52 court of appeals of maryland

the Governor was sometimes referred to as the
Chief Judge. The title of Chief Justice and Jus-
tice were appropriated to the members of the Pro-
vincial Court and the county courts. Whether
the judges dressed in special gowns is not known
now. Such special habiliments were considered
essential in England during the eighteenth cen-
tury, and gowns or special coats may have been
worn here too. In 1666⁴¹ it was ordered by the
Council that every Justice of the Provincial Court
should appear for the sittings with his ribbon and
medal, and in 1696 again, there was some discus-
sion in the Lower House of the purchase of a
gown for the Chief Justice.⁴² There is a portrait
of Daniel Dulany, the younger, showing him in
a special gown as crown counsel.⁴³ And Griffith,
in his Sketches of the Early History of Mary-
land,⁴⁴ says that after the organization of the
Court of Appeals in 1695:

The gentlemen of the bar, for whose regulation many acts
had been passed since the establishment of the province, were
henceforth subjected to examinations before admittance, and
judges and lawyers directed to wear gowns in court.

But Griffith's authority for the statement has not
been discovered. The councillors would not have
given gowns much wear on the Court of Appeals.
And such is the case on the issue of gowns before
1776.

There may be some disproportion between so
much discussion of the organization and ways of

41. Archives, Proc. Council, 1636 to 1667, 547.

42. Archives, Proc. and Acts Assembly, 1693 to 1696/7, 443, 487.

43. jSee illustration facing p. 86.

44. Thomas W. Griffith, Sketches of the Early History of Maryland,'
Baltimore, 1821, p. 38.