Territorial circuit courts were held to have jurisdiction to naturalize even before the general naturalization act of June 26, 1906, which clearly conferred such jurisdiction: 17 H. 295; 211 U.S. 146. The first paragraph of this § as originally enacted (see RLH 1935) may have been unconstitutional because not "an uniform rule:" 162 Fed. 470; it has been repealed by implication by the general naturalization act above referred to: Id, overruling 3 U.S.D.C. Haw. 191, and it was specifically repealed Oct. 14, 1940. Referred to in 13 H. 21. See §4 and note thereto; also citizenship and immigration cases in note to RLH 1955, §57-43.

Certificates of naturalization granted by the U.S. District Court for Hawaii between January 1, 1919 and July 1, 1922, validated "insofar as failure of the record to contain final order under the hand of the court is concerned" by the Act of June 29, 1938, c 822, 52 Stat 1249. Referred to in 236 F.2d 622.