the case after the war ended. In Ex parte Milligan (1866), the U.S. Supreme Court decided that Congress's 1863 suspension of the writ did not empower the President to try to convict citizens before military tribunals where the civil courts were open and operational. This was one of the key Supreme Court Cases of the American Civil War that dealt with wartime civil liberties and martial law. In the Confederacy In the Confederacy, Jefferson Davis also suspended habeas corpus and imposed martial law. Shortly after his inauguration as president of the Confederacy, an act of the Confederate Congress of February 27, 1862, was passed authorizing Davis to suspend the writ of habeas corpus and declare martial law "in such towns, cities, and military districts as shall, in his judgment, be in such danger of attack by the enemy". The Confederate Congress passed a limiting act two months to restrict the suspension of the writ "to arrests made by the authorities of the Confederate Government, or for offences against the same" and to add a sunset clause providing that authorization to suspend habeas corpus would expire 30 days after the next meeting of Congress. In various proclamations and orders beginning in 1862, Davis suspended the writ and declared martial law in parts of Virginia (including the Confederate capital of Richmond, Norfolk, Portsmouth, Petersburg, and elsewhere). Davis also suspended the writ in East Tennessee; in this region, Thomas A.R. Nelson was arrested by the Confederate military and held as a political prisoner before being released on the condition that he cease criticizing the Confederate government. Suspensions of civil process in the confederacy were used against suspected Unionists, particularly in border states. Historian Barton A. Myers notes that after the Confederacy imposed nationwide conscription, "the difference between arrest for political dissidence and conscription into the military became largely semantic, as anyone accused of Unionism was almost always first taken to a training camp where they were monitored and hazed under guard." Davis also suspended the writ in North Carolina (June 1862) and in Atlanta (in September 1862). The Confederate Congress passed re-authorizing legislation twice more, in October 1862 and February 1864. Davis suspended habeas corpus in Arkansas and the Indian Territory in January 1863. Although Davis had initially been resistant to the idea, he suspended the writ after receiving a telegram from General Theophilus Holmes complaining that his region was filed with disloyal