At the time the Constitution was drafted and ratified, and continuing thereafter courts in England and the United States applied the rule that ” when a document is required by the common law or by statute to be “signed’ by a person, a signature of his name in his own proper or personal handwriting is not required.” Finnegan v. Lucy, 157 Mass. 439, 440 (1892) (noting that this rule “‘was and still is very generally held”; collecting early English and American authorities); see also id at 443 (“Signing does not necessarily mean a written signature, as distinguished from a signature by mark, by print, by stamp, or by the hand of another.”). Rather, under the “principle of signatures,”‘ the common law recognized that one could sign a document not only with one’s own hand, but also by the hand of another who was properly authorized to affix one’s signature to the document on one’s behalf or who did so in one’s presence, Furthermore, a document signed in one’s name by the hand of another in either of these manners was equally effective as a document signed with one’s own hand°
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