that they would remain only as long as they received novices for their order. Their arrival marked the Ursuline order's first presence in the United States. When their desire for novices did not materialize, the nuns returned to Ireland three years after their arrival. Kohlmann also established an orphanage, which he placed under the care of Trappist nuns who had fled persecution in France. This institution was short-lived, as the Trappists left for Le Havre in October 1814. Seal of the confessional In 1813, Kohlmann became the subject of a lawsuit that rose to the national interest. A New York City merchant, James Keating, accused a man named Phillips and Phillips' wife of stealing goods from him. The police prosecuted the two accused, but before the trial could be brought to a close, Keating declared that he had been paid restitution, with Kohlmann acting as an intermediary in the transaction. The New York County District Attorney subpoenaed Kohlmann to provide the name of the thief who paid the restitution, but Kohlmann refused to reveal his identity, stating that it had been disclosed to him during the Sacrament of Penance and was therefore protected under canon law by the seal of the confessional. In response to the district attorney's demand that he disclose the thief, Kohlmann stated that he would suffer imprisonment or death before violating the seal. Kohlmann was brought before the Court of General Sessions to compel him to provide the identity of the thief. He was represented by two Protestant defense attorneys: Richard Riker and William Sampson. The four judges, DeWitt Clinton, Josiah Ogden Hoffman, Richard Cunnin, and Isaac Douglas, ruled in favor of Kohlmann, citing religious liberty as the basis of their decision. Speaking for a unanimous court, DeWitt Clinton wrote: The court's decision represented the first legal recognition of the confessional privilege in the United States. As a result, the New York State Legislature passed a law on December 10, 1828, codifying the confessional privilege: that when clergy members come to know of facts through their ministerial capacity and their denomination imposes a requirement of secrecy, they cannot be compelled to reveal those facts. Kohlmann also wrote a book directed at non-Catholics, explaining the Catholic doctrine on the Sacrament of Penance. Maryland and Washington, D.C. Upon his arrival in Maryland in 1815, Kohlmann was made the master of novices at the novitiate at White Marsh Manor.