Schoellkopf v. Devry

I cannot agree with the majority of the court in the decision of the issue presented by this case. It is said that when the Dower act was passed and thereafter until 1922, every woman who might lawfully be naturalized became an American citizen upon her being married to a citizen of this country. This is not true if the first and second sections of the Dower act are considered as having been adopted in 1845. Prior to the passage of the second section of the act of Congress of February 10, iSg'g, (10 Stat. at L. 604,) the provision was made by an act of 1804, (2 Stat. at L. 292,) that when any…