sought Garfield's support), and other candidates fell by the wayside. The General Assembly elected Garfield to the Senate in January 1880, though his term was not scheduled to commence until March 4, 1881. Garfield was never seated in the U.S. Senate. Legal career and other activities In 1865, Garfield became a partner in the law firm of a fellow Disciple of Christ, Jeremiah Black. They had much in common, except politics: Black was an avid Democrat, having served in the cabinet of President James Buchanan. The next year, Black was retained by some pro-Confederate northern civilians who had been found guilty of treason in a military court and sentenced to death. Black saw an opportunity to strike a blow against military courts and the Republicans. He had heard Garfield's military speeches, and learned of not only his oratory skills but also his resistance to expansive powers of military commissions. Black assigned the case to Garfield one week before arguments were to be made before the U. S. Supreme Court. When Black warned him of the political peril, Garfield responded, "It don't make any difference. I believe in English liberty and English law." In this landmark case, Ex parte Milligan, Garfield successfully argued that civilians could not be tried before military tribunals, despite a declaration of martial law, as long as civil courts were still operating. In his very first court appearance, Garfield's oral argument lasted over two hours, and though his wealthy clients refused to pay him, he had established himself as a preeminent lawyer. During Grant's first term, Garfield was discontented with public service and in 1872 again pursued opportunities in the law. But he declined a partnership offer from a Cleveland law firm when told his prospective partner was of "intemperate and licentious" reputation. In 1873, after Chase's death, Garfield appealed to Grant to appoint Justice Noah H. Swayne Chief Justice, but Grant appointed Morrison R. Waite. In 1871, Garfield traveled to Montana Territory to negotiate the removal of the Bitterroot Salish tribe to the Flathead Indian Reservation. Having been told that the people would happily move, Garfield expected an easy task. Instead, he found the Salish determined to stay in their Bitterroot Valley homeland. His attempts to coerce Chief Charlo to sign the agreement nearly brought about a military clash. In the end, he convinced two subchiefs to sign and move to the reservation with a few