1. Although it cannot be stated with certainty, it seems likely that this letter reflects the concern of Le Guen, a New York City merchant, over the effect of his status as an alien on the ownership of land in the United States, for he was both a French citizen and the owner of property in Morrisville, Bucks County, Pennsylvania. In any event, before the letter printed above had been written, he had applied for citizenship, and on June 18, 1799, the United States District Court for the District of New York ruled: “… And the Court nevertheless entertaining a doubt whether the said Louis Le Guen can be admitted to become a Citizen of the United States by reason of the proviso to the first section of the act entitled ‘An Act supplementary to and to amend the act entitled “An act to establish an uniform Rule of Naturalization and to repeal the act heretofore passed on that subject.”’ For that in the said section of the said Act it is declared ‘that no alien who shall be a native, Citizen, Denizen or subject of any Nation or State with whom the united States shall be at War at the time of his Application shall be then admitted to become a Citizen of the United States.’ And the Court therefore not thinking fit to proceed farther in the naturalization of the said Louis Le Guen unless by the Direction of some Competent Superior Tribunal” (RG 21, Minutes of the United States District Court for the Southern District of New York. 1780–1801, National Archives). For the texts of the relevant statutes, see “An Act supplementary to and to amend the act, intituled ‘An act to establish an uniform rule of naturalization; and to repeal the act heretofore passed on that subject’” (1 Stat. description begins The Public Statutes at Large of the United States of America, I (Boston, 1845); II (Boston, 1850). description ends 566–69 [June 18, 1798]); “An Act to establish an uniform rule of Naturalization; and to repeal the act heretofore passed on that subject” (1 Stat. description begins The Public Statutes at Large of the United States of America, I (Boston, 1845); II (Boston, 1850). description ends 414–15 [January 29, 1795]); and “An Act to establish an uniform Rule of Naturalization” (1 Stat. description begins The Public Statutes at Large of the United States of America, I (Boston, 1845); II (Boston, 1850). description ends 103–04 [March 26, 1790]).

The refusal of the Court to grant Le Guen citizenship created a possible threat to his right to own land in Pennsylvania. From 1789 to 1797, Pennsylvania had placed no restrictions on alien ownership of land, except in times of war. For the appropriate statutes, see Tench Coxe to H, May 10, 1795, note 3. Then, in 1797, the state legislature allowed the existing statute to expire. Although legislation enacted on April 11, 1799, recognized all existing contracts, patents, or deeds of conveyance involving aliens, Section 1 of this act provided for the following restriction on all future purchases: “That any foreigner or foreigners, alien or aliens, shall previously to such purchase or purchases, declare his or their intention to become a citizen or citizens, agreeably to the act of Congress, entituled ‘An Act supplementary to and to amend the act, entituled An Act to establish an uniform rule of naturalization, and to repeal the act heretofore passed on the subject,’ passed the eighteenth day of June, one thousand seven hundred and ninety-eight” (“An Act to enable aliens, in certain cases, to purchase and hold real estate in this commonwealth” [Pennsylvania Laws, 1798–1799 Sess., Ch. CCXXII]).

Le Guen may have been going to Philadelphia in July, 1799, to apply for citizenship in the United States Courts in Pennsylvania or to secure his title to his property in Morrisville. No evidence has been found that Le Guen ever received citizenship, but he did retain his land until his death. On May 11, 1835, his heirs, Louisa, Emily, and Josephine Le Guen, sold more than fourteen acres in Morrisville through their attorney, George W. Richards, to Joseph Wood of Trenton, New Jersey, for two thousand dollars (copy of the deed, Bucks County Historical Society Library, Doylestown, Pennsylvania). H was involved in these matters because he was Le Guen’s legal adviser.

2. Letter not found.

3. Thomas Stoughton was a New York City merchant. For his role in Le Guen’s protracted dispute with Isaac Gouverneur and Peter Kemble, see Goebel, Law Practice description begins Julius Goebel, Jr., ed., The Law Practice of Alexander Hamilton: Documents and Commentary (New York and London, 1964– ). description ends , II, 77, note 126.

4. Either Edward or William Tilghman, both of whom were Philadelphia lawyers. For William Tilghman’s opinion on the cases involving Le Guen, Gouverneur, and Kemble, see Gouverneur to H, January 7, 1798, and Goebel, Law Practice description begins Julius Goebel, Jr., ed., The Law Practice of Alexander Hamilton: Documents and Commentary (New York and London, 1964– ). description ends , II, 74–75.

5. Thomas FitzSimons, a native of Ireland, was a Philadelphia merchant. He was a Federalist member of the House of Representatives from 1789 to 1795.

6. Either Robert Morris or Gouverneur Morris. Robert Morris, the financier, had owned land in Morrisville, but in 1799 he was in debtors’ prison. If Le Guen’s property in Morrisville was part of Morris’s original holdings, then the financier may have been helping Le Guen secure his title to the land. Gouverneur Morris had remained in Europe for four years after James Monroe had succeeded him in 1794 as United States Minister Plenipotentiary to France. He arrived in New York on December 23, 1798. Le Guen may have requested Gouverneur Morris’s assistance in securing acceptance of his application for citizenship, as Morris had helped other foreigners with their applications in 1799 (Anne Cary Morris, ed., The Diary and Letters of Gouverneur Morris, Minister of the United States to France; Member of the Constitutional Convention, etc. [New York, 1888], II, 377, 378).