133 U.S. 258 (1890), argued 23 Dec. 1889, decided 3 Feb. 1890, by vote of 9 to 0; Field for the Court. T. L. Riggs, a U.S. citizen, died intestate, leaving as heirs family members who included both American and French nationals. The French descendants claimed, as part of their inheritance, property located in Washington, D.C. But the American heirs argued that the local law of Maryland, which the Federal District had incorporated, prohibited the descent of real estate to aliens. The issue was: could French aliens inherit from a U.S. citizen land situated in a U.S. territorial jurisdiction such as the District of Columbia?
After losing in the lower federal court the aliens appealed to the Supreme Court. Their argument was that a provision of an 1853 treaty between the United States and France permitted the descent of real estate to French nationals in “all states” whose local law so permitted. In addition, though it made no specific reference to Frenchmen, another treaty of 1800 governing Washington, D.C., had displaced the property law incorporated from Maryland. The Americans countered, however, that the District of Columbia was not a “state” within the meaning of the 1853 treaty.
Justice Stephen Field's opinion held that for purposes of the treaty a “state” was any political entity with an established government, including Washington, D.C. Reasoning that the American litigants’ interpretation of the treaty would result in discrimination against aliens and jeopardize reciprocity between the United States and France, the Court held that the French heirs could inherit property in the District of Columbia.
The decision expanded the right to transfer property and the rights of aliens primarily in Washington, D.C. But the precedent also applied if ambiguity existed in a particular state's law.