"Starkie, McNally, and Roscoe, the leading authorities upon the law of criminal evidence in 1850" and notes that they "made it quite clear that the fact of the corpus delicti, or the commission of the homicide, had to be proven by direct evidence to an absolute certainty, or beyond the least doubt. After this had been established absolutely, then the burden of proof was on the prosecution to show that the defendant had committed the crime beyond a reasonable doubt." "In his charge, however," Sullivan notes that "Shaw set a new standard for the degree of proof required to show the commission of the homicide. He stated that the corpus delicti was to be proved "beyond a reasonable doubt" only, and then the guilt of the accused "beyond a reasonable doubt" also. He further instructed the jury that the corpus delicti could be established beyond a reasonable doubt by circumstantial evidence alone." The case against Webster was one of the first capital cases to be won by the prosecution without absolute evidence that the victim had been murdered. Other noted cases The trial of anti-Catholic rioters who destroyed the Ursuline convent in Charlestown in Commonwealth v. Buzzell (1834). In Farwell v. Boston & Worcester Railroad Corp. (1842), Shaw created the "fellow servant" rule, using contract rationale to prevent a railroad laborer from recovering from his employer. Shaw held that the laborer was at liberty to prevent his injury and for the corporation to insure against it would create a moral hazard problem. The decision empowered both the railroad industry and the insurance industry, which now had a market for insuring against workplace injuries. In Commonwealth v. Hunt (1842), Shaw provided an important precedent in labor relations by arguing that members of labor unions were not engaging in criminal conspiracies against their employers. In Cary v. Daniels, 8 Metcalf (1844), Shaw created an important legal precedent in Massachusetts regarding the regulation of water power rights belonging to riparian proprietors. In Cobb v. Cobb (1847), Shaw presided over the unsuccessful divorce case of Henry Cobb against his wife Augusta Adams Cobb, for joining the Mormons and eventually marrying Brigham Young in a polygamous marriage. In Commonwealth v. Goode (1849), Shaw presided over the trial of Washington Goode, a black seaman convicted and executed on circumstantial evidence of murdering a fellow black mariner. In Brown v. Kendall (1850), Shaw established negligence as the