Turning Workers into Criminals: Gender, Class, and State Violence in the Twin Cities’ Responses to Sex Work, 1870-1900

By Duncan Riley



What Makes Someone a Criminal?

Modern society tends to view criminality as a product of immorality. If someone commits a crime, it is because they are a bad and antisocial person. However, the relationship between law and morality is in reality far more complicated. When John Brown and his party of White and Black supporters attempted to seize the Federal Armory at Harpers Ferry and ignite a general revolt against slavery, their actions were illegal. Meanwhile, slavery itself was perfectly legal, and defended by the state and its monopoly on violence. Equally, today the most odious policies of our government here in the United States, whether mass deportations, family separation, or the roll-back of reproductive rights, among others, are carried out under the protection of legality (or, at least, without legal consequences) and with the active participation and collaboration of all branches of government. Thus, even as the state commits widespread abuses of human rights on a massive scale, its actions are still regarded, broadly, as legal. On the other hand, hundreds of thousands of people, particularly Black and Brown people, face arrest and incarceration for nonviolent drug crimes, petty thefts, and crossing borders in order to look for work or reunite with their families. Thus, considering that the worst and most horrific violence in our society, the violence of the state, goes unpunished, while millions of poor people are locked up for nonviolent crimes, it is time that we recognize that it is not immorality that makes someone a criminal, but rather a legal system more interested in defending the social order and property than justice.

One area where this lesson has long been apparent has been in the response of political and legal authorities to sex work. Ever since the 19th century, moralists, politicians, and lawyers have sought to put and end to sex work through increasingly more draconian penalties, frequent police raids, and endless sermons denouncing female “immorality.” One key case demonstrating this trend is the postbellum Twin Cities in Minnesota. In the initial decades after the Civil War, the Twin Cities’ authorities attempted merely to regulate prostitution, controlling it through fines and arrests, but not abolishing it. But, towards the end of the 1880s and 90s, city officials, particularly in Minneapolis, came under increasing pressure from reformers to mount an aggressive campaign to “abolish” sex work. This campaign, despite claims that it would “save” and “reform” women, ultimately would end in turning sex workers, and working class women generally, into criminals under the law, resulting not only in the arrest and incarceration of a great number of women, but also reinforcing patriarchal gender norms and hierarchies both on the individual and societal levels.

Before we begin, a brief note on terminology. This study will generally prefer the terms sex work and sex workers to prostitute and prostitution, due to the moralistic and oft-times discriminatory overtones of the later terms. However, while the modern term sex worker refers to a wide variety of occupations, in the context of the study it simply refers to women who, either in brothels or independently, received payment for sex. At times, the terms prostitute and common prostitute will also be used, the latter because it was a specific legal category in the time period, and the former because the term prostitute in the 19th century did not just encompass payment for sex but also a wide variety of activities that broke with traditional female gender roles.

Gender Oppression, Class Divides, and the Laws that Maintained Them

As the Twin Cities grew after the Civil War, city officials initially focused on regulating rather than eliminating sex work. In St. Paul, common practice was to arrest madams every month and force them to pay a fine, in what effectively amounted to an informal tax granting a “one-month license to manage a brothel.”[1] In Minneapolis, similar practices seemed to prevail. An 1877 City Ordinance mandated a maximum $100 dollar fine or 90-day jail term for operating a “house of ill repute.”[2] Under this ordinance the police and courts were thus able to compel brothel owners to pay into the city coffers. For example, in July 1883 both Claude Adams and Sarah Weeks were compelled to pay $50 fines, while   Edna Leon was summoned in August 1884 to pay a $100 dollar fine to the city.”[3] Furthermore, a later article in the Tribune would allege that widespread informal collection of fines and fees from sex workers in the city was common, claiming that “each house of ill repute pays $50 a month [to the city],” eventually receiving a “license” to facilitate its operations.[4] In both cities, the system of fines put into place thus served to control sex work through the regular intervention of the courts into the operation of brothels, without actually shutting them down and driving them underground.[5]

It is important to note, however, that the Twin Cities’ regulatory policies were not only aimed at madams, but also targeted the sex workers themselves. The aforementioned 1877 ordinance also made it a crime to simply live or be found in an “house of ill fame,” putting sex workers at constant risk of arrest.[6] As such, police raids often resulted in sex workers and anyone else lodging in a “house of ill repute,” themselves being fined by the cities, though generally for smaller amounts than the madams were subject to. Indeed, an 1883 raid in Minneapolis would net $70 dollars in fines from seven women for “occupying apartments in a house of ill fame,” while an 1887 raid in St. Paul would collect $60 dollars in fines.[7] Sex workers could also be arrested on the charge of being a “common prostitute,” which in St. Paul usually carried with it a fine of $20.[8] Thus, the Twin Cities’ efforts to control prostitution throughout the 1870s and 80s did not only entail the informal taxing of madams, but also a general criminalization of sex work, subjecting sex workers to arrests and fines, and consequently granting the police and courts broad power over sex workers’ daily lives.

Indeed, hardly any aspect of sex workers’ lives went untouched by the law, as they were even prevented from attaining their fundamental needs. The same 1887 ordinance that made it a crime to live in a “house of ill repute,” also made it illegal to rent or sell any house or room to a “common prostitute,” consequently making it extremely difficult for sex workers to find stable housing.[9] Considering that the ordinance simultaneously denied sex workers independent access to housing while also making it a criminal offense to find lodging in a brothel, one must conclude that, at least to a certain extent, the ordinance must have been intended to force sex workers into illegal living arrangements in brothels, where it would be easier for police to monitor and arrest them. St. Paul equally sought to criminalize sex workers’ quotidian existence, an 1884 ordinance making it an offence punishable by a $10-$100 dollar fine for a common prostitute to enter a public park.[10] Considering the ways in which municipal law in the Twin Cities criminalized their basic needs like housing alongside their mere existence in public spaces such as parks, sex workers could not help but become criminals. Rather than being the result of any sort of inherent immorality on their part, the criminality of sex workers was the product of the legal authorities themselves, and their efforts to control and regulate sex work.

Thus, when the municipal governments of the Twin Cities’ sought to control sex work, this did not simply mean the de facto taxes imposed upon brothels, but also the use of ordinances to criminalize and exercise authority over sex workers as a social group. The various restrictions that the law placed upon those categorized as “common prostitutes,” had the cumulative effect of segregating sex workers from the rest of society, resulting in their isolation from the larger working class. From the standpoint of the Cities’ authorities, this segregation of sex workers within the city served two important purposes, firstly by ensuring that sex work remained in certain areas and thus its supposed immorality would not infect the rest of the Cities, and secondly because it made it far easier for the police to control sex work if it was confined to certain, specific “vice districts” of the cities.[11] For the sex workers, this meant that they could be subject to arrest at almost any time, and thus faced the constant danger of state repression and incarceration, giving city functionaries a far greater degree of power over them than they held over the rest of the city’s working class. For the cities’ governments, criminalization was therefore an extremely powerful tool in their effort to expand their authority over not just institutions, but people, that were seen as immoral.

The criminalization of sex work must be understood within a broader context of the application of law by political and legal authorities to enforce feminine gender norms and punish behavior that violated them, in particular targeting working class women. Behaviors or actions that violated what the powerful in society perceived as “acceptable” female behavior were penalized and could result in arrest and incarceration. Sex work itself was a key example of this process, as for a woman to engage in intercourse outside of wedlock, or to have multiple sexual partners, ran directly against Victorian society’s emphasis on what was seen as women’s innate “innocence and purity.”[12] As a result, sex workers were particularly singled out as targets for arrest and incarceration by the legal system.

However, aside from sex work, a wide variety of behaviors that flouted contemporary female gender norms were subject to criminalization. When, in 1887, Lizzie Bernholtz dressed in men’s clothes and attempted to join the circus, the police arrested her.[13] In another case about a month earlier, Annie Linstrom, described by the paper as a “strange creature,” was also arrested for “masquerading in male attire,” after a farmer complained to the police about her. Linstrom, who had been herding cattle when she was arrested, protested the charge, explaining that “I wear men’s clothes when herding so as to get around. If I wore women’s clothes I’d be bothered all the time. I never go on the streets without a dress, but I did this time, because the only dress I’ve got was in North Minneapolis.” The judge was unmoved by this appeal, and, recalling that she had been arrested once before for the same offense, stated “You must wear the garments of your sex or be punished. Your sentence is twenty days at the workhouse.”[14] Both these cases demonstrate that women’s transgressions of “acceptable” female behavior were viewed by the police and courts as criminal behavior which, if serious enough, merited incarceration. Further, Linstrom’s case in particular shows how working-class women could be extremely vulnerable to the repression that the Cities’ legal apparatus meted out to maintain female gender conformity. As a cattle herder, it was entirely impractical for her to wear a dress as she engaged in her work, and thus it was her very employment in physical labor which made her vulnerable to the accusations that she was breaking with traditional conceptions of femininity, ultimately leading to her arrest. Therefore, the efforts by the authorities of the Twin Cities to regulate gender roles through criminalization should be understood not only as a function of gender oppression, but as one of class oppression as well.

The usage of the law to delineate “correct” feminine behavior also resulted in women receiving far harsher sentences then men did for the same crimes. The year prior to her arrest for wearing men’s clothes, Linstrom had been arrested for reckless driving and received a sixty-day sentence in the workhouse.[15] On the other hand, when Charles Brown was arrested for the exact same crime that year, he was sentenced to pay a $3 fine.[16] Furthermore, when Tim McMahon was arrested for reckless driving, after causing a collision that hurt a young boy, he was sentenced to a fine of $11.60.[17] Thus, despite the fact that the charges facing Linstrom were no different from those facing the two men, only she was subject to incarceration, and for a significant period of time at that. Behind this disparate sentencing is the law’s dual purpose of both social and gender control. As Victoria Law notes, incarcerated women have broken “both laws and acceptable notions of feminine behavior and morality.”[18] Thus, in handing down such a harsh sentence on Linstrom, the courts were not only punishing her for her breach of the social order, but also for her breach of the social protocols that demanded docility from women. As such, in sentencing, as in all other aspects of the legal system, the need of the authorities to control and defend gender norms was far more important than any abstract notions of justice or equality.

The legal apparatuses of the Twin Cities as they emerged more fully in the post-Civil War era were thus instruments of repression directed not only against sex workers, but against any woman who did not adhere to notions of “respectable” feminine conduct. Thus it must be understood that the law, far from being a neutral expression of the public good, was rather the reflection of the desires of the men in power to defend their own and their class’s conception of morality and justice, imposed upon the women of the Twin Cities and defended by the armed force and coercive power of the police and courts. The law, thus, was a buttress of patriarchy, seeking to secure and ensure men’s rule over women in society. Equally, the law was a tool of class rule, as it was working class and poor women who would be most subject to criminalization under the efforts of the city governments to control behavior they viewed as unvirtuous. Considering this, we must understand the process of criminalization not simply as the making of something illegal, but also as the making of someone illegal.

The human costs of repression and incarceration, which have so often been obscured by societal and scholarly disinterest in, and indeed aversion to, those the state has labeled as criminals, cannot be forgotten. When Hannah Rack, a Swedish immigrant, was arrested a third time for drunkenness, she tried to hang herself in the city lockup.[19] The next day, the court, considering that she was a repeat offender, was unmoved by her situation, and sentenced her to thirty days in jail. Thus, while criminalization of women like Hannah Rack may have served the interests of city authorities in their quest to defend public morality, it came at the cost of forgetting their humanity.

The Reform Movement and the Escalation of Criminalization

Across the 1870s and 1880s the Twin Cities’ policies to simply regulate, and not eliminate, sex work met opposition from within the cities’ elite, sectors of which increasingly felt that any form of “vice” needed to be completely removed from the cities.[20] These upper and middle-class reformers, often led by clergy and supported by women’s reform groups, argued that “vice” was sinful, and thus that to merely regulate it rather than seeking to abolish it was immoral. In a similar vein, many reformers argued that regulatory policies violated the spirit of the law, which clearly stated that sex work in all its manifestations was illegal. It was also argued that regulation discriminated against women, as sex workers, rather than johns, were most subject to arrest.[21] One exposé of the system of regulated prostitution in Paris published by the Globe in 1887 clearly reflected the views of these reformers, criticizing the abuse and mistreatment women suffered at the hands of the “police des moeurs,” and warning other countries against any system of “legalized prostitution.”[22] Other articles of the period focused on the threat the system posed to the cities’ reputation, one piece in 1889 arguing that farmer’s would not send their sons to university as long as they were “situated in the very heart of a den of prostitution.”[23] Thus as the years drew on, the Twin Cities’ governments came under increasing pressure from the cities’ upper classes to change their focus away from the regulation of sex work and towards its elimination.

Another common argument amongst reformers for the complete prohibition of sex work was the assertion of the existence of a “white slave trade.” According to the theory, women were either tricked or coerced into sex work by “evil procurers,” madams or traffickers. From there, a woman would fall into vice and corrupt the young men around her, becoming a “sinister polluter.” However, while “the white slave trade” gave middle and upper-class reformers a powerful argument for prohibition, it had little to do with the reality of how and why women became sex workers.[24] In most cases, women were not coerced into sex work by “procurers,” but rather entered into it due to social and economic conditions. For example, abandonment by a lover, especially if a woman was pregnant or had children, often led her to sex work. Economic factors were also important, as the jobs available to working-class women, domestic service and needle trades, paid very poorly.[25] Indeed, when two hundred women went on strike at a clothing factory in Minneapolis, one of the strikers asked “How can girls live on such wages… and live and dress respectably… It is impossible. She must either go without clothing or board, or she must steal or get money in a way that I would blush to mention.”[26]  Furthermore, at times women themselves, when charged with prostitution, denied that they had been compelled. Jane Conwell, after being charged with prostitution by the court and urged by her mother to reform, refused to do so, saying that even if they sentenced her to the workhouse the moment she was released she would return to sex work.[27] Despite reformers’ assertions and their inability to believe that women were able to make independent economic choices, sex work was not the product of a “white slave trade,” but rather grew out of social conditions and the fact that women and their labor were treated unequally by capital.

Reformers also targeted the treatment of women by the legal system. In an 1886 conference on prison reform, Women’s Christian Temperance Union (WCTU) representatives condemned the abuse that women often suffered at the hands of male police and guards while incarcerated, arguing for the necessity of “prison matrons,” women to care for female prisoners in police stations and workhouses. The reformers, however, also displayed a deep strain of paternalism in their attitudes towards working class women, arguing that as girls emigrated to the cities from the country to find employment, they often found themselves unable to afford “to board in a decent place and dress as they were expected to. Then they drifted into wages of shame…”[28] Thus despite their concern for the treatment of women and girls by the prison system and society more generally, these reformers ultimately never challenged the underlying problem that lay at the heart of the issue, that the law, reflecting the patriarchal society that produced it, served as an instrument to criminalize any woman whose behavior did not conform to contemporary notions of moral feminine conduct. For the reformers, while those women who could not afford to act as they ought to and fell into “wages of shame” certainly did not deserve to be abused, they still had acted immorally, and thus incarceration and reformation under the guiding hand of the matron was still necessary. Indeed, much of the work reformers like the WCTU actually did within jails actually reinforced their role as institutions of gender control. For example, in the Minneapolis jail, the WCTU distributed schoolbooks and writing material to male prisoners, while women were given sewing, knitting, and crocheting tools and materials.[29] Thus while men were given educational opportunities, women were taught to be good wives, mothers, and homemakers, how to “reform,” and better meet societal expectations of their gender. As such though reformers may have sought to curb some of the worst abuses, they ultimately reinforced the broader efforts of the authorities to control women’s behavior.

Consequently, despite the concerns reformers had for the wellbeing of women and their pretensions of preventing discrimination and injustices, the question of reform was only ever to be discussed amongst the Twin Cities’ bourgeois. The women who would actually be affected by these policies, the “delinquents,” sex workers, and prisoners, were not consulted, their views or perspectives never considered. Thus, the Twin Cities’ influential elite, whether they defended the system of regulation or sought to put an end to “vice” once and for all, turned to the police and as such to the application of force and incarceration to address the problem of sex work.[30] In selecting the police as their tool, however, the cities’ reformers ensured that their goal of correcting the discrimination women suffered would be left unfulfilled. As has been noted above, the role of the police, and the legal system more generally as the enforcers of contemporary gender norms as they were expressed in law meant that empowering these institutions could only result in an even deeper and greater criminalization of women who did not adhere to those norms. Furthermore, the conceptions of morality that drove reformers’ desire to put an end to sex work were the same moral values that underlaid contemporary gender norms, and thus legal discrimination against women. The very women that reformers sought to help and “uplift,” would thus, through fines and incarceration, pay the price for the middle and upper classes’ vaunted reforms.

Indeed, despite reformers stated desire to protect women against discrimination and reform sex workers, their actual efforts at reform were generally motivated by moral and economic concerns and offered little aid to arrested or incarcerated women. In 1878, when a group of prominent citizens opposed to St. Paul’s regulation policies was organized by Reverend William McKibbin, its arguments generally focused on the immorality of the cities’ policies, not on concern for the wellbeing of sex workers.[31] When in 1881 a group of property owners in the wealthy neighborhood of Irvine Park organized a legal campaign against sex work, it was primarily out of a desire to push brothels away from their neighborhood and into other parts of the city.[32] In the most aggressive campaign, led by St. Paul Mayor Christopher O’Brien from 1883-1885, brothels were ordered closed and sex workers who refused to plead guilty to violating the city’s ordinances were charged with felonies, and if convicted, jailed. Meanwhile, men were simply prevented from entering brothels.[33] Thus, while reformers may have professed a desire to aid and uplift “fallen women,” the actual campaigns and policies they championed focused primarily on the moral castigation of women engaged in “vice,” and the defense of their economic interests. Furthermore, in the case of O’Brien’s campaigns against sex work, it would be the sex workers, not the abusive johns that reformers castigated, who would face arrest and incarceration. Thus, regardless of reformers’ intentions, the law, designed as it was to punish women for violating gender norms, would always fall most harshly upon the sex workers.

Though their reforms were only serving to escalate the criminalization of sex workers, this did not cause the reformers to reconsider their approach. On the contrary, in April 1889, Alderman Bradish of Minneapolis brought forward a new ordinance that would constitute the most aggressive anti-sex work measure that the city had seen thus far.[34] The “Bradish Ordinance,” which went into effect on the 16th of May 1889, defined a common prostitute as any female over the age ten that engaged in “concubinage” or “indiscriminate sexual intercourse with men, whether the same be for hire or not.” The new penalty for common prostitutes would be a fine not exceeding $100 dollars, or no more than ninety days in jail.[35] The new ordinance not only drastically increased the penalties for “common prostitutes,” it also defined the term in such a broad manner that any expression of female sexuality that transgressed contemporary social standards could be considered, and punished, as prostitution. This latest escalation in the trend towards making a criminal out of any woman who broke with patriarchal expectations of female behavior would lay the framework for the most aggressive police campaign against “delinquent” women that the city had seen up to that point.

The War on Sex Work

Sentences under the new ordinance generally became more severe. Indeed, less than a month after the ordinance’s passage, it was common to impose the maximum penalty on alleged common prostitutes.  In one of the first prosecutions under the new ordinance, Clara Hobart was sentenced to pay the maximum $100 dollar fine mandated by the ordinance or spend sixty days in the workhouse.[36] Two days later, Fannie Jones was fined the same amount.[37] Another common sentence initially was a $50 dollar fine or 60 days in the workhouse, falling upon both Hattle Armstrong and Nellie Whiby in the months that followed.[38] For reference, $100 dollars in 1889 would in today, 2019, be approximately equivalent to $2,790 dollars, and $50 to $1395.[39] The new ordinance also seems to have had an impact on how the courts sentenced women generally, regardless of whether they were charged with being a common prostitute. After Ella Brown was arrested in August 1893 for drunkenness, she was also sentenced to 90 days in the workhouse or a $100 dollar fine.[40] In only the first few months of its enforcement, the Bradish Ordinance had greatly increased the penalties not just for sex work, but for any woman who found herself before a judge.

While certainly many women would be incarcerated under the new ordinance, the stiffer penalties would also serve as a tool the courts could use to threaten women into behaving in a desired way. Mary Black, after being arrested as a common prostitute, had her sentence suspended so she could leave the city and rejoin her husband in the Dakotas.[41] Black therefore avoided a fine or jail sentence by rejoining her husband, and thus entering back into an accepted female gender role as a wife. Furthermore, the harsh sentences were at times also used to convince alleged sex workers to leave town. After Nellie Whitney was sentenced to sixty days in the workhouse, the sentence was suspended after she promised to leave town.[42] When women failed to keep to their promise, as Mary Dunn did, they were incarcerated.[43] Thus the Bradish Ordinance’s harsh penalties were leveraged by the court system to convince women to return to “correct behavior,” while also serving to drive unwanted practices, and, indeed, unwanted people, out of town.

Furthermore, despite the oft-stated concern of the reformers for the discrimination sex-workers and women suffered from the courts, facing significant penalties while the johns got off free, the new campaign in Minneapolis to end sex work would not change this. When Carrie Stratton was arrested for “being in a house of ill fame,” she was sentenced to thirty days in the workhouse. The two men also arrested received small fines.[44] Whatever the intentions of the reformers, the actual enforcement of their crusade against sex work made it abundantly clear that the courts, as institutions that were shaped by a patriarchal society to perpetuate itself and its notions of “correct” male and female sexual behavior, would always punish sex workers far more seriously than johns.

Accompanying the greater penalties were more aggressive police tactics targeting women suspected of being sex workers. Officers began to carry out sting operations, approaching women on the street and making “improper offers.” Mollie O’Donnell was arrested in one such case, and though she denied the charges, the court convicted her of being a common prostitute upon the testimony of the officer and sentenced her to the full ninety days.[45] In a similar case in November, Mary Glach, who worked as a washerwoman, was arrested for being a common prostitute after police claimed “they made a bargain with her.” Glach responded that the bargain had been for washing, not sex.[46] Considering that both women protested their innocence and argued that the police accounts of events were incorrect, the more aggressive tactics seem to have resulted in legally questionable arrests, and may not have even been targeting actual sex workers. Indeed, as the latter case shows, the sting operations seemed to have been targeting working-class women, regardless of whether or not there was any evidence beyond the officer’s perceptions that they were sex workers. In this way, the criminalization of women deemed by society as deviant, particularly working-class women, when combined with the new tactics greatly increased the police harassment women in Minneapolis would face.

The aggressive nature of the campaign to end sex work would also allow abusive conduct by police towards suspected sex workers to flourish. In 1890, after Sergeant Kirkham arrested Mary Niver and brought her before the court, Niver stated that while she previously had served time in the workhouse for being a common prostitute, she had since reformed and was innocent. Indeed, the judge found her innocent, as there was no evidence that she “had been plying her trade.”[47] Niver was arrested, not because there was any evidence, she had committed a crime, but because her personal history made her suspect to the police. Indeed, that the article still identifies sex work as “her trade” demonstrates that even after women had left sex work, they were still associated with it and could face arrest. A few weeks later. Kirkham arrested Mary O’Brien for being a common prostitute. Initially the judge, due to “Kirkham’s uncorroborated evidence,” declined to convict her, but more evidence was produced, and O’Brien was fined $50.[48] In a similar case several years later, Kirkham arrested Hattie French. French initially pleaded guilty, but later changed the plea to innocent, stating that Kirkham had advised her to plead guilty. Kirkham’s case, however, was saved, as Judge Mahoney declared she was “anything but a prude,” and sentenced her to a $50 dollar fine or sixty days in the workhouse.[49] In both of these cases, the evidence against the accused women was weak, and Kirkham’s conduct, especially in the French case was extremely questionable, trying to persuade her to plead guilty. However, Kirkham would suffer no consequences for this behavior, while O’Brien and French would have large fines or months in the workhouse. Furthermore, the fact that French was solely convicted on the basis of the judge’s prejudice that she was “anything but a prude” demonstrates once again that the effort to abolish sex work was in reality a wider campaign to punish, through arrest and imprisonment, any women who broke with the sexual norms that society placed upon her.

The Bradish Ordinance did not only serve to reinforce the authority of the law over women, but also helped husbands assert control over their wives, calling on the State and its repressive apparatus as an ally in familial disputes. When John Lavis came to Minneapolis looking for his wife, who had left him, he found her living in rooms rented from a man named Kelly. When she refused to come back to him, he swore out a warrant for her arrest as a common prostitute.[50] Rachel Davis was also accused of being a common prostitute by her husband, after she left him for a piano player. When brought before the court, she “preferred a fine, the workhouse, anything, in fact, to living with her husband.” She was sentenced to pay a $25 dollar fine, which, fortunately for her, the piano player paid.[51] In both these cases, husbands, having lost control of their wives, accused them of being prostitutes in order to have them arrested, using the courts to try and force their wives to accept their authority. Thus, the private, familial patriarchal control that husbands exercised over their wives was inseparable from the law’s broader role in regulating and controlling women’s behavior on a societal level, both oppressive dynamics mutually reinforcing each other. One result of these interlocking oppressions, one private and one public, was that women in abusive relationships found themselves being abused again by the state. In September 1896, Julia McKay testified in court that her husband abused her, but the judge ultimately dismissed the case after the defense brought forward evidence “to show the character of the plaintiff,” and that the couple was in the process of divorcing. Upon the dismissal of his charges, Fred McKay’s first action was to swear out a warrant for his wife’s arrest as a common prostitute.[52] Thus the violence of Mr. McKay was mirrored and compounded by the violence of the state.

The Bradish Ordinance also seems to have encouraged prosecutors to classify as common prostitutes women whose actions, while breaking with accepted feminine gender roles, had nothing whatsoever to do with sex work. After ten women were arraigned in court for vagrancy, the city attorney attempted to argue that they were, in fact, all common prostitutes. The judge, however, rejected the move, and the women were discharged.[53] A few years later, after Lizzie Gunderson was arrested for drunkenly stealing a carriage and going on a joy ride through the city, prosecutors attempted to charge her as a common prostitute. The gambit failed, and the judge released her, noting that there was no evidence she was a sex worker.[54] Despite the dismissal of charges in both cases, the prosecutors’ tendency to classify any women who had broken the law as a prostitute is another indication that the Bradish Ordinance was employed not just to end sex work, but to crack down on women who failed to conform to gender roles more generally. Whether the real crime committed was vagrancy, drunkenness, or theft, or indeed even if no crime had been committed at all, any woman who transgressed “respectable” boundaries could be accused of being a prostitute. Any hint of “immorality” on the part of a woman could thus be associated with sexual impropriety, shaming and dishonoring her in the eyes of respectable society.

Just like the police and courts, the jails themselves also served as institutions for controlling and “reforming” women, training them to behave in a manner more appropriate to contemporary gender norms. When the women’s wing to the Minneapolis workhouse was built on top of the old laundry building, besides holding spaces and washing rooms the only other place women could spend their time was a sewing room.[55] Thus, in the time they were incarcerated, women would spend their hours focused on the traditional and respectable feminine trade of the seamstress, and learn a skill necessary for wives and mothers. There were no opportunities to learn other, better-paying trades, which anyways were off-limits to women. “Reforming” women through incarceration thus, in reality, meant forcing them back into traditional gender roles.

It is important to note, however, that women were not simply passive victims of the violence that both husband and state used against them, they resisted and protested with the means available to them. Often times, this took the form of sudden bursts of protest in court against harsh sentences or unfair treatment. Alice Whittaker, when confronted by a witness in court who gave particularly controversial testimony, called out “You are a liar!”[56] In an earlier case, Carrie Keyes, who, after leaving her husband was accused by him of being a common prostitute, was sentenced to thirty days in the workhouse. In response she “broke out into a torrent of abuse,” and fought with her husband and the court officers, causing her sentence to be increased by another sixty days.[57] Both Whittaker and Keyes thus refused to passively accept their treatment by the courts. These acts of individual resistance, while seemingly small in comparison to the immense power and authority wielded by the state, demonstrated that the authorities could not count on women to easily accept their fates. As such, these small acts of protest and humanity were a powerful repudiation of the conventional conceptions of gender that tend to view women as docile and weak. However, as Keyes’s case shows, this repudiation could also come at a hard price, as in rebelling women had once again broken with expected feminine behavior, and thus could face harsher treatment at the hands of the courts.

The Bradish Ordinance, and the aggressive campaign to end sex work it provoked, thus had significant consequences for women in Minneapolis. Working-class women, suspected on account of their class of being sex workers, faced increased police harassment, while sex workers themselves faced greater fines and longer sentences to the workhouse. The campaign further quickly escalated, targeting not only suspected sex workers, but any woman who did not conform to the standards patriarchal society had placed upon her. Moreover, not only did the ordinance empower the state in its efforts to control women’s behavior, it also became a weapon in the hands of husbands who sought to reassert themselves over rebellious wives. Ultimately, despite reformers oft-stated belief that a vigorous campaign against sex work would save women, the real result of their efforts was that more and more women were arrested and incarcerated, while the hierarchies of gender and class that kept those well-meaning reformers at the top rung of Twin Cities’ society were more entrenched than ever.


The Twin Cities’ campaigns against sex work during the late 19th century demonstrate several important lessons which are relevant to our own times. First and foremost is that the state, alongside its police and courts, far from being a neutral or benignly beneficent institution dedicated to the public good, is rather, as an institution, identified with a particular social stratum, whose interests it serves to defend. In the case of the postbellum Twin Cities, the social strata that dominated city government and had the most influence on its policies towards sex work were the wealthy middle and upper classes, the professionals, the clergy, and businesspeople. Equally, it must be noted that in this social group, both among men and women, traditional notions of a woman’s “proper” role as first and foremost a wife and mother prevailed, alongside a general hostility and distrust towards female sexuality and a concern for female virtue. Indeed, as was noted above, even the politically active liberal reformers of the Women’s Christian Temperance Union, through their treatment both of sex workers and female prisoners, reinforced traditional patriarchal notions of women’s subservient place in society. While the Twin Cities’ bourgeois were certainly not uniform in their desired approach to sex work, split as they were between regulation and abolition, ultimately it was only their views that had any bearing on the cities’ policies. The working-class, and in particular working-class women, were not represented in the debate. The state, thus, is the creature of the privileged.

Today the state remains as much a tool of racial, class and gender oppression as it did in the 1890s. Since the advent of the War on Drugs, the number of women in prison has skyrocketed, growing by 108% between 1990 and 2000. These new prisoners primarily come from working class backgrounds, and Black and Latina women are in particular more likely to be incarcerated. This sudden and significant increase is not due to any increase in crime among women or in Black and Latina communities, but rather to aggressive police tactics, such as stop and frisk and increased patrols targeting these communities in an effort to “crack down on crime.” The more draconian sentencing and drug laws of the War on Drugs have also significantly contributed to the increasing numbers of incarcerated women.[58] Whether it is the Twin Cities’ war on prostitution in the 1890s or the contemporary nationwide War on Drugs, the state is always waging war on the poor.

The state’s subservience to the wealthier classes also tends to contradict the traditional notion that the character of institutions such as the police, courts, and prisons is dependent upon the character of the individuals that make them up – that if the police are good people they will behave justly, if prisons are run by good people they will serve the best interest of the prisoners and society, and so on. The reality however is that these institutions, having been created by the privileged and powerful to defend their interests, thus have at their core the same prejudices and hierarchies that characterize the rule of the dominant class. The injustices which the state’s repressive apparatus perpetrates daily against sex workers, women, immigrants, and so many others are not the product of the individual evil of those who make up that apparatus, but rather of the collective evil of the class that wields this apparatus in defense of its political, economic, and moral domination over society.[59] These abuses cannot be stopped, thus, simply by striving to put good or progressive people into positions of authority within these institutions and the state as a whole – they can only be stopped by abolishing the political and economic hierarchies and inequalities which gave rise to these institutions in the first place.

The lessons on power that the anti-sex work campaigns of the Twin Cities offer do not only help us outline what kind of society we need to fight for, but also how to fight for it. The quest of the Twin Cities’ liberal reformers to “abolish” sex work shows that abolition, in the final analysis, means granting new and broader powers to the state in order to arrest, prosecute, and incarcerate sex workers. Abolition, thus, seeks to empower not the sex workers themselves, but the state, an institution which develops from patriarchal society and serves to defend it. Considering this, it is not surprising that abolition campaigns like those of the Twin Cities ended in reinforcing, not diminishing, the control of men over women, both on the societal and individual levels. In our own times, sex workers themselves have been carving out a far more viable path towards social progress, as they unionize on an international level. Unions have been formed in 30 countries, and formal collective bargaining has occurred in four countries, including the US.[60] This move towards unionization rejects the intervention of the state, building the collective power of sex workers, and facilitating organized action and protest against both state repression and exploitative working conditions. By empowering the state, the oppressive dynamics we seek to destroy can only be reinforced, while when the oppressed empower themselves through their own self-activity and self-organization, they create a social base for the revolutionary transformation of society.

I am well aware that historians reading these conclusions may well feel that I have crossed the line which separates detached historical inquiry from political advocacy. This, of course, is entirely true, and, in my view, a necessary part of historical inquiry. If history is to remain a vital and relevant social science, its work must not be confined to universities and lecture halls, and solely published in expensive academic journals. Rather, historical study must be directly relevant to current social struggles, as much an arm of the oppressed as the pamphlet, the strike, and the rifle. Indeed, through historical study we can understand how the institutions and systems that underlie oppression today were formed and developed, helping us, eventually, to dismantle them. Equally, historical research can serve to rescue past social struggles from obscurity, giving us both new lessons and examples, thus deepening our understanding of the full depth of the historical task which today confronts us. That task, put most simply, is to reject the hierarchies, inequalities, and injustices which for centuries have hung over human society like a thick haze, and build a new society, where the seeds of liberty, equality, and solidarity can at long last blossom from a new, green earth.



Gender Oppression, Class Divides, and the Laws that Maintained Them  

[1] Joel Best, Controlling Vice: Regulating Brothel Prostitution in St. Paul, 1865-1883 (Columbus: Ohio State University Press, 1998), 3-4.

[2] Frank Healy, et al, Minneapolis City Charter and Ordinances. Court and Board Acts, Park Ordinances, Rules of City Council, etc (Minneapolis, MN, 1905), 874-75.

[3] “Municipal Courts.” The St. Paul Daily Globe. July 28, 1883, 6. The court cases are both listed in the section of the paper devoted to events in Minneapolis.

“Brief Mention.” The Minneapolis Daily Tribune. August 23, 1884, 8.

[4] “Truthful James.” The Minneapolis Tribune. December 19, 1886, 6.

[5] Best, Controlling Vice, 5.

[6] Frank Healy, et al, Minneapolis City Charter and Ordinance, 875.  

[7] “Municipal Courts.” The St. Paul Daily Globe. July 28, 1883, 6.

“Police Notes.” The Minneapolis Tribune. November 1, 1887, 3. Interestingly the St. Paul raid the paper details seems to have also picked up two men, though the exact circumstances of the arrests are unfortunately not made clear.

[8] “A Disreputable Woman.” The St. Paul Daily Globe. October 19, 1878, 4.

[9] Frank Healy, et al, Minneapolis City Charter and Ordinance, 875.

[10] William Pitt Murray, The Municipal Code of Saint Paul: Comprising the Laws of the State of Minnesota Relating to the City of Saint Paul, and the Ordinances of the Common Council; Rev. to December 1, 1884, by W.P. Murray, (St. Paul: Daily Globe, 1884), 352.

[11] Best, Controlling Vice, 5.

12] Best, Controlling Vice, 43.

[13] “A Naughty Girl.” The Minneapolis Tribune. August 15, 1887, 5.

[14] “A Girl Cowboy.” St. Paul Daily Globe. July 2, 1887, 3.

[15] “Minneapolis Globules.” St. Paul Daily Globe. December 19, 1886, 7.

[16] “Minneapolis Globules.” St. Paul Daily Globe. April 30, 1886, 3.

[17] “Notes About Town.” St. Paul Daily Globe. July 15, 1886, 2.

[18] Victoria Law, Resistance Behind Bars: The Struggles of Incarcerated Women, (Oakland: PM Press, 2012), 9.

[19] “Minneapolis Globelets.” St. Paul Daily Globe. August 23, 1884, 5. It should be noted however that Linnie Carlson, who was also arrested with Rack on charges of drunkenness, was released as it was her first offense and she had two children no one else could care for. Thus, while the courts had little compassion for women like Rack, who had broken both laws and gender norms multiple times, they could be far more sympathetic to first-time offenders who adhered more closely to traditional gender roles, mothers and wives for example.

The Reform Movement and the Escalation of Criminalization

[20] Best, Controlling Vice, 15-16; 79-80.

[21] Best, Controlling Vice, 15-16; 79-80.

[22] Emilie de Morsier, “Vice Thrives in Paris.” St. Paul Daily Globe. July 17, 1887, 20.

[23] “Conspicuous Imbecility.” The Minneapolis Tribune. May 2, 1889, 4.

[24] Best, Controlling Vice, 42.

[25] Ibid., 44.

[26] “Out on Strike.” The Minneapolis Tribune. April 19, 1888, 5.

[27] “In the Courts.” The Minneapolis Tribune, October 3, 1889, 8.

[28] “Adjourned Sine Die.” St. Paul Daily Globe. July 22, 1886, 8.

[29] Report of the Annual Convention, (Vol. 10. Red Wing, MN: Red Wing Printing, 1886), 39.

[30] Best, Controlling Vice, 18.

[31] Best, Controlling Vice, 90-91.

[32] Ibid., 93.

[33] Ibid., 94-5.

[34] “The Routine of the Council.” The Minneapolis Tribune. April 20, 1889, 5.

[35] Frank Healy, et al, Minneapolis City Charter and Ordinance, 876.  

The War on Sex Work

[36] “Briefly Mentioned.” The Minneapolis Tribune. June 7, 1889, 5.

[37] “In General.” The Minneapolis Tribune. June 9, 1889, 5.

[38] “Municipal Court.” The Minneapolis Tribune, July 10, 1889, 7.

“Municipal Court.” The Minneapolis Tribune, August 18, 1889, 14.

[39] “Inflation Rate between 1889-2019: Inflation Calculator.” CPI Inflation Calculator.

[40] “Municipal Court.” The Minneapolis Tribune, August 23, 1889, 8.

[41] “In the Municipal Court.” The Minneapolis Tribune, November 24, 1889, 9.

[42] “Minneapolis Globules.” St. Paul Daily Globe, July 10, 1889, 3.

[43] “A Tough Place Pulled.” The Minneapolis Tribune, August 30, 1889, 8.

[44] “Police Court Notes.” The Minneapolis Tribune, July 13, 1889, 7.

[45] “Monday in Police Court.” The Minneapolis Tribune. June 25, 1889, 8.

[46] “Municipal Court Briefs.” The Minneapolis Tribune, November 22, 1889, 8.

[47] “Bound for Stillwater.” St. Paul Daily Globe, June 8, 1890, 10.

[48] “Police Court Notes.” St. Paul Daily Globe, June 24, 1890, 3.

[49] “He Was Not ‘Roasted.’” St. Paul Daily Globe, March 17, 1893, 3. This article, along with the prior two, is drawn from the section of the paper devoted to events in Minneapolis.

[50] “Lavis and His Wife.” St. Paul Daily Globe, April 6, 1894, 3.

[51] “Minneapolis Globules.” St. Paul Daily Globe, April 7, 1894, 7.

[52] “The M’Kays Again.” The Minneapolis Tribune, September 25, 1896, 8.

[53] “Minneapolis Globules.” St. Paul Daily Globe, March 16, 1894, 3.

[54] “Gave Her Freedom.” The Minneapolis Tribune, September 24, 1896, 10.

[55] “At the Workhouse.” St. Paul Daily Globe, June 24, 1890, 3.

[56] “From the Police Station.” The Minneapolis Tribune, February 27, 1894, 4.

[57] “Oh Woman, Woman.” The Minneapolis Tribune, April 30, 1891, 5.


[58] Law, Resistance Behind Bars, 1-3.

[59]For example, restrictive immigration policies tend to serve the interests of corporations and business owners, allowing them to respond to any attempt to organize for better pay and conditions with the threat of deportation, one example of this being the raids in Jackson, Mississippi in August 2019.

[60] Gregor Gall, “Sex Worker Unions Are Reforming Their Industry,” (The Conversation, May 12, 2016).


“A Disreputable Woman.” The St. Paul Daily Globe. October 19, 1878. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1DFIPZ57%2F78101901&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=a6f12c32-b222-4a1c-8e2f 3720733ff4f3&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=4&submit.y=9&page_name=&page_name=.

“Adjourned Sine Die.” St. Paul Daily Globe, July 22, 1886. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031/1HMADE58/86072201&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=m. a. warner&sort_col=relevance&highlightColor=yellow&color=&cnt=36&CurSearchNum=5&search_doc1=m. a. warner&submit.x=0&submit.y=0&page_name=&page_name=.

“A Girl Cowboy.” St. Paul Daily Globe. July 2, 1887. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE58%2F87070201&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=cowboy&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=7&search_doc1=cowboy&submit.x=11&submit.y=8&page_name=&page_name=.

“A Naughty Girl.” The Minneapolis Tribune. August 15, 1887. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F87081501&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa 8705a70f68f8&zoom_factor=current&search_doc=lizzie&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=10&search_doc1=lizzie&submit.x=16&submit.y=7&page_name=&page_name=.

“A Tough Place Pulled.” The Minneapolis Tribune, August 30, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89083001&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=suspended&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=suspended&submit.x=16&submit.y=5&page_name=&page_name=.

“At the Workhouse.” St. Paul Daily Globe, June 24, 1890. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE59%2F90062401&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=14&submit.y=10&page_name=&page_name=.

Best, Joel. Controlling Vice: Regulating Brothel Prostitution in St. Paul, 1865-1883. Columbus: Ohio State University Press, 1998.

“Bound for Stillwater.” St. Paul Daily Globe, June 8, 1890. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE59%2F90060801&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=8&submit.y=13&page_name=&page_name=.

“Brief Mention.” The Minneapolis Daily Tribune. August 23, 1884. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005/1DFC5E58/84082301&query1=&recoffset=0&collection_filter=All&collection_name=dec3f287-fb75-46e6-8db0-ac54e9e47662&sort_col=relevance&cnt=5&CurSearchNum=0&recOffset=0.

“Briefly Mentioned.” The Minneapolis Tribune. June 7, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89060701&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=5&search_doc1=prostitute&submit.x=12&submit.y=8&page_name=&page_name=.

“Conspicuous Imbecility.” The Minneapolis Tribune. May 2, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89050201&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitution&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=prostitution&submit.x=4&submit.y=11&page_name=&page_name=.

de Morsier, Emilie. “Vice Thrives in Paris.” St. Paul Daily Globe. July 17, 1887. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE58%2F87071701&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=paris&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=8&search_doc1=paris&submit.x=0&submit.y=0&page_name=&page_name=.

“From the Police Station.” The Minneapolis Tribune, February 27, 1894. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F59%2F94022701&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=prostitute&submit.x=10&submit.y=14&page_name=&page_name=.

Gall, Gregor. “Sex Worker Unions Are Reforming Their Industry.” The Conversation, May 12, 2016. http://theconversation.com/sex-worker-unions-are-reforming-their-industry-58541.

“Gave Her Freedom.” The Minneapolis Tribune, September 24, 1896. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F59%2F96092401&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=11&submit.y=8&page_name=&page_name=.

Healy, Frank, L. Lydiard, William H. Morse, and Henry N. Knott. Minneapolis City Charter and Ordinances. Court and Board Acts, Park Ordinances, Rules of City Council, Etc. Minneapolis, MN, 1905.

“He Was Not ‘Roasted.’” St. Paul Daily Globe, March 17, 1893. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE59%2F93031701&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=french&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=7&search_doc1=french&submit.x=3&submit.y=12&page_name=&page_name=.

“Inflation Rate between 1889-2019: Inflation Calculator.” CPI Inflation Calculator. Accessed October 22, 2019. http://www.in2013dollars.com/us/inflation/1889?amount=100.

“In General.” The Minneapolis Tribune. June 9, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005/1DFC5F58/89060901&query1=&recoffset=0&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&sort_col=relevance&cnt=8&CurSearchNum=7&recOffset=0.

“In the Courts.” The Minneapolis Tribune, October 3, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89100301&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=prostitute&submit.x=12&submit.y=7&page_name=&page_name=.

“In the Municipal Court.” The Minneapolis Tribune, November 24, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89112401&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=7&submit.y=4&page_name=&page_name=.

“Lavis and His Wife.” St. Paul Daily Globe, April 6, 1894. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE59%2F94040601&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=4&submit.y=5&page_name=&page_name=.

Law, Victoria. Resistance Behind Bars: The Struggles of Incarcerated Women. Oakland: PM Press, 2012.

“Minneapolis Globelets.” St. Paul Daily Globe. August 23, 1884. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031/1HMADE58/84082301&query1=&recoffset=0&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&sort_col=relevance&cnt=0&CurSearchNum=1&recOffset=0.

“Minneapolis Globules.” St. Paul Daily Globe. April 30, 1886. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031/1HMADE58/86043001&query1=&recoffset=0&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&sort_col=relevance&cnt=13&CurSearchNum=3&recOffset=0.

“Minneapolis Globules.” St. Paul Daily Globe. December 19, 1886. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031/1HMADE58/86121901&query1=&recoffset=0&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&sort_col=relevance&cnt=2&CurSearchNum=1&recOffset=0.

“Minneapolis Globules.” St. Paul Daily Globe, April 7, 1894. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE59%2F94040701&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=6&search_doc1=common prostitute&submit.x=0&submit.y=0&page_name=&page_name=.

“Minneapolis Globules.” St. Paul Daily Globe, July 10, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE58%2F89071001&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=7&search_doc1=common prostitute&submit.x=8&submit.y=4&page_name=&page_name=.

“Minneapolis Globules.” St. Paul Daily Globe, March 16, 1894. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%252F1HMADE59%252F94031601&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%2520prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common+prostitute&submit.x=13&submit.y=6&page_name=&page_name=

“Monday in Police Court.” The Minneapolis Tribune. June 25, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89062501&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=prostitute&submit.x=11&submit.y=13&page_name=&page_name=.

“Municipal Courts.” The St. Paul Daily Globe. July 28, 1883. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031/1DFIPZ58/83072801&query1=&recoffset=0&collection_filter=All&collection_name=a6f12c32-b222-4a1c-8e2f-3720733ff4f3&sort_col=relevance&cnt=4&CurSearchNum=3&recOffset=0.

“Municipal Court.” The Minneapolis Tribune, July 10, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005/1DFC5F58/89071001&query1=&recoffset=0&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&sort_col=relevance&cnt=10&CurSearchNum=7&recOffset=0.

“Municipal Court.” The Minneapolis Tribune, August 18, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005/1DFC5F58/89081801&query1=&recoffset=0&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&sort_col=relevance&cnt=0&CurSearchNum=6&recOffset=0.

“Municipal Court.” The Minneapolis Tribune, August 23, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89082301&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=%20brown&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=5&search_doc1= brown&submit.x=20&submit.y=11&page_name=&page_name=.

“Municipal Court Briefs.” The Minneapolis Tribune, November 22, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89112201&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitute&sort_col=relevance&highlightColor=yellow&color=&cnt=9&CurSearchNum=3&search_doc1=prostitute&submit.x=8&submit.y=10&page_name=&page_name=.

Murray, William Pitt. The Municipal Code of Saint Paul: Comprising the Laws of the State of Minnesota Relating to the City of Saint Paul, and the Ordinances of the Common Council; Rev. to December 1, 1884, by W.P. Murray. St. Paul: Daily Globe, 1884.

“Notes About Town.” St. Paul Daily Globe. July 15, 1886. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031/1HMADE58/86071501&query1=&recoffset=0&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&sort_col=relevance&cnt=11&CurSearchNum=4&recOffset=0.

“Oh Woman, Woman.” The Minneapolis Tribune, April 30, 1891. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F59%2F91043001&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=10&search_doc1=prostitute&submit.x=4&submit.y=11&page_name=&page_name=.

“Out on Strike.” The Minneapolis Tribune. April 19, 1888. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F88041901&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=strike&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=8&search_doc1=strike&submit.x=5&submit.y=17&page_name=&page_name=.

“Police Court Notes.” The Minneapolis Tribune, July 13, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89071301&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=fine&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=fine&submit.x=16&submit.y=10&page_name=&page_name=.

“Police Court Notes.” St. Paul Daily Globe, June 24, 1890. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0031%2F1HMADE59%2F90062401&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=d72e456d-522a-4fdf-8336-56a3e5376728&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=14&submit.y=10&page_name=&page_name=.

“Police Notes.” The Minneapolis Tribune. November 1, 1887. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F87110101&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=house%20of%20ill%20repute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=-1&search_doc1=house of ill repute&submit.x=5&submit.y=12&page_name=&page_name=.

Report of the Annual Convention. Vol. 10. Red Wing, MN: Red Wing Printing, 1886.

“The M’Kays Again.” The Minneapolis Tribune, September 25, 1896. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F59%2F96092501&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=common%20prostitute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=3&search_doc1=common prostitute&submit.x=6&submit.y=9&page_name=&page_name=.

“The Routine of the Council.” The Minneapolis Tribune. April 20, 1889. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F89042001&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=ordinance&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=2&search_doc1=ordinance&submit.x=9&submit.y=1&page_name=&page_name=.

“Truthful James.” The Minneapolis Tribune. December 19, 1886. https://newspapers.mnhs.org/jsp/viewer.jsp?doc_id=mnhi0005%2F1DFC5F58%2F86121901&view_width=640.0&rotation=0&query1=&collection_filter=All&collection_name=4a0c6900-28ec-40e6-bafa-8705a70f68f8&zoom_factor=current&search_doc=house%20of%20ill%20repute&sort_col=relevance&highlightColor=yellow&color=&CurSearchNum=6&search_doc1=house of ill repute&submit.x=2&submit.y=9&page_name=&page_name=.


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