[1] Lacombe was assigned by operation of law to additional and concurrent service on the United States Court of Appeals for the Second Circuit on June 16, 1891, to a new seat authorized by 26 Stat.

[2] In 1909, Lacombe reluctantly conferred American citizenship on Bhicaji Balsara, a Parsi thought to be the first Indian to become a United States citizen.

[citation needed] He was reluctant to confer citizenship as he reasoned that there "was much force in the argument that the Congress which framed the original act for naturalization of aliens ...intended it to include only white persons belonging to the races whose emigrants had contributed to the building up on this continent of the community of people which declared itself a new nation".

[citation needed] Lacombe only gave Balsara citizenship on the hope that the United States Attorney would indeed challenge his decision and appeal it to create "an authoritative interpretation" of the law.

[citation needed] As Lacombe felt if, the definition of 'free white persons' was to be extended ... it... [would] bring in, not only the Parsee... which is probably the purest Aryan type, but also Afghans, Hindoos, Arabs, and Berbers".

[citation needed] Lacombe wrote a letter to the New York Times advancing a conspiracy theory about the German sinking of the RMS Lusitania in 1915.