SELFISH INTENTIONS - K-REx - Kansas State University

has not property (other than a single suit of wearing apparel) which is not in the possession of
said plaintiff.” 149
In a later affidavit, Downing categorically denied that he had ever physically abused his
wife and told a story that tended to undercut Susanna’s claim that she was terrified of him.
When the Wyandotte County sheriff had found him in early February, Downing had returned
home immediately. When he showed up, Susanna had shown him the restraining order, but had
then allowed him to stay at the residence. Downing claimed that he immediately set to work
taking care of farm business. He went so far as to account for the $9.00 that had been in his
possession when he returned: all but $1.50, he claimed, had gone for groceries for his wife.
Downing’s story was reinforced by an affidavit from the Downings’ hired man, C. P. Ellis. Ellis
testified that William Downing had been “careful” of the interests of Susanna Downing in taking
care of the farm and livestock, including during the period since his return. More significantly,
Ellis also claimed that he had never seen anything to believe that the plaintiff was in any danger
of bodily harm from her husband, asserting instead that Downing had conducted himself at all
times as an ordinarily reasonable and kind husband. 150
As for his Downing’s alleged infidelity, he more or less confessed. But he added that the
fault for his behavior rested on Susanna Downing. He had been induced to such acts
149 Ibid.
150 Ibid.
151 Ibid.
by the vile, profane, indecent and abusive language and villainous threats of said
plaintiff heaped on this defendant day after day that said plaintiff with vile,
profane invective too indecent to be written has frequently threatened to murder
this defendant and instead of seeking the “legitimate ends and objects of
matrimony” has made defendants fond dream of wedded bliss a reign of terror. 151
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