I find that James Beattie has a brief discussion of the Aristotelian category of echein/habitus, in his work, Theory of Language, Part II, Chapter II. In context, he's looking at adverbs, and he considers a possible way that had been proposed of categorizing adverbs in terms of Aristotle's categories. He goes through the categories briefly, assigning adverbs, and notes that there's no obvious English adverbs for the category of habitus, although he recognizes that this doesn't mean you couldn't have any, and he even gives a hypothetical example of how a particular etymology, if it had gone a different way than it actually did, might have delivered one. (Our contemporary English perhaps gives an actual example, in nattily.) Then he has a slight digression discussing the category itself:
By the by, I cannot see, for what purpose Aristotle made a separate category of the tenth; for to me it seems included in some of the preceding. A crown is as really a substance, as the head that wears it, and may last a thousand years longer . Or, if it is the having of the crown, or the being crowned, that distinguishes the category, as when we say, a crowned head, then crowned denotes a quality perceived by sense, and so belongs to the third predicament. Indeed this is not the only objection that might be made to the doctrine of the categories. Whoever treats of it in the way of detail, and without prejudice, will find, if I mistake not, that in some things it is redundant, and in others defective.
This is unsurprising -- Beattie, like many early modern philosophers, has a dislike for 'the schoolmen'. The substance argument is very much the one later given Bentham, although Beattie has perhaps more justification for it -- when he defined the category originally, he said that it "denotes something additional and exterior to a substance, but not a part of it" (pp. 159-160), whereas Bentham is purportedly deriving his discussion from Sanderson but ignores Sanderson's explicit definition of the category in terms of adjacency.
But Beattie is also in many ways a more educated man than Bentham, and unlike (apparently) Bentham was directly familiar with Aristotle himself, and so he considers a more adequate way of thinking of it, in terms of "the having" (the literal meaning of echein) of the other substance. His suggestion that in that case it should be reduced to quality (the third predicament, counting substance and quantity as the first two) is interesting. There is of course a form of quality that shares a cognate name with the tenth category -- hexis, or acquired disposition (translated into Latin with the same word for this category, habitus), is derived from one of the forms of echein -- so this is not implausible. (And makes clear that, despite the fact he's not making a show of it, Beattie's argument is informed by his familiarity with the actual Greek.) There is in fact a very good modern article -- Abraham Edel's 1975 "Aristotle's Categories and the Nature of Categorial Theory" (I highly recommend it) -- that proposes something of the kind, leaning very heavily on the etymology.
Nonetheless, I think this is fairly certainly a mistake. Being crowned is not really all that much like being skilled or virtuous (the most obvious forms of habitus in the quality sense), and Beattie's particular assumption that being crowned is a 'sensible quality' is probably related to the fact that as a Scottish common sense theorist he has a very broad interpretation of what counts as a 'sensible quality'. Obviously being crowned is not immediately sensible in the way that being red is; you have to have an intellectual understanding of what a crown is to see that someone is crowned.
What is true is that we sometimes treat being skilled, or virtuous, or red, or any kind of quality possession, on the model of being clothed. This is, again, a metaphorical use, and presumably happens because vestment is more sensible and imaginable than quality possession. (And there are sometimes direct connections. We can wear utility belts and other useful things, for instance, and these are things that can be instrumental to skill, and thus, in actual use, expressions of skill.) We can use vestment as a model for any kind of having, and we especially use it as a metaphor for contingent having (i.e., where what is had is something acquired, or something that depends on particular circumstances); even though the senses of 'having' are themselves very far from being univocal.
