Claim: Charles Fitzroy received the subsidiary titles of Earl of Chichester and Baron Newbury, then upon his mother's death in 1709, the 1st Duke of Southampton (a title in the Peerage of England) succeeded to her hereditary peerages.
Evidence: On the death of his mother in 1709, the Duke became also second Duke of Cleveland, by a special remainder in the grant of the dukedom which set aside his illegitimacy.