persons and deserters, and that he could not enforce conscription. At least 2,672 civilians were subject to military arrest in the Confederacy over the course of its history, although this is likely an undercount given the incompleteness of records. Civil War historian Mark E. Neely Jr. suggests that "there seems to be no difference in the arrest rate in those periods when the Confederate Congress refuse to authorization suspension of the writ of habeas corpus and those periods was authorized. ... civilian prisoners trickled into Confederate military prisons whether the writ of habeas corpus was suspended or not." The last suspension lapsed in August 1864, amid deep domestic opposition to the suspension, including from the Confederate vice president Alexander H. Stephens, Davis's political rival. Citing "discontent, disaffection, and disloyalty", Davis made entreaties in late 1864 and 1865 about the necessity of suspension, but bills to further suspend habeas corpus failed in the Confederate Senate. Suspension during Reconstruction Following the end of the Civil War, numerous groups arose in the South to oppose Reconstruction, including the Ku Klux Klan. In response, Congress passed the Enforcement Acts in 1870–71. One of these, the Civil Rights Act of 1871, permitted the president to suspend habeas corpus if conspiracies against federal authority were so violent that they could not be checked by ordinary means. That same year, President Ulysses S. Grant suspended the writ of habeas corpus in nine South Carolina counties; the Act's sunset clause ended that suspension with the close of the next regular session of Congress. Suspension in the Philippines In response to continuing unrest, the Philippine Commission availed itself of an option in the Philippine Organic Act of 1902, , and on January 31, 1905, requested that Governor-General Luke Edward Wright suspend the writ of habeas corpus. He did so the same day, and habeas corpus was suspended until he revoked his proclamation on October 15, 1905. The suspension gave rise to the United States Supreme Court case Fisher v. Baker, . Habeas corpus during World War II Immediately following the attack on Pearl Harbor, the governor of Hawaii Territory, Joseph Poindexter, at the specific request by Lieutenant General Walter Short, US Army, invoked the Hawaiian Organic Act, (1900), suspended habeas corpus, and declared martial law. Short was recalled to Washington, D.C. two weeks after the attack and subsequently Hawaii was governed by US Army Lieutenant Generals Delos Emmons and