.) 485-487; Watson, Trial of
Jefferson Davis (1915) 25 Yale L.J. 669. Philippine insurrections:
United States _v._ Magtibay, 2 Phil. 703 (1903), United States _v._ De
Los Reyes, 3 Phil. 349 (1904) (mere possession of rebel commissions
insufficient overt acts; strict enforcement of two-witness requirement;
convictions reversed); United States _v._ Lagnason, 3 Phil. 472 (1904)
(armed effort to overthrow the government is levying war). United States
_v._ Fricke, 259 F. 673 (1919) (acts "indifferent" on their face held
sufficient overt acts). United States _v._ Robinson, 259 F. 685 (1919)
(dictum, acts harmless on their face are insufficient overt acts).
United States _v._ Werner, 247 F. 708 (1918), affirmed in 251 U.S. 466
(1920) (act indifferent on its face may be sufficient overt act). United
States _v._ Haupt, 136 F. (2d) 661 (1943) (reversal of conviction on
strict application of two-witness requirement and other grounds;
inferentially approves acts harmless on their face as overt acts).
Stephan _v._ United States, 133 F. (2d) 87 (1943) (acts harmless on
their face may be sufficient overt acts; conviction affirmed but
sentence commuted). United States _v._ Cramer, 137 F. (2d) 888 (1943).

[738] 343 U.S. 717.

[739] Ibid. 732. For citations on the subject of dual nationality, _see_
ibid. 723 note 2. Three dissenters asserted that Kawakita's conduct in
Japan clearly showed he was consistently demonstrating his allegiance to
Japan. "As a matter of law, he expatriated himself as well as that can
be done." Ibid. 746.

[740] Ex parte Bollman, 4 Cr. 75 (1807).

[741] United States _v._ Burr, 4 Cr. 470 (1807).

[742] Cramer _v._ United States, 325 U.S. 1 (1945).

[743] Haupt _v._ United States, 330 U.S. 631 (1947).

[744] Ex parte Bollman, 4 Cr. 75, 126, 127 (1807).

[745] 12 Stat. 589. This act incidentally did not designate rebellion as
treason.

[746] Miller _v._ United States, 11 Wall. 268, 305 (1871).

[747] Wallach _v._ Van Riswick, 92 U.S. 202, 213 (1876).

[748] Lord de la Warre's Case, 11 Coke, 1 a. A number of cases dealt
with the effect of a full pardon by the President of owners of property
confiscated under this act. They held that a full pardon relieved the
owner of forfeiture as far as the Government was concerned, but did not
divide the interest acquired by third persons from the Government during
the lifetime of the offender. Illinois Central R. Co. _v._ Bosworth, 133
U.S. 92, 101 (1890); Knote _v