14. Clen V. Jorgensen, 265 F. 120 (3d cir 1920).


15. 35 Opinions Att'y General 104 (June 24, 1926). The opinion denied that the
 Colonial Council of St. Croix had authority to pass on the qualifications of Council
 members appointed by the Governor.

 16. Luther Evans, 53.

 17. Even the local codes of 1920-1921, formulated by the Navy government to
 Americanize the legal system of the Virgin Islands, assumed that the transfer
 brought U.S. citizenship to the Islanders. A juror was required by the codes, for
 example, to be either a citizen of the municipality in which re resided, or a citizen
 of the United States. Luther Evans observed that this provision, "was based on
 the assumption that the treaty of cession granted United States citizenship to the
 inhabitants of the Virgin Islands, except when the choice of retaining Danish
 citizenship was excercised." Luther Evans, 216.

 18. The constitutionality of this provision, when proposed, was subject to Senate
 debate revolving about the status of the Islands; see Boyer, Civil Liberties, p. 49.
 Until 1940, there was considerable agitation to abrogate this provision. The levy
 of $8 per ton was reduced to $6 per ton by the Act of February 25, 1927, 44 Stat.
 1234. In 1941, the Municipal Council of St. Croix repealed this sugar export tax,
 under the authority of the governor; Annual Report of the Governor of the Virgin
 Islands. 1942, 3.

 19. See, e.g., William W. Boyer, "Rothschild Francis and Freedom of the Press in the
 United States Virgin Islands," paper presented for the Symposium
 Commemorating the 100th Anniversary of the Birth of Rothschild Francis (1891-
 1927), at the University of the Virgin Islands, St. Thomas, USVI, October 1, 1991;
 submitted to Caribbean Affairs for 1992 publication. See, also: Boyer, America's
 Virgin Islands, ch. 6.

20. 44 Stat. 1234 (1927).

21. See, e.g., Samuel S. Shipley, "Our Naval Autocracy in Samoa," The Nation,
 March 15, 1922, pp. 309-311. For an eyewitness account of "the rejoicing and
 emotion of the people on this occasion," see Letter to the Editor from Adolph
 Gereau, St. Thomas, March 3, 1927, in The New York Times, 20 March 1927, sec.
 9,16.

22. 47 Stat. 336 (1932).

23. Executive Order No. 5566, February 27, 1931.

24. Luther Evans, 282-283.