In 1934, American politician William "Wild Bill" Langer, then governor of North Dakota, was convicted of conspiring to defraud the federal government after his administration collected political contributions from highway employees paid through federal relief programs. When the North Dakota Supreme Court ordered him removed from office, Langer signed a Declaration of Independence for the state, declared martial law in Bismarck, and barricaded himself inside the governor's mansion. He relented after his own officers refused to recognize his authority. An appeals court overturned his conviction in 1935, a later retrial acquitted him, and voters elected him governor again in 1936.
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