not explain the principles of the Constitution, was entitled to be naturalized, where it was shown that he was peaceable, industrious, of a good moral character, and law-abiding.

(G.) Change of Name.

At the time and as a part of the naturalization of any alien it shall be lawful for the court in its discretion upon the petition of such alien to make a decree changing his name, and his certificate of naturalization shall be issued to him in accordance therewith. Sec. 6.*

Prior to the passage of the law of 1906, it was held in In re Nigri, 32 Misc. 392, 66 N. Y. S. 182, that a person who obtains a legal change of name was not entitled to have his certificate or record of naturalization changed accordingly.

Where the name is misstated in the certificate the true name may be proved by parol. Behrensmeyer v. Kreitz, 135 Ill. 591.

Every final order which may be made upon the petition for naturalization shall be under the hand of the court and entered in full upon a record kept for that purpose.

6. Certificate.

(a.) In General.

Prior to the enactment of the Law of June 29, 1906, no form of naturalization certificate was prescribed by law and there was great variety in the certificates issued. Some were long with a full recital. Others were short, with a bare statement that the holder was admitted to

*In every case in which the name of a naturalized alien is changed by order of court, as provided in Section 6, the clerks of courts are required to report to the Bureau of Immigration and Naturalization, when transmitting to it the duplicate of the certificate of naturalization of the alien whose name is changed, both the original and the new name of the said person. Nat. Reg. of Oct. 2, 1906.

citizenship on a certain day. The certificates contained no description of the person naturalized, and were, in consequence, readily transferable. They were printed from type on ordinary paper, and it was easy to manufacture spurious certificates.

(b.) Certificates Under the Act of March 3, 1903.

The Act of March 3, 1903, 32 Stat. at L. 1222, in its 39th section, known as the "anarchist clause," provided that in order to render a naturalization certificate valid the naturalizing court should cause to be entered of record the affidavit of the applicant and his witnesses, so far as applicable, reciting and affirming a compliance with the terms of that act and previous acts relating to naturalization, and that each final order and certificate thereafter made should show on the face thereof that the affidavits required of the applicant and his witnesses were duly made and recorded.

Many courts, through ignorance of the provisions of the Act, or for other reason, issued invalid certificates of naturalization. Thousands of such invalid certificates were issued and many were issued to persons entitled to receive valid certificates. To remedy this injustice, on the same day the Act of June 29, 1906, establishing a Bureau of Immigration and Naturalization, and providing for a uniform rule for the naturalization of aliens, was passed, which repealed Section 39 of the Act of March 3, 1903, the following law was passed:

"Naturalization certificates issued after the Act approved March third, nineteen hundred and three, entitled 'An Act to regulate the immigration of aliens into the United States,' went into effect, which fail to show that the courts issuing said certificates complied with the requirements of section thirty-nine of said Act, but which were otherwise lawfully issued, are hereby declared to be

as valid as though said certificates complied with said section: Provided, That in all such cases applications shall be made for new naturalization certificates, and when the same are granted, upon compliance with the provisions of said Act of nineteen hundred and three, they shall relate back to the defective certificates, and citizenship shall be deemed to have been perfected at the date of the defective certificate.

"Section 2. That all the records relating to naturalization, all declarations of intention to become citizens of the United States, and all certificates of naturalization filed, recorded, or issued prior to the time when this Act takes effect in or from the criminal court of Cook County, Illinois, shall for all purposes be deemed to be and to have been made, filed, recorded, or issued by a court with jurisdiction to naturalize aliens, but shall not be by this Act further validated or legalized." Act of June 29, 1906.

(c.) Under the Act of June 29, 1906.

The Act of 1906, makes it the duty of the Secretary of Commerce and Labor to cause to be engraved on distinctive paper blank certificates of citizenship (Sec. 17), to be furnished clerks of courts having jurisdiction in naturalization matters. Sec. 12, par. 3. All blank certificates are consecutively numbered, and clerks are required to account for them to the Bureau of Naturalization.

(d.) Form.

The Act prescribes the form of certificates as follows:

Description of holder: Ag........... height.......

; complexion; color of eyes hai................ visible distinguishing marks. age, and place of residence of wi...................

; color color of ...........Name,

Names, ages, and places of residence of minor children

court of............., held at.............. on the................day off.......... in the year of our Lord nineteen hundred and

...........

who previous to his (her) naturalization was a citizen or subject of ... at present residing at number.. street...city (town).......... state (territory or district), having applied to be admitted a citizen of the United States of America pursuant to law, and the court having found that the petitioner had resided continuously within the United States for at least five years and in this State for one year immediately preceding the date of the hearing of his (her) petition, and that said petitioner intends to reside permanently in the United States, had in all respects complied with the law in relation thereto, and that he was entitled to be so admitted, it was thereupon ordered by the said court that he be admitted as a citizen of the United States of America.

In testimony whereof the seal of said court is hereunto affixed on the....day off.............., in the year of our Lord nineteen hundred and. and of our independ

ence the............

[L. S.]

(Official character of attestor.)

It will be noticed that the certificate includes a personal description of the holder, and he is required to sign his name on the face of the certificate. This precludes false personation.

The prescribed form is brief and simple, as well as comprehensive. It attests that the person therein named and described, having made application pursuant to law, and the court having found that he had complied in all respects with the law in relation to naturalization and was entitled to be naturalized, it was ordered by the court that he be admitted as a citizen.

The seal of the court is affixed to the certificate.

Each certificate of naturalization shall bear upon its face in a place prepared therefor the volume number and page number of the petition whereon such certificate was issued, and the volume number and the stub number of such certificate. Sec. 14.

(e.) Duplicate of Certificate.

It is made the duty of the clerk of every court exercising jurisdiction in naturalization matters under the Act of 1906 to send to the Bureau of Naturalization at Washington within thirty days after the issuance of a certificate of citizenship a duplicate of such certificate. Sec. 12.

(f.) Stub.

The Act also requires the clerk to make and keep on file in his office a stub for each certificate issued by him whereon shall be entered a memorandum of all the essential facts set forth in such certificate. Sec. 12.

The prescribed form of the stub of certificate is as follows: