Only once before. in the case of Lafayette. has Congress been moved to such a unique expression of public sentiment. However. strictly speaking. Lafayette did not become an American citizen by act of Congress. He was first made a citizen of the States of Maryland and Virginia. before the Constitution was ratified and the Federal Congress established. At that time. the individual States could establish their own naturalization rules. Later. these State acts were accepted as part of the Federal law. If there has ever been a case since then for a foreigner to receive exceptional honor here. it would seem to be now with Winston Churchill.
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naturalization