courts, the majority of them arising from prosecutions of Mormon polygamists in the courts of the Utah Territory. Reynolds v. United States (1878) rejected six challenges to a polygamy conviction: that the territorial grand jury statute provided for fewer members that grand juries in the circuit courts; that it violated the Impartial Jury Clause to seat a juror opposed to polygamy; that for cause challenges were improperly granted to the prosecution; that testimony violated the Confrontation Clause; that polygamy was protected by the Free Exercise Clause; and that it was improper for the judge to comment on the social ills of polygamy. Miles v. United States (1880) also rejected several challenges to a polygamy conviction. The Court held that bigamy could be proved by testimony (as opposed to, for example, a wedding certificate); that the question of whether the evidence established guilty beyond a reasonable doubt could not be raised de novo in the Supreme Court; that the judge could exclude jurors for-cause who believed polygamy was compelled by God; that it was too late post-conviction to complain for the first time that the wives were not named in the indictment; that there was no invalid variance from the indictment between the names "Caroline Owens" and "Caroline Owen Maile"; that wearing a wedding dress and attending a church known for polygamous weddings were competent evidence of marriage; that incompetent testimony (proof of the first marriage given by the second wife) could be given at the voir dire. In another such case, Clawson v. United States (1885), the Court held that there was no right to bail on appeal where a defendant had been sentenced to imprisonment (there was such a right where the only punishment was a fine). Reaching the merits that same year, the Court held that the Congressional statute permitting for-cause challenges of jurors who believed that polygamy was divinely compelled applied to grand juries as well as petit juries, and that the marshall could call a second venire if the 200-person venire was exhausted before a full jury was seated. In Cannon v. United States (1885), the Court rejected two further challenges. First, the Court held that an indictment for the polygamy offense (which only applied to male defendants) need not allege the gender of the defendant. Second, the Court held that it was no defense that the defendant had ceased having sexual relations with his additional