The Chase Court (1864–1873) issued thirty-five opinions in criminal cases over nine years, at a significantly higher rate than the Marshall Court or Taney Court before it. Notable such cases include Ex parte Milligan (1866), Pervear v. Massachusetts (1866), Ex parte McCardle (1867, 1869), Ex parte Yerger (1868), and United States v. Kirby (1868). An array of Reconstruction-era statutes created new federal crimes and new sources of federal jurisdiction to hear criminal cases—both by removal and writs of habeas corpus. Background During the tenure of Chief Justice Salmon P. Chase, the fundamental structure of the federal criminal system—arising from the Judiciary Act of 1789—underwent several legislative modifications. According to Wiecek, "[i]n no comparable period of our nation's history have the federal courts, lower and Supreme, enjoyed as great an expansion of their jurisdiction as they did in the years of Reconstruction, 1863 to 1876." First, in 1866, Congress authorized the removal of criminal cases from state courts to federal courts in certain situations (known as "civil rights removal"). The act provided: That the district courts of the United States, within their respective districts, shall have . . . cognizance . . . , concurrently with the circuit courts of the United States, of all causes, civil and criminal, affecting persons who are denied or cannot enforce in the courts or the judicial tribunals of the State or locality where they may be any of the rights secured to them by the first section of this act; and if any suit or prosecution, civil or criminal, affecting persons who are denied or cannot enforce in the courts or the judicial tribunals of the State or locality where they may be any of the rights secured to them by the first section of this act . . . . Second, in 1867, Congress broadened the authority of the federal courts to hear habeas petitions, and authorized the Supreme Court to hear direct appeals from the adjudication of those petitions in the lower federal courts (as an alternative to original habeas). Most notably, the 1867 act extended the power of the federal courts to hear habeas petitions from state prisoners (although the Chase Court heard no such cases). Further, by explicitly providing for appeals from habeas petitions in lower federal courts, the act abrogated the Supreme Court's decision in Barry v. Mercein (1847), which held that such appeals could not be maintained as