arms—marched by the agency in military order, himself at their head with the cap of his holsters thrown back, and his rifle cocked", and later successfully campaigned to have the agent's boss, Silas Dismoor, fired from his job.

"Dreadful Fracas Atween the Gineral and the Bentons at Nashvil" from Seba Smith's 1834 parodic biography of Andrew Jackson

• In 1813, during the interregnum between the fruitless Natchez expedition and the Fort Mims massacre that started off the Creek War, Jackson participated in a brawl at Nashville tavern with Thomas Hart Benton (great-great-uncle of the painter), Jesse Benton, John Coffee, Stockley Hays, and Alexander Donelson. The men deployed knives, and whips, and shot each other with pistols; Jesse Benton shot Jackson in the shoulder or arm and Jackson was seriously injured. At age 46, this was Jackson's last gunfight. According to Remini in 1977, "Like the others, there was something petty about it. None of Jackson's quarrels did him credit; all diminished him." As of 1826, there were still two bullets from this fight embedded in the wall of the tavern "to which some of the hot headed Tennesseans daily offer repeated and hearty libations."

Bell Tavern photograph, taken sometime before the building was condemned in 1913, as published in Paddy Meagher's Ordinary and the Bell Tavern (Memphis and Shelby County Room 976.819 A955p)

• Date unclear (1810s?), Jackson allegedly caned a man who suggested that he was the father of a girl called Sally Meagher who lived near the Third Chickasaw Bluff (now Memphis) and what is now called President's Island; "the account published of this caning by his enemies, some fifteen years later, was very prejudicial to Jackson. It was even stated that several of his friends stood by with cocked pistols, threatening to kill the fellow if he moved. The General gave some grounds for this charge by his excessive fondness for Sally, and the common opinion was that he would either adopt her or do something handsome for her." Paddy Meagher was some kind of vassal to Jackson, although no one entirely understood the arrangement. As for Sally, "Jackson once thrashed a fellow for talking about Sally. Sally was short and thick, and had red hair and a ready wit, all of which she inherited from Paddy. She had talented legs as well as a talented tongue, and could outdance the rest of the young women of the neighborhood. She drew custom to Paddy's bar, where a free and easy manner reigned." In 1822, either the first or second property deed ever registered in Memphis (a town that began as a land speculation of Jackson, John Overton, and James Winchester) was lot 43, recorded in the name of Sally Meagher. Both Paddy Meagher and Sally Meagher eventually died of alcohol dependence-related illnesses.
• In 1828, Jackson and Jesse Benton had a sequel to their 1813 Nashville tavern brawl, only this time the venue was the Bell Tavern in Memphis. The second time around Jesse Benton was beaten.

Self-defense

• In 1833, Robert Beverly Randolph, a U.S. Navy purser who had been fired for "rendering a false financial account," came up to President Jackson at a party in Virginia and "tried to pull his nose." Jackson immediately grabbed his trusty cane and yelled that his age would not prevent him from "punishing a dozen cowardly assassins." Randolph ran off; when he was later caught and charged with assault Jackson told Van Buren to pardon him, apparently because in Jackson's mind, according to historian Bertram Wyatt-Brown, "only physical reprisal was the proper response to insult."
• During an assassination attempt while he was president, at age 68, Jackson "armed only with a cane, he had valiantly charged forth to do battle with an assassin carrying two pistols."

Threats

Threats included on this list should be specific, targeted, and potentially actionable. Rhetorical and figurative flourishes alluding to violence are not currently included. An example of the latter would be Jackson writing about Aaron Burr in January 1807: "If he is a traitor, he is the basest that ever did commit treason, and being tore to pieces, and scattered to the four winds of heaven, would be too good for him." See below for a related counter example, a seemingly specific, targeted and potentially actionable threat against Secretary of War Henry Dearborn.

• Sometime between 1788 and 1794, Jackson reportedly promised to "cut the ears out of [Robards's] head," meaning Lewis Robards. This was in the course of their conflict over the future Mrs. Jackson.

Further information: Lewis Robards § Lewis Robards v. Andrew Jackson

Russell Bean surrendering to Judge Jackson (conjectural illustration published 1844)

• The highest and best use of Jackson's propensity for threatening people was probably in 1798, the first year of his service as a state judge. A man named Russell Bean had returned from an extended trip to the Natchez District, found his wife nursing a child he could not have fathered, and cut off the baby's ears. Despite repeated attempts, the local sheriff failed to successfully execute the arrest warrant for Bean, a hulking and evidently well-armed master gunsmith. Jackson, on hearing this, armed himself with two pistols, found Bean and said something to the effect of "surrender, you infernal villain...or I'll blow you through." In reply, Bean reportedly "called out, 'I'll surrender to you, Mr. Devil!' and laid down his arms." This anecdote has the savor of folklore and Jackson himself never commented on it. The editors of The Legal Papers of Andrew Jackson (1987) recounted the historiography of the story and reported that they had found a "warrant issued in February 1802 by a justice of the Washington County Court of Pleas and Quarter Sessions for Bean's arrest for having feloniously and on purpose maimed and disfigured an infant child by having cut off both its ears.' The editors have not discovered any documentation linking Jackson with the prosecution of Bean in the Washington County court in 1802."
• 1806: Threatened to kill a "Secretary of War for advising him, accurately, about rumors that connected him with Aaron Burr." Henry Dearborn had questioned Jackson's allegiance because of reports that he was sending two regiments of men to the lower country to aid Burr in his expedition. Jackson wrote to Dearborn about Burr, "But, sir, when prooff [sic] shows him to be a traitor, I would cut his throat with as much pleasure as I would yours on equal testimony."
• Allegedly threatened to hang attorney Jonathan Thompson "to the first tree, or highest tree" for pursuing legal action regarding Aaron Burr and/or Harman Blennerhassett's debts.
• Allegedly "swore by god he would shoot all his prisoners" if served a writ of habeas corpus for people detained under his declaration of martial law in New Orleans in 1814–15.
• According to the slave narrative of James Robinson, after Jackson used slaves and free people of color to fight and win the Battle of New Orleans, he made a speech recanting promises to free the slaves who had worked and fought under his command and added, "Before a slave of mine should go free, I would put him in a barn and burn him alive."
• Allegedly "threatened personal violence to several of our senators" who were investigating or criticizing his illegal seizure of Florida, an invasion generally known as the First Seminole War. To be specific, in January 1819 he apparently raged to his advisors that he should challenge Congressman Henry Clay to a duel for speaking out against him on the floor of the house and that he would "cut off [Abner] Lacock's ears" for heading the Senate select committee that "methodically gathered and sifted evidence" in the matter.
• In 1827, while on his way to New Orleans for an electioneering trip, the steamboat Pocahontas on which he was a passenger was playfully "buzzed" by another steamer. According to James Alexander Hamilton (son of Alexander Hamilton), who had invited himself along on the trip to benefit Martin Van Buren, this made Jackson furious, and Jackson "sent for his rifle" and "shouted to the other steamboat that he would shoot the pilot if he continued to show such disrespect." Mrs. Jackson, who was along for the trip, ably defused the situation.
• Date unclear: Threatened to kill two men who called him "ambitious"

Other quarrels, evidently non-violent

Scott in 1814, around the time when Jackson was quarreling with him

• In 1817, Jackson "challenged" Winfield Scott, after Scott confirmed that he considered Jackson to have "committed an act of mutiny" when he "ordered disobedience by his troops" to War Department orders. Apparently they did not fight but Jackson called Scott a "hectoring bully" and one of the War Department's "intermeddling pimps and spies." Scott replied that "Jackson could call him whatever he chose...but he should wait until the next war to find out if Scott were truly a coward."
• According to one capsule biography of federal judge John McNairy, McNairy supported the removal of James Robertson as U.S. agent to the Chickasaws, and Jackson opposed it, and "Jackson became so enraged at the attitude of his former friend and fellow student and used such 'unparliamentary language' in regard to him that a breach occurred that time never healed."

See also

• Legal affairs of Andrew Jackson
• Dueling in the Southern United States
• Andrew Jackson and slavery § Violence
• Arrest of Dominic Hall and Louis Louaillier
• Arbuthnot and Ambrister incident
• Josiah Francis (Hillis Hadjo)
• Coffin Handbills

Further reading

• Gorn, Elliott J. (February 1985). ""Gouge and Bite, Pull Hair and Scratch": The Social Significance of Fighting in the Southern Backcountry". The American Historical Review. 90 (1): 18. doi:10.2307/1860747.
• Somit, Albert (1948). "Andrew Jackson: Legend and Reality". Tennessee Historical Quarterly. 7 (4): 291–313. ISSN 0040-3261. JSTOR 42620991.
• Yarn, Douglas (2000). "The Attorney as Duelist's Friend: Lessons from the Code Duello". Case Western Reserve Law Review. 51 (1): 69. ISSN 0008-7262.