House Arrest (1904)

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Martha Stewart complains that life under "house arrest" is just terrible. OED has "house arrest" from 1936.
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Actually, the "house" never gets "arrested."
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Did it start with the Kaiser?
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(PROQUEST HISTORICAL NEWSPAPERS) ("under house arrest")
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KAISER PUNISHES HIS SON.; Crown Prince Confined to Quarters for Riding in Dangerous Horse Race.
Special Cable to THE NEW YORK TIMES.. New York Times (1857-Current file). New York, N.Y.: May 14, 1904. p. 1 (1 page):
This is the second time the Emperor has punished his son for reckless driving, having a short time ago ordered him under "house arrest" for a week for a daring feat of horsemanship.
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VACANT PALACE SIGN OF SCANDAL; Archduke Ludwig Banished by Austrian Emperor for Mysterious Escapade. MAY BE U. S. EMBASSY. Ambassador Storer May Secure House Left Behind by Exiled Royalty. Palace a Fine Structure. Archduke in a Scandal. Ludwig Banished by Emperor. This Archduhke Runs Amuck. Marie or Karl May Get Palace.
Chicago Daily Tribune (1872-1963). Chicago, Ill.: Mar 4, 1906. p. B1 (2 pages)