1870-November-10: A new territorial dispute emerged when Haitian Minister Preston asked Secretary Fish to recognize Haiti’s title to the Island of Navassa.

1870-November-10: A new territorial dispute emerged when Haitian Minister Preston asked Secretary Fish to recognize Haiti’s title to the Island of Navassa. Haiti sought jurisdiction over the small island—located between Haiti and Jamaica—to break up “smugglers’ camps” operating there. The island had been claimed by Peter Duncan, an American citizen, in 1857 under the Guano Islands Act, which protected Americans who discovered guano deposits on unoccupied islands. This initiated a legal battle over whether the island had ever been “actually occupied” by a sovereign power prior to the arrival of American guano miners.