That a wife's political status follows that of her husband, see Mr. Frelinghuysen, Sec. of State, to Mr. Lawrence, March 31, 1883, 146 MS. Dom. Let. 287; to Mr. Foster, April 2, 1883, 146 MS. Dom. Let. 311. "The view has been taken by this Department in several cases that the marriage of an American woman to a foreigner does not completely divest her of her original nationality. Her citizenship is held for most purposes to be in abeyance during coverture, but to be susceptible of revival by her return to the jurisdiction and allegiance of the United States." Mr. Blaine, Sec. of State, to Mr. Phelps, min. to Germany, Feb. 1, 1890, See, to the same effect, Mr. Evarts, Sec. of State, to Mrs. Wood, Sept. 24, An application was made to the Department of State for a passport for an American woman, who, though married to a British subject, desired, it was said, to retain her American citizenship and to reside in New York. The Department declined to grant the application, on the ground that, under British law and the naturalization treaty between the United States and Great Britain of May 13, 1870, the woman in question was a British subject. It was added, however, that this decision did not imply any opinion as to her status," so far as her property and local rights may be concerned, under the law of the State of her residence. That is a question determinable by a court having appropriate jurisdiction.” Mr. Day, Assist. Sec. of State, to Mr. Robertson, Oct. 21, 1897, 221 MS. It is the practice of the Department of State to decline to issue passports A person who inquired "whether the British Government would recognize the naturalization papers of a former British subject, an English woman, who was naturalized in the United States without the consent of her husband," was advised to consult private counsel learned in the law of Great Britain. (Mr. Adee, Acting Sec. of State, to Mrs. Clark, Oct. 3, 1896, 213 MS. Dom. Let. 77.) (2) REVERSION OF NATIONALITY. An application for the interposition of the United States was made by a woman who represented that she was an American citizen by birth and the widow of a Turkish subject. The application was dated at Constantinople, and its tenor indicated that the applicant's "marital domicil was in Turkey." Supposing this to be the case, the Department of State had "no hesitation in saying" that, so long as she remained in Turkey, she could not, unless for the purpose of enabling her to return to the United States, obtain the Department's interposition. By marrying a Turkish subject and taking up her residence in Turkey, she became, said the Department, a Turkish subject, and to recover her American nationality "must leave Turkey and take up an American residence." Mr. Bayard, Sec. of State, to Mrs. Lografo, Feb. 6, 1886, 158 MS. Dom. The fact that an American-born woman married to a Chinese subject A quotation has been made from a note of Mr. Frelinghuysen to the minister of Sweden and Norway (supra, p. 453). The woman therein referred to was afterwards divorced from her husband, a Swede, by the Swedish courts, on account of her insanity, and was placed by her mother, an American citizen, by whom she was supported, in an asylum in Austria. From this asylum she was in 1888, against the protest of her mother, removed by a person acting as her guardian under Swedish law to an asylum in Sweden. Her mother sought to regain her custody, as her "only rightful and natural guardian;" and to this end resorted to the Swedish courts, and also invoked the good offices of the United States. The Department of State gave the following instructions: "As Madam de Bdivorced from her husband upon his application it is thought that such good offices can properly be employed in her behalf as a person whose original American nationality has reverted to her." was Mr. Bayard, Sec. of State, to Mr. Magee, min. to Sw. & Norway, No. 127, See, however, Pequignot r. Detroit, 16 Fed. Rep. 211. An American woman was married to a Russian subject. Four years after his death, while she was residing in France, the intervention of the United States in her behalf was invoked in respect of proceedings which, it was alleged, were about to be instituted to commit. her to an insane asylum. As it did not appear that she had exercised her "possible right" of reversion to her original citizenship, which, if it existed, could be effectively asserted "by returning to and dwelling in the country of her maiden allegiance," it was held that the United States could not officially intervene in her behalf. Mr. Day, Assist. Sec. of State, to Mr. Updegraff, Jan. 27, 1898, 225 MS. NATIONALITY. [§ 410. 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, 2. MARRIAGE OF ALIEN WOMEN TO AMERICANS. (1) AMERICAN LAW. § 410. "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; 185. 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, irrespective of the time or place of marriage or the residence of the parties (Kelly r. Owen, 7 Wall. 496; United States . Kellar, 11 Biss. 314; Williams, At.-Gen., 1874, 14 Op. 402); even though the woman 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 . Rose, 63 Ga. 458. See Burton v. 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 c. 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 r. 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, II. 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 fix or declare the conditions constituting citizens of the country within its own territorial jurisdiction, and may confer the rights of American citizens everywhere upon persons who are not rightfully subject to the authority of any foreign country or government, it ought not, by undertaking to confer the rights of citizenship upon the subject of a foreign nation, who had not come within our territory, to interfere with the just rights of such nation to the government and control of its own subjects." Mr. Fish, Sec. of State, to Mr. Jewell, June 9, 1874, H. Ex. Doc. 470, 51 In 1896 Mr. Breckinridge, then American minister at St. Petersburg, observing in the foregoing instruction an uncertainty as to the actual state of the Russian law, addressed an inquiry on the subject to the Russian foreign office. Mr. Chichkine replied March 14/26, 1896, that "every Russian woman married to a foreigner embraces the nationality of the latter if the marriage has been contracted conformably to Russian law." Mr. Breckinridge, min. to Russia, to Mr. Olney, Sec. of State, No. 264, Mr. Olney, observing the clause "if the marriage has been contracted con- The Department of State seems to have thought, in 1863, that the By article 1026 of the Russian Civil Code, Collection of Laws of the Russian Empire, IX., edition of 1876, it is provided: "Every Russian subject who has married a foreigner, and thereby will be considered as a foreigner, has the right after the death of her husband, or after a formal divorce, to resume Russian allegiance, and in this case it will suffice for her to present to the governor of the province in which she may have chosen domicil a special certificate proving her widowhood or divorce. The document delivered by the governor stating that the above certificate has been presented to him will be available to the person in question as proof of her resumption of Russian allegiance." See Mr. Peirce, chargé d'affaires ad interim, to Mr. Sherman, Sec. of State, Aug. 18, 1897, enclosing a note of Count Lamsdorff, of July 31/Aug. 12, 1897, For. Rel. 1897, 445, |