If you find yourself walking down Park Avenue this summer, a detour on to 37th Street will land you at one of New York’s many historical markers for the Revolutionary War.[1] The marker honors Mary Lindley Murray—an unexpected hero of the Revolution. Imagining the figures of the American Revolution generally conjures up images of crossing the Delaware, throwing tea off a ship in Boston Harbor, or sewing a flag—rarely are we recounting hosting duties. Yet that is how we honor Mrs. Murray, who is immortalized on this plaque for “services rendered her country during the American Revolution entertaining at her home, on this site, Gen. Howe and his officers, until the American troops under Gen. Putnam escaped.”[2]

American Major General Israel Putnam, of Connecticut, was a leader of the Continental Army with George Washington, serving as General Washington’s second in command in New York City.[3] In August 1776, General Putnam participated in the mess that was the Battle of Brooklyn.[4] After a long spring waiting for the British to attack New York City after evacuating Boston, the British landed on Staten Island in early July, poised to overwhelm American troops.[5] The Continental Army, largely outnumbered, had managed to erect major fortifications on Governors Island, in Red Hook, in Brooklyn Heights, and in the Battery of Manhattan.[6] From there, they awaited the British.[7]

According to the National Park Service, the first shots were fired by the Americans on August 26, 1776, directed at two British soldiers seen in a watermelon patch.[8] That evening, capitalizing on the Continental Army’s failure to secure the Jamaica Pass, General Howe of Great Britain led 10,000 soldiers into position to attack Brooklyn Heights from the rear.[9] The next morning British soldiers attacked the Continental Army, firing on troops stationed near the Red Lion Tavern in Brooklyn.[10] Realizing they were overwhelmed and facing defeat, the Americans evacuated from Brooklyn, turning their sights back to Manhattan.[11]

So where does Murray come in? After retreating to Manhattan, General Washington determined that the Army would be better placed in Harlem Heights and began to make his move.[12] But there was a problem—General Putnam’s troops, numbering near 4,000, needed to escape from lower Manhattan.[13] This set the stage for Mrs. Murray and her hosting skills.

On September 15, 1776, as the Americans planned their evacuation, British soldiers traversing through New York City made a stop at what would be Murray Hill’s (named for the Murrays themselves) first but certainly not last notable party.[14] Mr. Robert Murray, Mrs. Murray’s husband, was a known supporter of the Crown. But Mrs. Murray was a friend to the Revolution and had learned something of General Washington’s plans from his visit to her home just two days prior.[15] Despite knowing her loyalties, British General Howe paid a social visit to the Murrays, bringing along other British militia leaders and leaving his soldiers outside in the shade of the trees surrounding her mansion.[16]

Mrs. Murray spent hours serving wine, tea, and cake to the British generals who suspected nothing as General Putnam and his troops, with help from Aaron Burr, passed through what would become Times Square and up to Harlem Heights. The next day the Continental Army would win the only victory for the Americans in New York City during the war.[17] Recounting Mrs. Murray’s skillful hosting, James Thacher, who maintained a detailed firsthand account of the war in his journal, remarked that “it has since become almost a common saying among our officers that Mrs. Murray saved this part of the American Army.”[18]

Today, you will see homages to Mary Lindley Murray sprinkled throughout her former home in midtown Manhattan. Beyond her plaque, P.S. 116, a public elementary school located on the border of Murray Hill and Kip’s Bay, is named for her. A Staten Island ferry was named in her honor.[19] And her actions inspired famed Musical Theatre visionaries Rodgers and Hart to write their musical Dearest Enemy, recounting Mrs. Murray’s victories, which opened in 1925.[20]

So what do lawyers have to learn from Mrs. Murray—aside from the lifelong truth that almost everyone enjoys cake. Mrs. Murray was not a general, yet she saved thousands of soldiers’ lives and propelled the Revolution forward. Her approach was unorthodox, opening her home to her enemy so that the American Army could escape. For her, going to battle was not the only way to win the war. The same is true for many lawyers. The decisions that propel forward client interests are not always best won in battle—sometimes they are won in kindness. There are many approaches to lawyering, and many who do it well. As we celebrate the Declaration’s anniversary, one can hope that we will all continue to make advances in styles uniquely our own.

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Editor’s note: The author, an attorney and resident of New York City, is known to enjoy a historical landmark.

[1] This author has endeavored to include directions for finding the New York City historical landmarks referenced in this article. While it is hard to imagine the modern New York City skyline when reading about the Revolutionary War, historical landmarks around the city help us do so. The events described in this article, and this edition of the Quarterly, took place on our blocks, around our universities, and down the street from our office buildings. Historical landmarks connect the New York City of 250 years ago with the city that the Second Circuit sits in today.

[2] Mary Lindley Murray, The Hist. Marker Database, https://www.hmdb.org/m.asp?m=42792 (May 29, 2011).

[3] Israel Putnam, Nat’l Park Serv., https://www.nps.gov/people/israel-putnam.htm (Feb. 20, 2025); The Role of Governors Island in the American Revolution, Nat’l Park Serv., https://www.nps.gov/gois/learn/historyculture/battle-of-brooklyn.htm (Feb. 26, 2015).

[4] This is also called the Battle of Long Island – take your pick!

[5] The Role of Governors Island in the American Revolution, Nat’l Park Serv., https://www.nps.gov/gois/learn/historyculture/battle-of-brooklyn.htm (Feb. 26, 2015).

[6] Id.

[7] Id.

[8] Id.

[9] Battle of Long Island, George Washington’s Mount Vernon, https://www.mountvernon.org/library/digitalhistory/digital-encyclopedia/article/battle-of-long-island (last visited Apr. 6, 2026).

[10] If you are making a tour out of this, the Red Lion Inn was located at the corner of 4th Ave and 35th Street, on the border of Greenwood Heights and Sunset Park. You can find a plaque commemorating it, and the battle, in the Green Wood Cemetery located in that area. Red Lion Inn, The Hist. Marker Database, https://www.hmdb.org/m.asp?m=13243 (Jan. 31, 2023). Today, Brooklyn’s Costco and Industry City complex sit nearby.

[11] Battle of Long Island, George Washington’s Mount Vernon, https://www.mountvernon.org/library/digitalhistory/digital-encyclopedia/article/battle-of-long-island (last visited Apr. 6, 2026).

[12] The buckwheat field which would see the heaviest fighting during the Battle of Harlem Heights would later become the site of Columbia University and Barnard College as we know them today. You can find a commemoration of this battle on the street side of the Mathematics Hall. Battle of Harlem Heights, The Hist. Marker Database, https://www.hmdb.org/m.asp?m=223661 (May 19, 2023).

[13] WOMAN’S RUSE HELPED WIN THE REVOLUTION; Mary Murray, Who Detained General Howe, May Have a Park Avenue Memorial, N.Y. Times, Sept. 22, 1929, at Section X, Page 13.

[14] Morgan and Others Fight to Save Murray Hill, N.Y. Times, June 7, 1914, Page 44, https://www.newspapers.com/article/24914351/mrs_mary_lindley_murray_at_murray_hill.

[15] WOMAN’S RUSE HELPED WIN THE REVOLUTION; Mary Murray, Who Detained General Howe, May Have a Park Avenue Memorial, N.Y. Times, Sept. 22, 1929, at Section X, Page 13.

[16] Id.

[17] Id.

[18] James Thacher, A Military Journal During the American Revolutionary War from 1775 to 1783, 60 (2d Ed. 1827).

[19] NEW CITY FERRYBOAT GOES DOWN THE WAYS; The Mary Murray Is Second of Three Streamlined Craft – Mayor Attends Ceremony, N.Y. Times, June 4, 1937, at page 25.

[20] Dearest Enemy, Internet Broadway Database, https://www.ibdb.com/broadway-show/dearest-enemy-2992 (last visited Apr. 6, 2026).