Clara Burkhardt never went through the naturalization process.  Under the 1855 law, an immigrant woman instantly became a U.S. citizen at the moment a judge's order naturalized her immigrant husband. If her husband naturalized prior to September 27, 1906, the woman may or may not be mentioned on the record which actually granted her citizenship. Her only proof of U.S. citizenship would be a combination of the marriage certificate and her husband's naturalization record.