 Swift's prize fighting had led to the death of two former opponents, and William Phelps, himself, had previously killed a man in a prize fight.These factors later incited several magistrates to act and three months later, in June of 1838, Curtis was sentenced to eight months imprisonment at Herford Assizes for acting as a principle to manslaughter in the second degree, even though he had only acted as second to the victim.Curtis was discharged from custody, however, on 11 July 1838, when a coroner determined that the cause of death could not be exclusively attributed to the fight.