Kentucky Law Journal Volume 45 | Issue 3 Article 4 1957 Passports--A Modern Gordian Knot Melvin Scott University of Kentucky Follow this and additional works at: https://uknowledge.uky.edu/klj Part of the Administrative Law Commons, and the Constitutional Law Commons Right click to open a feedback form in a new tab to let us know how this document benefits you. Recommended Citation Scott, Melvin (1957) "Passports--A Modern Gordian Knot," Kentucky Law Journal: Vol. 45 : Iss. 3 , Article 4. Available at: https://uknowledge.uky.edu/klj/vol45/iss3/4 This Note is brought to you for free and open access by the Law Journals at UKnowledge. It has been accepted for inclusion in Kentucky Law Journal by an authorized editor of UKnowledge. For more information, please contact
[email protected]. NOTES PASSPORTS-A MODERN GORDIAN KNOT From 1796, the date of the first United States passport, until 1947, there were relatively few restrictions upon peacetime travel. During this period the main requirement for obtaining a passport was that one be a citizen or otherwise subject to the jurisdiction of the United States. Historically, the passport was a document, useful, but not essential, for traveling abroad. Its primary purpose was to facilitate travel.:' Early in the history of our country the practice of issuing pass- ports in time of peace was engaged in not only by the State Depart- ment, but also by state and local officials.2 As late as 1835 in the case of Urtetique v. D'Arcy, the Supreme Court said: There is no law in the United States, in any manner regulating the issuing of passports, or directing upon what evidence it may be done or declaring their legal effects.