817.041/3: Telegram

The Secretary of State to the Minister in Nicaragua (Eberhardt)

120. Your 184, July 31, 4 p.m. The Department perceives no occasion now to question on the grounds of de facto character of courts legality of acts of Supreme Court or Court of Appeals whose judges were replaced by de facto authorities. Your citation to Cooley considered in point. See also volume one, Moore’s Digest, page 54, et seq.

Kellogg