London, December 10, 1937

According to this article, Wallis Simpson was ranked 29th lady of the land, although her husband was the 4th gentleman of the land; however, a Time Magazine article published December 20th, 1937 stated that:

Exactly one year after Edward VIII’s abdication appeared last week a new edition of Burke’s Peerage, ranking the Duchess of Windsor in England as the 33rd Lady in the Land, ranking the Duke 4th (i.e., after his three brothers). It was next discovered last week that the new Debrett’s Peerage, an equally standard work, ranks the Duchess as 8th Lady. Consulted about this discrepancy, the Royal College of Arms this week inclined to agree with Debrett’s, but weaseled by declaring “only the King is able to state the exact position.”