Under orders from Major General Burnside, Representative Clement L. Vallandigham (D-Ohio), was arrested for violating Burnside’s General Order No. 38 by uttering “disloyal sentiments” and hindering the government’s prosecution of the war after giving an anti-war speech at Mount Vernon, Ohio, on May 1, 1863. Convicted by a military tribunal, Vallandigham was sentenced to prison for the duration of the war. Although President Lincoln commuted the congressman’s sentence to banishment behind Confederate lines, Vallandigham petitioned the U.S. Supreme Court, unsuccessfully, to have his conviction overturned on appeal. In 1866, the use of military tribunals to try civilians in the United States would be limited by a Supreme Court decision in Ex parte Milligan.