By a joint resolution approved May 18, 1898, reciting that Nellie Grant Sartoris, widow, daughter of Gen. U. S. Grant, and a naturalborn citizen of the United States, had married in 1874 a British subject, thereby becoming, under the laws of Great Britain, a naturalized British subject, recognized as such by the United States under the naturalization convention of May 13, 1870, it was declared that Mrs. Sartoris was, " on her own application, unconditionally readmitted to the character and privileges of a citizen of the United States," in accordance with Art. III. of that convention. 30 Stat. 1496. A woman, a citizen of the United States, was married to a Dutch subject, from whom she was subsequently divorced. After the divorce she resumed her domicil in the United States. It was held that she was entitled to a passport as an American citizen. Mr. Hay, Sec. of State, to Mr. Leishman, min. to Switzerland, No. 160, "Any woman who is now or may hereafter be married to a citizen of the United States, and who might herself be lawfully naturalized, shall be deemed a citizen.” Rev. Stat., § 1994; act of Feb. 10, 1855, chap. 71, § 2, 10 Stat. 604; As to the law prior to the act of 1855, see Shanks r. Dupont, 3 Pet. 242; The act applies to a woman married to an alien who subsequently be- The statute applies to a woman married to a citizen of the United States, lived at a distance from her husband and never came to the United States till after his death. (Kane v. McCarthy, 63 N. C. 299; Headman v. Rose, 63 Ga. 458. See Burton r. Burton, 1 Keyes, 359, 362, 366; Pequignot v. Detroit, 16 Fed. Rep. 211, 215.) But it has been held that a native woman who married an alien in the United States, and lived with him there till his death, did not conversely become an alien. (Comitis v. Parkerson, 56 Fed. Rep. 556.) In an earlier case, however, it was held that a woman, an alien by birth, who lived in the United States, and who, after the death of her husband, a citizen of the United States, married a subject of her native country, resumed her original nationality. (Pequignot v. Detroit, 16 Fed. Rep. 211. Contra, Phillips. Solic. General, 1877, 15 Op. 599.) That a divorced woman continues to be a subject of the state of which her husband was a subject, still she, by some act, changes her nationality, seems to be tacitly assumed in Pequignot v. Detroit, 16 Fed. Rep. 211. "Inasmuch as the subject of naturalization is within the exclusive jurisdiction of Congress, there would seem to be little question that such a marriage [one in conformity with the act of June 22, 1860] would be effectual for the purpose of naturalizing an alien female married to a citizen of the United States." Mr. Fish, Sec. of State, to Mr. Bancroft, June 7, 1870, MS. Inst. Prussia, Under the act of February 10, 1855, an alien woman, upon her marriage to an American citizen, acquires the right to be regarded by the authorities of the United States as an American citizen "in every country except that to which she owed allegiance at the time of her marriage." It may be, however, that by the law of such country she is regarded as becoming by her marriage a foreigner. In such case no conflict of law could arise, since the government of her original allegiance would concede her full American citizenship. Mr. Fish, Sec. of State, to Mr. Jewell, min. to Russia, June 9, 1874, H. Ex. Where a woman, a native of Santo Domingo, who had been married to a consul of the United States in that country, but who, after his death, continued to reside there, invoked the interposition of the United States in respect of depredations on her property, which were alleged to have been permitted by the authorities of the island, it was held that, while the United States "does regard the naturalization of a foreigner by reason of her marriage to an American citizen to be valid, yet at the same time something more than a mere marriage solemnization is required to establish good citizenship, such, for instance, as a domicil of some considerable duration in this country;" and that, as the complainant was a native of Santo Domingo, was married there, and had lived there since her husband's death, and as her property interests seemed to be "centered in that quarter," and the evils of which she complained appeared to be “of a purely judicial nature," it was not thought that it would be "either efficacious or proper" to interfere in the matter. Mr. Evarts, Sec. of State, to Mrs. Marced de la Rodia, June 21, 1879, 128 It was suggested, but not decided, on a passport application, that the same The Government of the United States can not recognize the right of the original Government of an alien-born woman, who was married to a naturalized citizen of the United States, but who has been divorced from him, to intervene in her behalf, so long as she voluntarily continues to make the United States her home. (Mr. Adee, Second Assist. Sec. of State, to Mr. Knagenhjelm, Aug. 21, 1895, MS. Notes to Sw. & Norway, VII. 591.) The American minister at Peking having instructed the American vice-consul at Hankow that Chinese and Japanese women, married to citizens of the United States, form an exception to the rule that the citizenship of the husband determines that of the wife, on the ground that Chinese and Japanese are not capable of naturalization in the United States and that women of those races therefore do not fall within sec. 1994 R. S., his views were approved. Mr. Hay, Sec. of State, to Mr. Conger, min. to China, No. 622, Feb. 5, 1903, For. Rel. 1903, 45, citing Kelly v. Owen, 7 Wall. 496, and Burton v. Burton, 40 N. Y. 373. See Mr. Conger to Mr. Cameron, Dec. 11, 1902, For. Rel. 1903, 44, citing 5 Sawyer, 155; 6 Sawyer, 541; Fong Yue Ting v. United States, 149 U. S. 716; In re Gee Hop, 71 Fed. Rep. 274. (2) REVERSION OF NATIONALITY. § 411. J., the widow of an American citizen, residing in Nicaragua, claimed exemption, on the ground of her American citizenship, from a forced loan. She was a native of Nicaragua. Held, that while she acquired by her marriage the nationality of her husband by virtue of section 1994, Revised Statutes, yet, being a native of Nicaragua and continuing to reside in the country of her origin, there was room for the contention that she had resumed her original nationality; and that, as she had not since her husband's death manifested any intention of coming to the United States, it was not the duty of the Government to intervene to secure her immunity from obligations imposed upon her by the country of her birth and continued domicil. Mr. Gresham, Sec. of State, to Mr. Baker, min. to Nicaragua, Jan. 24. 1894, For. Rel. 1894, 460. "I have received your letter of October 21st, complaining of a law recently promulgated in Nicaragua, by virtue of which a native Nicaraguan woman, who, having married an alien, continues to reside in Nicaragua after his death, recovers her Nicaraguan nationality. "As the courts of the United States have decided that an Americanborn woman who marries a foreigner and subsequently becomes a widow, still residing here, remains a citizen of the United States, we can not object to Nicaragua declaring by law a similar rule in respect to a native of Nicaragua." 66 Mr. Uhl, Act. Sec. of State, to Mr. Flint, Dec. 11, 1894, 199 MS. Dom. This evidently refers to the decision in Comitis r. Parkerson, 56 Fed. Rep. 556. By her marriage to a citizen of the United States Mrs. Constantine became vested with his rights as a citizen of the United States. Upon his death she might revert to her original citizenship or retain her American citizenship. She elects to do the latter, and the fact that she is dwelling in Turkey does not militate against her doing so, the Department having repeatedly ruled that the limitations of permitted residence abroad do not apply to that country." It was therefore held that she was entitled to a passport as a citizen of the United States. Mr. Hay, Sec. of State, to Mr. Choate, amb. to England, No. 530, Jan. 14. 1901, MS. Inst. Gr. Br. XXXIII, 534. 66 L., a woman, originally a British subject, went to Canton, in China, and opened a hotel. By the British regulations, British subjects were required, under certain penalties, to take out a license for such purpose. There was no American regulation on the subject. L. claimed to be an American citizen under § 1994, Revised Statutes of the United States, which provides that any woman who is now or may hereafter be married to a citizen of the United States, and who might herself be lawfully naturalized, shall be deemed a citizen." She had lately, however, been divorced from her American husband by the judgment of the United States consular court at Niuchwang. The consul at Canton inclined to the opinion that she had by the divorce lost her American citizenship. The minister at Peking expressed the opinion that the divorce had simply dissolved the marital relations, and that she still remained a citizen of the United States. The Department of State approved this opinion, stating that L., by her marriage, became an American citizen, both by British and by American law; that she had not lost her American nationality by any method recognized by American law; that according to British law an English woman, who by marriage acquires foreign citizenship, must, in order to reacquire her original nationality upon her husband's death, obtain a certificate there for from the British authorities; that it was not believed that any different rule would be applied where the parties were divorced, and that, as L. claimed American citizenship, it was assumed that she had not taken any steps to reacquire British nationality, and that there was no conflicting claim to her allegiance. Mr. Uhl, Acting Sec. of State, to Mr. Denby, min. to China, March 17, 1894, For. Rel. 1894, 139. In 1887 the authorities of the canton of Zurich, Switzerland, applied to the American legation in Berne for a passport for Mrs. Weiss, an insane pauper, as a citizen of the United States. It appeared that she was a native of Zurich, and that she was married at New York in March, 1873, to John Weiss, a native of Baden, who, in the following October, was naturalized. In 1878, however, Weiss and his wife returned to Europe, and in 1880, while they were residing in Zurich, he deserted her, and, it was said, went back to the United States; but since the desertion nothing had been heard of him, and it was not known that he was alive. It was held by the Department of State that her remaining in Zurich after her desertion would, under ordinary circumstances, presumptively revive her Swiss domicil and nationality; that, notwithstanding her lunacy, such a revival might be caused by the election of her local guardians, and that the action of the Swiss authorities, in hunting up the record of her husband's naturalization and asking that a passport be given her, apparently with a view to export her to the United States and thus get rid of the burden of her support, could not be regarded as an assertion in her behalf of American citizenship. Mr. Bayard, Sec. of State, to Mr. Winchester, min. to Switzerland, Jan. 5, and March 19, 1888, For. Rel. 1888, H. 1516, 1531. 3. LAW IN OTHER COUNTRIES. $412. "In 1862 it was decided by the British Government, in the case of American-born widows of British subjects, that, if the American law was at variance with their own (conferring upon the wives of British subjects the privileges of natural-born British subjects), and the |