The Green Mountain Insurgency: New York’s Rebellion Against the Crown

The pre-Revolutionary War history of Vermont centered on a border dispute between the colonies of New York and New Hampshire. It is a complicated but colorful history, one that has been populated through the years with stories of greedy royal governors, show trials by corrupt provincial officials, land hungry settlers, shady land speculators, lawless vagabonds and bandits, and the birth of a paramilitary militia group the world would come to know as the Green Mountain Boys.

The Crown’s 1764 border ruling set the New York border at the Connecticut River, but failed to address the issue of New Hampshire land titles already issued in the region. New York immediately acted on their perceived authority by invalidating New Hampshire townships and the individual claims of all title holders, and required re-petitioning to New York for confirmation of their claims, including payments for new surveys, patenting fees and higher quit-rents. The settlers in the region initially sought confirmation of their New Hampshire titles and townships with New York, but their perception of inequitable and coercive requirements prompted a direct appeal to the Crown (1766 petition) and resulted in relief from the Crown (instructions and orders in 1767). It is that relief that the settlers rationally relied upon, and that reliance would soon place them in the crosshairs of New York’s provincial government and wealthy, landed elite. The Ejectment Trials represent the moment when New York formally imposed this jurisdictional opposition to the Crown upon eighteen long-time settlers.

An Issue of Equitable Title Interests, Not a Disputed Border

This contest was no longer a border dispute after the 1764 border ruling, as the New Hampshire government did not take any official action to contest the ruling. While there were accusations—and some evidence—of conniving behind the scenes by officials to prompt the settlers to seek re-annexation to New Hampshire, those clandestine efforts were likely motivated by a desire to maximize the value of the proprietary interests of those who were beneficiaries of the corrupt Gov. Benning Wentworth. Because the border was not officially in dispute, the appointment of a border commission, such as those appointed in New York’s disputes with Massachusetts and New Jersey, was not appropriate.

The Crown’s 1764 border ruling failed to address the issue of New Hampshire land titles already issued in the region, and at the heart of the dispute after the border ruling was how to resolve the equitable interests of those already settled and those with interests in New Hampshire titles. After invalidating New Hampshire titles, in 1765 New York issued conflicting land patents in the western region of the Hampshire Grants from Bennington north to Manchester. While open to confirming certain townships and individual settlers’ lands, a new ancient border was unilaterally declared which precluded confirmation of western townships that conflicted with the newly re-patented lands there. The 1765 patents and the newly declared ancient border became permanent obstructions for the residents of the western townships, and this area would become the focal point of settler resistance.

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No Allies in New York or New Hampshire

While settlers faced the threat of losing their improved and settled lands, there were many other parties interested in these lands. In New York, James Duane and Attorney General John Tabor Kempe had been beneficiaries of the first New York patent in the region after the border ruling, and had already incurred significant costs in surveying the land and paying patent fees in anticipation of a recurring stream of income from tenant farmers and land sales. Many of the politically connected and wealthy elite of New York petitioned for more tracts of land as interest in the region increased. Numerous veterans of the recent war had received land grants in the region as compensation for their service, and interests of non-settling veterans were marketed to and sought by connected New Yorkers.

The vast majority of the settlers who later became defendants in the Ejectment Trials had settled on their land prior to the announcement of the border ruling, and they had neither the financial resources nor the political connections to contend with the powerful forces which aligned against them. Most of their wealth and that of their fellow settlers had been created by their efforts in carving out farms and homes in this remote frontier region, and they lacked the financial ability to fund a vigorous defense of their cases. They had essentially been abandoned by the official New Hampshire political establishment, who only connived behind the scenes for re-annexation to maximize the value of their own titles in the region. Most settlers were interested only in their own plot of land, and were uninvolved in the speculative market for New Hampshire titles that subsequent actors like Ethan Allen and his kin would seek to profit from. They had no official agents in London acting in their interest, unlike the provincial government of New York, whose agent Robert Charles resided in London and actively lobbied New York’s position before the Crown. Their appeals to the king were not relayed through official channels by royal officials, but instead carried by their own to the courts of London, where they tried to form unofficial alliances to guide and assist them in their quest for confirmation of their titles.

The Crown Asserts Jurisdiction in Resolution of Title Issues

While the Crown initially failed to provide any direction regarding the title disputes created by the border ruling, this deficiency was corrected by late 1766 after New York had taken a series of aggressive actions to co-opt the rights of those with New Hampshire titles. In a December 11, 1766 letter, Lord Shelburne instructed New York Governor Sir Henry Moore to “take care that the Inhabitants lying Westward of the Line, reported by the Lords of Trade as the Boundary of the Two Provinces be not molested on account of Territorial differences, or disputed jurisdiction for whatever Province the Settlers may be found to belong to, it should make no difference in their Property, provided that their Titles to their Lands should be found good in other Respects or that they have been long in the uninterrupted Possession of them.”^[1]

The Crown was asserting royal jurisdiction over the dispute in directing the government of the Royal Colony of New York to honor the settlers’ property claims under New Hampshire titles. Adding the weight of the king’s authority to clarify any ambiguities, Shelburne subsequently wrote “His Majesty’s Intentions are so clearly expressed to you in the above Paragraph that I Cannot doubt of your having immediately upon receipt of it removed every cause of those complaints which the Petitioners set forth. If not it is the King’s express command that it may be done without the smallest delay.”^[2]

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Shelburne clarified and expanded the Crown’s jurisdiction over the dispute in his April 11, 1767 letter to Moore. In addition to another order constraining New York in their treatment of the settlers, the Crown halted New York land grant authority in the contested region: “I am to signify to you His Majesty’s Commands that you make no new Grants of these Lands and that you do not molest any person in the quiet possession of His Grant, who can produce good and valid Deeds for such Grant under the Seal of the Province of New Hampshire until you receive further orders respecting them.”^[3] The prohibition of granting authority was restated in the King’s Order-in-Council dated July 24, 1767, with the further admonition that violations would be met with the “Pain of his Majesty’s highest displeasure.” The order stated that this prohibition would stay in place “until his Majesty’s further Pleasure shall be known.”^[4]

The tone and tenor of these orders made clear that the Crown had asserted its jurisdiction in the region, by both compelling and constraining New York in interactions with the settlers and in granting activity. These explicit orders provided a reasonable basis for the settlers to believe they would receive fair treatment in the resolution of their land claims, and that it would be the Crown and not New York that would resolve the dispute. The equitable interests of all parties demanded careful review and prioritizing of the various claims, a task the Board of Trade had undertaken.

Jurisdictional Compliance to Crown turns to Disobedience

When Governor Moore received the July 1767 Order-in-Council he immediately ceased all granting of lands in the Hampshire Grants region, an action that caused significant friction with the New York establishment. Many asserted the order prohibited only conflicting grants and did not extend to lands not previously granted by New Hampshire. In correspondence with Lord Hillsborough just one month before his death, Moore shared the difficulties he encountered with his constituents because of his correct interpretation of this order:

When His Majesty’s order in Council was first sent over by the Earl of Shelburne forbidding any further grants to be made of the Lands in question it was the general opinion here, that the restriction was only intended to be laid on the granting of any patents which could possibly affect the particular Townships, set forth in Robinson’s Petition; I took His Majesty’s order in a greater latitude, & notwithstanding the repeated attacks made upon me, as well by reduced officers and disbanded Soldiers, as by the Inhabitants of this Province, I have constantly refused to comply with their demands although the Lands for which they applied had never been granted by the Government of N. Hampshire, or included in the above mentioned Petition.^[5]

Moore was no friend of the settlers on the Hampshire Grants; prior to the Crown’s interdiction, he had followed prior policies of New York that invalidated New Hampshire titles, and demanded settlers to pay a second time for surveys and patent fees. He had instituted a program forcing all claimants to travel or send attorneys to New York City—instead of more convenient Albany—to prove their New Hampshire interests in order to receive the opportunity to pay a second time to have their interests confirmed. While he confirmed six eastern townships—with required payments and higher quit-rents—he also declared a new ancient border of New York that eliminated any possibility of western townships being confirmed “for 21 of these [townships] being indisputably within the former Limits of this Province before His Majesty’s Proclamation in regard to New Hampshire and the only Settlements made on any of those twenty one Townships are Intrusions.” [6] He took great umbrage to the settlers’ 1766 petition, reserving particular invective for Samuel Robinson, the representative of the settlers who carried the petition to London. Expressing a social superiority common among the New York elite, Moore demeaned Robinson with a condescending reference to what he understood his military service had been: “How else should a Man of one of the lowest and meanest Occupations at once set up for a Statesman and from a Notion that the wheels of Government are easily managed and conducted as those of a Waggon, take upon him to direct the King’s Ministers in their Departments.”[7]

But while Moore had no particular regard for the settlers, he had a great deal of respect for the office of governor and for loyalty to the Crown. During this period of acquiescence to the Crown’s authority, no ejectment actions were initiated by New York patent holders, demonstrating that Moore’s administration was following the instructions from the Crown not to harass the settlers over their titles. As Moore continued to resist more aggressive New York factions, Kempe’s letter to Duane on April 16, 1768 is demonstrative of the growing frustration with this constraint: “I wish something was done about our Princetown Lands—our interest grows worse every day by the number of Enemys settled on them.”^[8]

The status quo (no harassment of settlers, no land grants) in the region continued until September 11, 1769, when Governor Moore unexpectedly died after a three week illness. Over the next sixty days, a series of New York actions would overturn the compliance to the Crown’s orders and instructions that had been demonstrated since 1767. In October ejectment suits were filed against seventeen settlers in Bennington, Shaftsbury, Sunderland, Arlington, and Manchester, actions prohibited by 1767 Crown instructions which still remained in place.[9] In the same month, the New York Council provided an interpretation of the 1767 Order-in-Council that the land granting restriction applied only to overlapping grants, an interpretation used by successive governors to justify further grants of land.[10]

This act of Council was factually flawed, for whatever ambiguities that may have existed in the order had been made clear by the Crown. The prohibition applied to the entire Hampshire Grants region, as Governor Moore understood and correctly applied, Lt. Gov. Cadwallader Colden was specifically told,^[11] and which became order No. 49 for future governors of New York.^[12] In 1772, the Board of Trade reiterated that the granting prohibition always extended to the entire region, not just overlapping grants:

Upon a full hearing of those Complaints His Majesty was pleased by his order in Council of the 24 of July 1767 to declare that no part of Lands lying on the Western side of the River Connecticut, within that district before claimed by New Hampshire should be granted until His Majesty’s further pleasure was known and an Instruction was accordingly given to the Governor of New York directing him upon pain of His Majestys highest displeasure not to presume to make any Grant whatever or to pass Warrants for the Survey of any part of the said Lands until His Majesty’s pleasure should be signified concerning the same which Instruction has been ever since continued in force and now forms the 49th article of the Code of General Instruction given to Mr. Tryon His Majesty’s present Governor of New York.^[13]

These actions by New York after Moore’s death opened the door for further granting of land in the region, which first focused on non-conflicting grants, but eventually evolved into widespread grants of lands overlapping New Hampshire townships.

New York would further assert that the Crown lacked authority to resolve the title disputes. Gov. William Tryon, in a 1773 letter to Lord Dartmouth asserted, “I understand it, My Lord, to be a question of Law between the Patentees of both Governments whose is the best title? and that they are obstinate in their claims it must receive a determination in the Courts of Justice. Certainly, both Governments had not authority to issue grants of the same Lands.”[14] An expanded view of New York’s jurisdictional argument was outlined by Attorney Robert Yates in a letter to James Duane just after the Breakenridge stand-off in July 1771. Yates had asked some settlers assembled

whether they acknowledged at present the New York jurisdiction. They did. Whether they acknowledged themselves loyal subjects to his present majesty, this they also readily acknowledged. Whether it did not flow as a necessary consequence from these principles that they should peacefully acquiesce in the determination of the courts instituted by his majesty for the distribution of justice. To this they gave an evasive answer by observing that they had their grants from New Hampshire and that any controversy about the validity of these grants could only be determined by his majesty.

He then outlined the New York argument that the king lacked the authority to resolve the title dispute; “I observed to them the extreme absurdity of such an expectation for that I acknowledged it was in his majesty’s power to alter, establish or change the jurisdiction as often as he pleased but that the right of soil when once his majesty had divested himself from the same, and any dispute should arise between subject and subject about that right, it could only be determined by the courts of justice where such controversies arose.”[15]

But within this same conversation the settlers made clear they were aware the Board of Trade in London was busy working on a comprehensive resolution of the title disputes in the contested region. They told Yates “they had from their agent in England Lately received the strongest assurances that their Differences would soon be Determined in their favor.”[16] The settlers’ intelligence was correct, as the board had just issued its first report to the Privy Council which was largely in their favor. Yet the settlers’ reliance on the Crown for resolution of their land titles was mocked by the Yorkers who demeaned them as “delusional” in their claims.

No Delusion—The Crown Admonishes New York in the Strongest Terms

The Board of Trade’s first report to the Privy Council in 1771 regarding the respective claims in the region recommended that all settlers under New Hampshire titles be confirmed in their possessions with no additional payments, other than those whose titles overlapped antecedent New York patents. [17] The board made the post-1764 military patents subservient to the claims of the settlers, with veterans offered land elsewhere if their claims overlapped. The board even recommended that New Hampshire claimants who had not settled be given the opportunity to claim up to 500 acres. Most significantly to the New York landed class, none of the conflicting non-military patents in the area were to be validated or recognized. This recommendation would have essentially nullified the results of the Ejectment Trials.^[18]

Continued abusive grants of land, the settlers request for re-annexation to New Hampshire, and continuing disturbances in the Grants put the issue back in front of the Board of Trade again in 1772. With the 1771 proposal now deemed impractical, the board went even further and recommended the confirmation of all New Hampshire townships that did not conflict with antecedent New York grants. The 1772 report added the condition that antecedent New York patents however would be subject to challenge for failure to meet patent requirements of settlement. Non-conforming circumstances were the pretense for the surveying activity of Walloomsac in October 1769.

These reports also offered harsh indictments of New York actions in contravention of the Crown’s instructions throughout this entire episode. Criticisms were wide-spread over a variety of issues. First and foremost, the board issued a scathing indictment of New York’s conflicting land patenting activity: “Proprietors of Lands in the Townships granted by the Gov^r of New Hampshire who have bona fide made actual settlement and improvement thereon have sustained great injury and suffered great oppression by the irregular conduct of the Gov^r and Council of New York in granting Warrants of Survey for Lands under such actual Settlement and Improvement”^[19] This finding was made more than a year after the first Ejectment Trials concluded.

The board harshly criticized the exorbitant fees charged by New York; that state had “taken and do now exact considerably more than double what that ordinance allows.” The fees were so great that “the whole amount of these fees upon a Grant of one thousand acres of Land is in many instances not far short of the real value of the fee Simple.”^[20] The board further indicated “we can by no means recommend to your Lordships to advise his Majesty to suffer the Governor and Council of New York to dispose of the said Lands either upon the terms or in the manner in which they have hitherto exercised that power.”^[21] This lack of institutional trust led the board to advise the Privy Council that “we are of opinion that the Instructions to be given to the Governor of New York in the latter case cannot be too explicit and precise in order to guard against those irregularities & abuses which we are concerned to say have but too much prevailed in the exercise of the powers given to his Majestys [governors] in America, for the granting of lands to the great prejudice of his Majestys interest to the discouragement of Industry and many Instances to the apprehension of the subject by the exaction of exorbitant & unreasonable Fees.”^[22]

There was also an admonishment that Duane and Kempe certainly felt personally. The device by which they circumvented the 1,000 acre per person limit in obtaining their interest in the Princetown Patent was specifically criticized, adding to the list of abuses highlighted by the Crown: “His Majesty’s Governors of New York have of late years taken upon themselves upon the most unwarrantable pretences to elude the restrictions contained in His Majestys Instructions with regard to the quantity of Land to be granted to any one person and to contrive by the insertion in one grant of a number of names either fictitious or which if real are only lent for the purpose to convey to one person in one Grant from twenty to forty thousand acres of Land an abuse which is now grown to that height as well to deserve your Lordships attention.”^[23] Lord Hillsborough used the strongest language in referring to this practice as “an abuse of so gross and fraudulent a nature as deserves the severest Reprehension, and it is highly necessary, both for the interest of the Crown and for the dignity of his Majesty’s Government that some effectual measure should be taken to put a stop to it.”^[24]

Shelburne’s letter of April 1767 provides the lens through which the Crown viewed the land granting authority it delegated to its royal governors, and the expectations for New York in this dispute: “The Power of Granting Lands was vested in the Governours of the Colony originally for the purpose of accommodating not distressing setlers especially the poor and industrious.”^[25] The Crown repeatedly found the actions of New York after the border ruling violated this basic premise of sound governance. In doing so, the Crown clearly and consistently gave the settlers reasonable hope that their claims would be given fair treatment, and issued instructions, orders, and rulings favorable to the settlers’ claims. The Crown strongly censured New York’s behavior, with scathing indictments of abuses combined with the proposed nullification of all conflicting land patents issued after the border ruling, including Duane and Kempe’s Princetown Patent.

New York’s Continued Defiance

New York Governor William Tryon was informed of “his Majesty’s further pleasure” for resolving the title disputes in the Hampshire Grants in an April 10, 1773 letter from Lord Dartmouth. Based upon the December 1772 recommendations of the Board of Trade, this resolution was a repudiation of New York’s actions since the border ruling. While the settlers’ request for re-annexation to New Hampshire was denied, the ruling confirmed essentially all settled New Hampshire townships and as a result voided all conflicting New York patents issued since 1764.

With news of a nearly total defeat from London, Tryon encountered even more indignation than Moore had faced when he followed the Crown’s orders and instructions. In his response, Tryon declared that the proposed solution would be impossible to implement due to resistance from the landed elite of the province: “I cannot flatter myself with the slightest hope of procuring the concurrence of the Assembly of this Province in a scheme so repugnant to the claims of persons who from their numbers and connections have a very powerful influence in the Colony.”[26] Both the power and hypocrisy of the landed oligarchy was further highlighted in Tryon’s response to one specific finding of the board. One of the many New York attacks on the validity of the New Hampshire townships was the fact that many had not been settled and therefore failed to follow the requirements of their charters, making them invalid. New York patents had similar requirements for settlement, but with the board suggesting this requirement be enforced against New York patents, Tryon stated that “scarce any measure can raise a more general discontent in this Colony, than a Law to vacate Patents for nonsettlement—those of which the advantage might be taken are many, and the dread of a precedent of this kind will unite all the Landholders to oppose a project so alarming to their Interest”.[27]

Conclusion

The initiation of actions against the settlers in New York courts was in direct defiance of the Crown’s 1767 instructions not to harass settlers under New Hampshire titles. To justify its actions, New York would assert that the Crown lacked the authority to resolve the title disputes in this region. While acknowledging that the king had the power to establish jurisdictional borders, New York asserted that resulting title disputes must be resolved in its own courts. But while Yorkers demeaned settlers as “delusional” for their “absurd” reliance on the Crown, the Board of Trade in London was busy working on a comprehensive resolution of the title disputes in the contested region. The board’s 1771 report ignored the results of the Ejectment Trials, and proposed confirmation of settlers’ titles on lands not previously patented by New York:

for however disputable their titles may be upon the Ground of the Grants themselves yet there always has been & we think there always ought to be in the Plantations an attention to actual Settlement and Improvement, that in cases where the possession does not interfere with the Rights of others ought to have preference to any other consideration; and therefore we think, that persons under this description ought to be left in entire possession of such Lands as they have actually cultivated and improved subject to no other condition or reservation either of Quit-Rent or otherwise than what is contained in the Grants under which they claim.^[28]

This proposal would have essentially nullified the results of the Ejectment Trials, as seventeen of the eighteen defendants settled on lands not previously patented by New York as of the border ruling. The board’s 1772 report went further, proposing confirmation of most New Hampshire townships:

That, provided such townships do not include lands within the limits of some antecedent grant, upon which actual improvement has, at any time, been made, it would be advisable that they should be confirmed as townships, according to the limits expressed in grants thereof; and that all persons having possession of any shares in the said townships, whether as original grantees, or by purchase or conveyance, and upon which shares any actual improvement or settlement has been made, ought not, in justice, to have been, or to be, in future, disturbed in the possession of such shares; nor ought they to be bound to any other conditions, whether of quit rent or otherwise, than what is contained in the grant.^[29]

The board criticized the New York court actions, calling out the injustice of their stating the settlers “ought not, in justice, to have been . . . disturbed in the possession” of their land. Approved by the king, the findings of the board—which made known “his Majesty’s further pleasure” long anticipated by both sides—would be contested by New York, and the dispute would linger through the Revolutionary War and last until Vermont was granted statehood in 1791.

In an era of escalating colonial tensions between the citizenry and the Crown, it was the Royal Colony of New York that rebelled against the civil and political authority of the Crown, ignoring instructions and orders by initiating ejectment actions and resuming land grants. These acts of defiance attempted to remove the Crown from the title dispute, thereby escalating the conflict in a coercive and threatening manner against the settlers. This New York rebellion was launched not for the natural rights of all its citizens, but to preserve a class-based society predicated on a land policy that served the interest of the powerful while subjugating the poor. The settlers of the Hampshire Grants found the measures employed by New York to be intolerable, and would launch their own rebellion, not against their king and Parliament, but against the disobedient and obstinate provincial government of New York.

[1] Lord Shelburne to Governor Moore, April 11, 1767, in Edmund B. O’Callaghan, Documentary History of the State of New York, Vol. 4 (Albany: Charles Van Benthuysen, 1851), 589-590 (DHNY).

[2] Ibid.

[3] Ibid.

[4] Kings Order in Council, July 24, 1767, DHNY 4:609-610.

[5] Moore to Lord Hillsborough, August 10, 1769, DHNY 4:612.

[6] Moore to Shelburne, June 9, 1767, DHNY4:604. New York had never previously asserted any other eastern border besides the Connecticut River. This new ancient border appears to be the work of John Tabor Kempe, who described such a border as the eastern most point of the Walloomsac Patent in his report to Lord Dunmore in February 1771.

[7] Moore letter to Shelburne, 9-Jun-1767, DHNY 4:604.

[8] John T. Kempe to James Duane, April 16, 1768, Duane family papers, 1665-1916 (bulk 1756-1900). Series I: Correspondence, 1680-1853. Box 2, 1767-1772, New York Historical Society, American Manuscripts.

[9] James Breakenridge would later become the eighteenth defendant after a Proclamation for his arrest after the October 1769 surveying confrontation was issued. Notices of Ejectment were filed on behalf of George Clarke and Stephan DeLancey.

[10] DHNY 4:611.

[11] Hillsborough to Cadwallader Colden, December 9, 1769, in Edmund B. O’Callaghan, Documents Relative to the Colonial History of the State of New York, Vol. 8 (Albany: Weed, Parson and Company, 1856), 198 (DRCNY). “I likewise think fit to send you a copy of his majesty’s order in council, of the 24th, of July 1767, forbidding any grants to be made of lands annexed to New York by his majesty’s determination of the bound any of that colony and New Hampshire,” adding an injunction that he should not “on any pretense, presume to act contrary thereto.”

[12] Hiland Hall, The History of Vermont: From Its Discovery to Its Admission Into the Union in 1791 (Albany: J. Munsell, 1868), 99-100. Hall here referenced a February 7, 1771 addition to the orders to the Governor: “It is therefore our will and pleasure that you do take effectual care for the observance of said order in council, and that you do not upon pain of our highest displeasure, presume to make any grant whatever, or pass any warrant of survey of any part of the said lands, until our further will and pleasure shall be signified to you concerning the same.”

[13] Representation of the Board of Trade to the Lords of the Privy Council with a plan for the settlement of the difficulties respecting the New Hampshire Grants, December 3, 1772, DHNY 4:803 (emphasis added).

[14] William Tryon to Dartmouth, July 1, 1773, DHNY 4:838.

[15] Robert Yates to James Duane, July 20, 1771, Duane family papers, 1665-1916 (bulk 1756-1900). Series I: Correspondence, 1680-1853. Box 2, 1767-1772. Robert Yates to John Toberkouck [?] and James Duane, July 20, 1771, cdm16694.contentdm.oclc.org/digital/collection/p16124coll1/id/35302

[16] Ibid.

[17] The Board of Trade to the Lords of the Privy Council, June 6, 1771, DHNY 4:712.

[18] Only the claims against Breakenridge in the Walloomsac Patent would have been subject to review. The claims of Duane (Schlatter), Small and Princetown against the other seventeen settlers would have been nullified.

[19] Board of Trade to the Lords of the Privy Council, December 3, 1772, DHNY 4:803.

[20] Ibid.

[21] Board of Trade to the Lords of the Privy Council, June 6, 1771, DHNY 4:712.

[22] Ibid.

[23] Board of Trade to the Lords of the Privy Council, December 3, 1772, DHNY 4:803.

[24] Earl of Hillsborough to Tryon, December 4, 1771, DRCNY 8:285.

[25] Shelburne to Moore, April 11, 1767, DHNY 4:589-590.

[26] Tryon to Lord Dartmouth, July 1, 1773, DHNY 4:831.

[27] Ibid, 4:836.

[28] Board of Trade to Privy Council, June 6, 1771, DHNY 4:712.

[29] Board of Trade to Privy Council, December 3, 1772, DHNY 4:803.