Congressman William Stephen Morgan
of Virginia introduced House Resolution 8 on March 5, 1838. Morgan drafted his bill following several high-profile duels that included Members of Congress. This legislation was considered, but not passed, shortly after the fatal duel between House Members Jonathan Cilley
of Maine and William Graves
of Kentucky. Cilley was killed as a result of the duel on February 24, 1838. In 1826 Representative Sam Houston
of Tennessee and General William A. White dueled, and General White was seriously wounded. Morgan’s bill sought to amend the Constitution to prohibit dueling by any person holding federal public office and to bar anyone who took part in a duel after its passage from holding office. Congress outlawed dueling in the District of Columbia in 1839.