Petitioner, a native-born American woman, was taken to Canada by her father who became naturalized there while she was still a minor. Petitioner later married a British subject and seeks naturalization here under a statute authorizing this to American women who have lost their citizenship through marriage to an alien. A treaty in force between the United States and Great Britain provided that persons naturalized according to Canadian law should lose American citizenship. The Canadian statute provided that if the father became naturalized, his minor children should, "within Canada," be deemed Canadian subjects. Held, that petitioner had not lost her citizenship by her father's naturalization, the Constitution preventing loss of citizenship without actual consent. On appeal, held that the treaty applied, and that petitioner's status had been changed by her father's naturalization. United States v. Reid, (C. C. A. 9 th, 1934) 73 F. (2d) 153.
INTERNATIONAL LAW-EXPATRIATION-CITIZENSHIP OF CHILD LOST BY REMOVAL AND EXPATRIATION OF FATHER,
Mich. L. Rev.
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