Lewis Hartley’s Complaint to the Circuit Court

One of the most bizarre documents in the Holy Roller affair was Lewis Hartley’s complaint where he not only explained why he wanted a divorce from his wife, Cora, but also detailed how he tried to, murder his wife's lover, or in his words, "in order to avoid further annoyance deem it proper to assist the said Creffield to leave this mortal earth in a speedy manner."

No. 4377

In the Circuit Court State of Oregon, For Benton County. Lewis Hartley (Plaintiff) vs. Cora A. Hartley (Defendant) , Complaint filed May 11th, 1906. Victor Moses (Clerk. by Robt. Johnson (Deputy) W. S. McFadden, Attorney for Plaintiff.

In the circuit Court of the State of Oregon for Benton County.

Lewis Hartley----Plaintiff.

Vs.--

Cora A. Hartley---Defendant.

Plaintiff for cause of suit against the defendant above named alleges the following facts:--That heretofore to wit: on or about the 11th day of October 1881 in the County of Macomb in the State of Illinois this plaintiff and defendant were duly united in the contract of marriage and are now and have been at all times and dates since 1881 husband and wife.

That this plaintiff and defendant are now residents and inhabitants of Benton County State of Oregon and have been such residents and inhabitants at all times and dates for more than eight years last past.

That this plaintiff has at all times conducted himself toward his said wife as a true husband and cared for her in a becoming manner according to his station in life with a good comfortable home and all the necessaries and good things of this life to the best of his ability and with due respect to his marriage obligations to said defendant.

That the defendant in total disregard of her marriage duties has been guilty of cruel and inhuman treatment and personal indignities toward this plaintiff for the past three years rendering his life burdensome in this: ’’That without the knowledge and against the will of this plaintiff in the early summer of 1903 and at all times until the fall of 1903 covering a period of many months the said defendant deserted the home of this plaintiff and took herself to Kiger’s Island in said County and went into camp with one Creffield known locally as “The Joshua” or “New Christ”, and the head of what is known as the Holy Rollers; and said defendant remained in camp with sundry women and men and more particularly the said Creffield; the said defendant said Creffield and other women being engaged in wild orgies on the earth together in almost a nude condition rolling on the earth together in a promiscuous way during unusual hours of the night and day separated from the balance of the world, and the said defendant conforming to certain ritualistic or sensualistic practices prescribed and ordained as coming from Heaven by and through the mediation of the aforesaid Joshua--said defendant divesting herself of her under clothing for the purposes of conforming to the revelations claimed to be received in some occult way by said Creffield and consenting to certain acts and practices with The Joshua in conflict with the fundamental laws of the State of Oregon; that his plaintiff in order to induce defendant from said camp and influences and acts on more than one instance brought her back to his home in the City of Corvallis; but said defendant in total disregard of his desires and against his protests would desert her home and repair to said Camp and engage in said practices whenever this plaintiff’s business called him from said city which was frequently during all of the Summer and fall of 1903; that the said Camp and its followers left said Island in the fall of 1903 and established themselves immediately South of Corvallis at what is known as the Hurt residence and the defendant deserted her home and at said Hurt residence again took up her abode with said Creffield and his band of Holy Rollers in the same manner and form substantially as to acts  and doings as on said Island, and there engaged in wild and unknown practices during whole nights with said Creffield; and burnt furniture, clothing, ornaments, watches, jewelry and generally every thing necessary to the comfort of a well regulated household; besides making burnt offerings of domesticated animals such as dogs and cats. That this plaintiff by real force and entreaties did induce the defendant to leave the premises last aforesaid and the said Holy Rollers on at least three different occasions after the hour of midnight and return to her home with him; but said defendant as soon as he left his home to attend to his usual business matters would return to said Hurt place and the general (pretty illegible, maybe the word is “religion”) of said Rollers and said Creffield and engage in the wild and unusual practices herein before mentioned. That this plaintiff has been most earnest in his endeavors to induce the said defendant to quit and leave said Camp, said Rollers, said Hurt residence orgies and the acts and practices and similar acts and practices of said band, headed, controlled and operated by said Creffield as is sensualistic Prophet, Joshua and High-Priest-that after the confinement of said Joshua in the Penitentiary of this State for a Statutory crime for the term of about two years and her said acts being condoned so far as possible by this plaintiff while the Prophet was serving his term in said prison and said Creffield being released from said prison in the early part of 1906; the said defendant in some way or manner unknown to this plaintiff became advised of the whereabouts of the said Creffield and did immediately commence to evince the same dispositions as had before actuated her. That on or about the 21st day of April 1906 the said defendant left the home of this plaintiff to join said Creffield at or near some camp near Waldport Lincoln County Oregon and did leave Corvallis at said last mentioned on the C&E RR for the purpose of going to the camp of said Creffield at said last mentioned place; that this plaintiff to defeat her intentions from being realized did also at said last date take the cars to go in the same direction as his said wife to locate the whereabouts of said Creffield and his Rollers; but said defendant discerned this plaintiff’s intentions and at Blodgett in Benton county left the train and walked to Toledo some 30 or 40 miles and by ways and means unknown to plaintiff followed said Creffield to a point about 21 miles south of Waldport in Lane County Oregon. That this plaintiff in order to avoid further annoyance deem it proper to assist the said Creffield to leave this mortal earth in a speedy manner, but owing to the fact of rim cartridges instead of center fire cartridges that happy even was avoided by the flight of the said Prophet: That against the will of the defendant she was induced to return to the home of this plaintiff after the flight of Creffield. That defendant refuses to live with this plaintiff and it is impossible for this plaintiff longer to live with her as his wife or otherwise live with her--that she pronounces him unclean-unsactified (sic) and reprable (sic) and will not countenance him for having endeavored to assist the prophet to that happy country beyond this mundane sphere of tears and sorrows.

That the acts of defendant and her practices for the past three years in manner and form as herein mentioned has been continuous and since said Creffield has been released from the Penitentiary and particularly since the 1st of April last has been most annoying and vexatious to this plaintiff. That this plaintiff has labored with the said defendant to reclaim her from the practices and peculiarities and acts herein mentioned as well kindred acts and practices and has procured the assistance of good and reputable persons to assist him to the same end of inducing defendant to return to her marriage obligations and conduct herself as she did during her married life prior to 1903; but all to no purpose.

That she conceives herself to be the bride of the said so called prophet and this plaintiff as an alien and a stranger to her in a legal sense and not in fact her husband. That this plaintiff is a man of the usual qualities and feelings of the average human being and by the long and continuous acts, practices and cruel and inhuman treatment and personal indignities his life has become burdensome by and through the said defendant.

Wherefore Plaintiff prays a decree of the Court dissolving and annulling the marriage contract now existing between plaintiff and defendant and decreeing this plaintiff his costs and disbursements in this suit.

W. S. McFadden, attorney for Plaintiff