“She Insists Her Mind is Balanced”: Habeas Corpus, Psychiatric Confinement, and the Legal Resistance of Immigrant Women Caroline Bauer and Anna Sultz, 1868-1906.

Location

Ponderosa Room D

Presentation Type

Presentation

Presentation Topic

Habeas Corpus, Immigrant Women, American Legal History, Psychiatric Institutions

Start Date

6-3-2026 10:10 AM

Event Sort Order

13

Abstract

Based on the findings of my senior capstone project, this presentation examines how two immigrant women, Caroline Bauer (1868) and Anna Sultz (1906) utilized habeas corpus to navigate and challenge their coercive confinement in psychiatric institutions by their husbands. Drawing on cases from Dr. Katrina Jagodinsky’s Petitioning for Freedom project, historic newspaper reports, and contemporary historian’s scholarship on psychiatry, asylums, gender, and immigration, this project argues that institutionalization was frequently used as a form of patriarchal control, rather than medical necessity. Despite facing restrictive gender norms, rising nativism, possible legitimate mental health struggles, and, in Anna Sultz’s case, a language barrier, both women successfully leveraged their legal knowledge and supportive immigrant communities to resist wrongful institutionalization. Their cases exemplify their legal agency, which contradicts the modern day characterization of who had legal agency during this time period. Their cases also reflect three larger patterns in the Petitioning for Freedom dataset: women were disproportionately successful in their habeas corpus challenges to psychiatric confinement, male family members frequently weaponized institutionalization for personal gain, and courts recognized that certain degrees of mental illness did not justify involuntary confinement. Caroline Bauer and Anna Sultz’s stories underscore the power of community, the complexity of immigrant women’s legal struggles, and the enduring need to revisit the histories of mental health, gender, and resistance.

Presenter Bio

Andy Knopik is a May 2025 graduate of the University of Nebraska Lincoln. They majored in Psychology and Women and Gender Studies, with minors in English and Sexuality Studies. During their undergraduate career, they worked under Dr. Katrina Jagodinsky in the Petitioning for Freedom lab, which focuses on the use of habeas corpus in nineteenth and twentieth century American history. Currently, Andy works for Nebraska Law in the office of Admissions, and hopes to pursue either graduate or law school. When Andy is not working, you can find them cooking, playing DND, or watching movies.

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Mar 6th, 10:10 AM Mar 6th, 11:00 AM

“She Insists Her Mind is Balanced”: Habeas Corpus, Psychiatric Confinement, and the Legal Resistance of Immigrant Women Caroline Bauer and Anna Sultz, 1868-1906.

Ponderosa Room D

Based on the findings of my senior capstone project, this presentation examines how two immigrant women, Caroline Bauer (1868) and Anna Sultz (1906) utilized habeas corpus to navigate and challenge their coercive confinement in psychiatric institutions by their husbands. Drawing on cases from Dr. Katrina Jagodinsky’s Petitioning for Freedom project, historic newspaper reports, and contemporary historian’s scholarship on psychiatry, asylums, gender, and immigration, this project argues that institutionalization was frequently used as a form of patriarchal control, rather than medical necessity. Despite facing restrictive gender norms, rising nativism, possible legitimate mental health struggles, and, in Anna Sultz’s case, a language barrier, both women successfully leveraged their legal knowledge and supportive immigrant communities to resist wrongful institutionalization. Their cases exemplify their legal agency, which contradicts the modern day characterization of who had legal agency during this time period. Their cases also reflect three larger patterns in the Petitioning for Freedom dataset: women were disproportionately successful in their habeas corpus challenges to psychiatric confinement, male family members frequently weaponized institutionalization for personal gain, and courts recognized that certain degrees of mental illness did not justify involuntary confinement. Caroline Bauer and Anna Sultz’s stories underscore the power of community, the complexity of immigrant women’s legal struggles, and the enduring need to revisit the histories of mental health, gender, and resistance.