Plowden states a case that if a woman is warden of a prison and marries one of the prisoners, the prisoner has escaped and is at large; for he cannot be lawfully imprisoned but under a keeper, and he cannot be under the custody of his wife, she having no separate legal existence. Therefore the law necessarily adjudges him to be at large.

— H.C. Shurtleff, “The Grotesque in Law,” American Law Review, January-February 1920