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Don't have a definite answer for you, but I've got plenty of doubt. I'm not 100% sure when 3 Stat. was last current, but Wheaton's was published between 1816 and 1827, and there've been significant changes in the law since then.
Not saying it isn't still true, and it seems like a sensible proposition on principle...just saying an early 19th century footnote doesn't give me much confidence that it is true, especially given how broad a statement it is.
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