Eight people have been so honored, six posthumously, and two, Sir Winston Churchill and Saint Teresa of Calcutta, during their lifetimes.
In the other cases, an Act of Congress was passed authorizing the President to grant honorary citizenship by proclamation.
[9] In 1803, President Thomas Jefferson wrote that he would have offered to make Lafayette governor of Louisiana, had he been "on the spot".
[10] In 1932, descendant René de Chambrun established his American citizenship based on the Maryland resolution,[11][12] although he was probably ineligible for the distinction, as the inherited citizenship was likely only intended for direct descendants who were heir to Lafayette's estate and title.
Private bills are, on rare occasions, used to provide relief to individuals, often in immigration cases, and are also passed by Congress and signed into law by the president.