It is speculated that Jérôme's prospective title is a reason the 11th Congress of the United States in 1810 proposed the Titles of Nobility Amendment to the U.S. Constitution that would strip an American of his citizenship if he accepted a title of nobility from a foreign nation.
Titles of Nobility Amendment, proposed amendment to the United States Constitution sponsored by Sen. Philip Reed of Maryland in 1810
Another argument is a missing amendment to the Constitution, known as the Titles of Nobility Amendment, which precedes the current Thirteenth Amendment.
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Another tax protester argument is that a 'missing' Thirteenth Amendment to the Constitution known as the Titles of Nobility Amendment or "TONA" precedes the current Thirteenth Amendment; the missing amendment purportedly would have divested the citizenship of any person receiving a title of nobility.
There is speculation that the Congress proposed the amendment in response to the 1803 marriage of Napoleon Bonaparte's younger brother, Jerome, and Betsy Patterson of Baltimore, Maryland, who gave birth to a boy for whom she wanted aristocratic recognition from France.
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Upon approval of a resolution offered by U.S. Senator Philip Reed of Maryland, during the 2nd Session of the 11th Congress, TONA was submitted to the state legislatures for ratification.
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The marriage had been annulled in 1805—well before the amendment's proposal by the 11th Congress.
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