evidence: Navassa is the only guano island now in dispute. Sixteen Haitian constitutions through the past century and a half all lay claim to the island. Although Haitian President Rene Preval has yet to publicly renew his nation’s protest over Navassa, his government directed its Miami-based legal advisor, Ira Kurzban, to build Haiti’s legal case. [...] Haiti again formally protested in 1872, after the United States ceded two guano islands it had occupied to the neighboring Dominican Republic. Haiti insisted that Navassa was an identical case, and it backed the claim with documents showing that the island was part of the territory Spain ceded to France in 1697 and French King Charles X conceded to Haiti when his nation finally recognized its independence in 1825. [...] Yet the State Department review also cited interpretations of the Guano Islands Act that tended to favor Haiti’s claim. There was a 1905 State Department letter to a prospective buyer of Navassa: "This government possesses no territorial sovereignty over the island of Navassa." And a 1907 memo by the department’s solicitor general stated: "It is maintained that the United States has not surrendered jurisdiction over Navassa under the Guano Act, but that it could not say Navassa ‘belongs’ to the United States."