One of his official acts as Consul deserves special mention. The war between the United States and England was still raging, when one day an American privateer came into the harbor of Tunis with three English East Indiamen loaded with valuable cargoes as prizes. The prizes and cargoes were turned over to the American Consul to sell at auction. The British Minister protested against such sale on the ground of a clause in the treaty with England which provided that no Christian power should sell a British prize or its cargo in an Algerian port. Noah admitted the _bona fides_ of the stipulation, but contended that under proper interpretation of international law the United States could not be held to be a Christian nation within the meaning of the treaty and hence was excepted from the inhibition. To prove his contention he exhibited the Constitution of the United States with its provisions against sectarianism and religious tests, and finally cited the Joel Barlow Treaty with Turkey of 1808, ratified by the United States Senate, which declared that the United States made no objections to Mussulmen because of their religion and that they are entitled to and should receive all the privileges of citizens of the most favored nations. This argument was sustained by the Bey and the prizes were accordingly sold in Tunis. Noah’s contention thus became established as a principle of international law which has never since been challenged. It was perhaps this stand taken by Noah in declaring the American nation to be non-Christian which convinced the government at home that his faith was “an obstacle to the exercise of his consular functions.” On his return to America Noah settled in New York (1816), where he resided for the rest of his life in the enjoyment of many honors and great popularity. He was successively the editor of the “National Advocate,” “New York Enquirer,” “Evening Star,” “Commercial Advertiser,” “Union” and “Times and Messenger.” In 1819 he published in New York his “Travels in England, France, Spain and the Barbary States” in which he described his experiences abroad, the services he had rendered to his government in Tunis and the manner in which he was requited. His occupation as a journalist, which brought him into frequent connection with the theatre, led him to return to dramatic authorship, and he was reputed to be one of the most popular American playwrights of his day. Most of his plays were based on American history, but some of them dealt with other themes, like his successful melodrama “Yousef Carmatti, or The Siege of Tripoli.” He also took an active part in politics, and was appointed High Sheriff of New York in 1822; but when the office was made elective a short time afterwards he was defeated after an exciting campaign. He was a supporter of General Jackson, and was later appointed by him Surveyor of the Port of New York.