AuthorTitleCitationSummaryYearKeyTerm
Evan D. Bernick, Paul Gowder, Anthony Michael Kreis BIRTHRIGHT CITIZENSHIP AND THE DUNNING SCHOOL OF UNORIGINAL MEANINGS 111 Cornell Law Review Online 101 (23-Jul-25) This Essay critically surveys the recent debate surrounding birthright citizenship in the United States, particularly in light of arguments presented by legal scholars Randy Barnett, Kurt Lash, and Ilan Wurman. Under the guise of originalism, Barnett, Lash, and Wurman propose an ahistorical, revisionist interpretation of the Fourteenth... 2025 yes
Rebecca E. Zietlow FUGITIVES FROM SLAVERY, FREE BLACK ACTIVISTS, AND THE ORIGINS OF BIRTHRIGHT CITIZENSHIP 94 Mississippi Law Journal 1425 (2025) Introduction. 1426 I. Constitutional Structure and Fugitives from Slavery. 1429 II. Delany, Douglass and the Theory of Birthright Citizenship. 1432 A. Martin Delany. 1433 B. Frederick Douglass. 1435 C. Anti-Slavery Constitutionalism and Citizenship Rights. 1438 III. Black Activism for Citizenship Rights. 1440 A. Fugitives From Slavery and Free... 2025 yes
Anonymous MADE IN AMERICA: THE CONSTITUTIONAL GUARANTEE OF BIRTHRIGHT CITIZENSHIP 59 University of San Francisco Law Review Forum 32 (12-May-25) [W]e are a nation of immigrants. Unless you are one of the first Americans, a Native American, we are all descended from folks who came from someplace else .. The united states was built by immigrants, with its history deeply rooted in the diverse waves of people who have come from every corner of the world in search of new opportunities. Today,... 2025 yes
Jacob Hamburger THE CONSEQUENCES OF ENDING BIRTHRIGHT CITIZENSHIP 103 Washington University Law Review 209 (2025) On the first day of his second term in office, President Donald Trump issued an executive order purporting to deny citizenship to children born in the United States to undocumented parents. After numerous federal district courts enjoined implementation of the order, the Supreme Court's decision in Trump v. CASA, Inc. paved the way for it to go into... 2025 yes
Gregory Ablavsky , Bethany Berger "SUBJECT TO THE JURISDICTION THEREOF": THE INDIAN LAW CONTEXT 100 New York University Law Review Online 201 (October, 2025) Section 1 of the Fourteenth Amendment provides that [a]ll persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. Much of the debate over the meaning of this provision in the nineteenth century, especially what it meant to be subject to the... 2025  
Carol Nackenoff CASTE AND AMERICAN CITIZENSHIP IN THE TRUMP ERA 85 Maryland Law Review 178 (2025) Among the categories of individuals born in the United States and not subject to the jurisdiction thereof, the privilege of United States citizenship does not automatically extend to persons born in the United States: (1) when that person's mother was unlawfully present in the United States and the father was not a United States citizen or lawful... 2025  
Alexandra Fay CITIZENSHIP AND EMPIRE IN ELK v. WILKINS 102 Washington University Law Review 1839 (2025) In 1884, the Supreme Court held that the Fourteenth Amendment's guarantee of birthright citizenship did not apply to Native Americans. In Elk v. Wilkins, the Court denied John Elk the right to vote on the grounds that he was born a tribal member, not subject to the jurisdiction of the United States, and thus ineligible for citizenship. This Article... 2025  
Neoshia R. Roemer EQUITY FOR AMERICAN INDIAN FAMILIES 109 Minnesota Law Review 1713 (April, 2025) For the better part of two centuries, the cornerstone of federal Indian policy was destabilizing and eradicating tribal governments. In the process, federal Indian policy also dismantled American Indian families via child removal. Attempting to equalize American Indians through the practice of assimilation, decades of Indian child removal policies... 2025  
Carla D. Pratt INDIANNESS AS PROPERTY 105 Boston University Law Review 311 (February, 2025) This Article expands upon the seminal work by Cheryl Harris entitled Whiteness as Property by exploring the intersection of race and property through Indianness. Indianness has been constructed as a form of property conferring rights and privileges to its holders which this Article examines through the inertial relationship between race and legal... 2025  
Anthony M. Ciolli IVORY TOWER COLONIALISM 34 Boston University Public Interest Law Journal 41 (Winter, 2025) Introduction. 42 I. The Real-World Damage to the Territories Caused by Academia. 42 II. Borderlands Constitutionalism: Denying All Constitutional Rights to All U.S. Territories. 46 III. Borderlands Constitutionalism: Marginalizing the Indigenous People of the Territories. 50 Conclusion. 56 2025  
Neoshia R. Roemer REPRODUCING CITIZENSHIP 27 Georgetown Journal of Gender and the Law 31 (Fall, 2025) I. Introduction. 31 II. Reproductive Justice and the Order. 34 A. The Reproductive Justice Framework. 35 B. The Order and its Context. 38 C. The Mythical Immigrant: the Imagined Illegal Immigrant. 41 III. The Rights of Citizens (and Noncitizens). 46 A. The Right to Procreate and Parent. 48 B. The Right to Citizenship. 53 C. Defining Citizenship... 2025  
Amanda Frost PARADOXICAL CITIZENSHIP 65 William and Mary Law Review 1177 (April, 2024) C1-2Table of Contents Introduction. 1178 I. The Birth of Birthright Citizenship. 1181 A. The Civil Rights Act of 1866. 1182 B. The Fourteenth Amendment's Citizenship Clause. 1185 II. The Paradox of Universal Birthright Citizenship and Racially Exclusive Naturalization. 1187 A. Political Battles. 1188 B. Legal Battles. 1189 C. Immigration Battles.... 2024 Yes
Riley J. Gutierrez UNINCORPORATED: A CASE FOR AMERICAN SAMOA THROUGH THE FOG OF THE INSULAR CASES 18 Liberty University Law Review 641 (Spring, 2024) For over a century, American Samoa has been an unincorporated territory of the United States. Due to its unincorporated status, its inhabitants lack U.S. constitutional citizenship under the Fourteenth Amendment. Congress has further failed to pass legislation granting statutory birthright citizenship to American Samoans, setting American Samoa... 2024 Yes
Rebecca E. Zietlow ABORTION, CITIZENSHIP, AND THE RIGHT TO TRAVEL 27 Employee Rights and Employment Policy Journal 335 (5/31/2024) This article considers the changed landscape for abortion rights since the United States Supreme Court's opinion in Dobbs v. Jackson Women's Health. Before Dobbs, the right to choose an abortion was a fundamental right under federal law, enforceable against all state governments. After Dobbs, the scope of one's right to choose an abortion depends... 2024  
Evelyn Marcelina Rangel-Medina CITIZENISM: RACIALIZED DISCRIMINATION BY DESIGN 104 Boston University Law Review 831 (April, 2024) This Article advances the conceptual framework of citizenism to describe how citizenship is mobilized and weaponized to sustain structural racism. Citizenism transcends formal citizenship status because the construction of whiteness underwrites it as the only presumptively legitimate racial category for citizenship. A focus on citizenism provides... 2024  
Renee Nicole Allen CONTEXTUALIZING THE TRIGGERING EVENT: COLONIAL WHITE SUPREMACY, ANTI-BLACKNESS, AND BLACK LIVES MATTER IN ITALY AND THE UNITED STATES 33 Minnesota Journal of International Law 1 (Spring, 2024) In the summer of 2020, spurred by George Floyd's murder and amid a worldwide pandemic, Black Lives Matter demonstrations peaked in the United States. The viral nature of the police violence that caused Floyd's death was a triggering event for transnational Black Lives Matter protests. Around the world, millions took to the streets to demand... 2024  
Amanda Frost DRED SCOTT'S DAUGHTER: GRADUAL EMANCIPATION, FREEDOM SUITS, AND THE CITIZENSHIP CLAUSE 35 Yale Journal of Law & the Humanities 812 (2024) The Fourteenth Amendment's Citizenship Clause connected borders, birth, and egalitarian status to forge a new definition of U.S. citizenship, freed for the first time from constraints of race and lineage. This Article locates a forerunner to the Citizenship Clause in antebellum laws enacted by six northern states under which all persons born within... 2024  
Elizabeth Hidalgo Reese TRIBAL REPRESENTATION AND ASSIMILATIVE COLONIALISM 76 Stanford Law Review 771 (April, 2024) Abstract. There are 574 federally recognized domestic dependent tribal nations in the United States. Each tribe is separate from its respective surrounding state(s) and governs itself. And yet, none of them have the power to send representatives to Congress. Our democratic representative structures function as if tribal governments and the... 2024  
Deanna Salem BIRTHRIGHT CITIZENSHIP AND THE PLIGHT OF AMERICAN SAMOA 56 UIC Law Review 783 (Winter 2023) I. Introduction. 783 II. Background. 784 A. The Union between the United States of America and American Samoa (1900-1904). 785 B. The Insular Cases (1900-1922). 786 1. The Territorial Incorporation Doctrine Applied. 788 2. Reid v. Covert and the Impractical and Anomalous Standard (1957). 789 C. American Samoa: The Only U.S. Territory without... 2023 Yes
Angela R. Remus CAUGHT BETWEEN SOVEREIGNS: FEDERAL AGENCIES, STATES, AND BIRTHRIGHT CITIZENS 34 Stanford Law and Policy Review 225 (2023) The Fourteenth Amendment enshrines a commitment to birthright citizenship that extends to almost anyone born in the United States. While the federal government is the arbiter of questions of citizenship, the states are indispensable partners: State-issued birth certificates have long been the preeminent form of proof of birthright citizenship.... 2023 Yes
Hon. Ivan L. R. Lemelle AMENDING THE CONSTITUTION: IF NOT NOW, WHEN? 69 Loyola Law Review 367 (Spring, 2023) In recent years, the political and jurisprudential divide over issues such as the right to privacy (including abortion and gay marriage), the right to possess firearms, First Amendment protections, voting right protections, and so many other topics has increasingly become intensified. However, instead of these issues being decided by Congress, the... 2023  
Catherine Y. Kim CITIZENSHIP OUTSIDE THE COURTS 57 U.C. Davis Law Review 253 (November, 2023) The notion of citizenship lies at the core of our constitutional structure, determining possession of fundamental rights ranging from the rights to vote and hold public office to the right to enter and remain in the United States at all. Indeed, the entire constitutional project of self-governance rests on the premise of a defined group of We the... 2023  
Jason Buhi CITIZENSHIP, ASSIMILATION, AND THE INSULAR CASES: REVERSING THE TIDE OF CULTURAL PROTECTIONISM AT AMERICAN SAMOA 53 Seton Hall Law Review 779 (2023) Notwithstanding the gravity of American sovereignty, the people of American Samoa have maintained a distinctive way of life: the fa'a Samoa. This resiliency reflects that American Samoa is in many ways the most unique of the five U.S. territories, including the fact that its residents are the only Americans who do not automatically attain... 2023  
Amy McMeeking CITIZENSHIP, SELF-DETERMINATION, AND CULTURAL PRESERVATION IN AMERICAN SAMOA 70 UCLA Law Review 840 (September, 2023) Recent litigation about the Citizenship Clause's applicability in American Samoa exposes tensions between competing goals of inclusion, self-determination, and cultural preservation. The noncitizen national category and the Insular Cases are both legacies of a long tradition of racial exclusion in the United States, but their current significance... 2023  
Ming Hsu Chen COLORBLIND NATIONALISM AND THE LIMITS OF CITIZENSHIP 44 Cardozo Law Review 945 (February, 2023) Policymakers and lawyers posit formal citizenship as the key to inclusion. Rather than presume that formal citizenship will necessarily promote equality, this Article examines the relationship between citizenship, racial equality, and nationalism. It asks: What role does formal citizenship play in excluding noncitizens and Asian, Latinx, and Muslim... 2023  
Janet M. Calvo CONCEPTS OF CITIZENSHIP IN THE CONTROVERSY ABOUT CONSTITUTIONAL CITIZENSHIP FOR PEOPLE BORN IN U.S. TERRITORIES 91 Fordham Law Review 1671 (April, 2023) Introduction. 1672 I. An Overview of Constitutional and Statutory U.S. Citizenship. 1674 II. The Statutory Status of National. 1675 III. Legal Status of American Samoa. 1676 IV. The Fitisemanu Decisions. 1678 A. The District Court's Opinion. 1678 B. The Tenth Circuit's Opinion. 1679 C. Judge Tymkovich's Concurrence. 1681 D. Judge Bacharach's... 2023  
Torey Dolan CONGRESS' POWER TO AFFIRM INDIAN CITIZENSHIP THROUGH LEGISLATION PROTECTING NATIVE AMERICAN VOTING RIGHTS 59 Idaho Law Review 47 (2023) American Indians' path to citizenship and the franchise has not been straightforward nor simple. The legacy of this complicated path bears out today in the myriad of ways that Native Americans lack equitable access to voting in state and federal elections and otherwise face barriers to participating in the body politic that non-Indians do not.... 2023  
Maggie Blackhawk FOREWORD: THE CONSTITUTION OF AMERICAN COLONIALISM 137 Harvard Law Review 1 (November, 2023) C1-2CONTENTS Introduction. 2 I. The Constitution of American Colonialism. 22 A. Constituting American Colonialism. 26 1. Colonization Within the Founding Borders. 28 2. Colonization Beyond the Founding Borders. 33 3. Colonization of Noncontiguous Territory. 43 B. The Rise of the Plenary Power Doctrine. 53 1. Plenary Power as Doctrine. 55 2.... 2023  
Myisha S. Eatmon FROM THE "LEGAL CULTURE OF SLAVERY" TO BLACK LEGAL CULTURE: REIMAGINING THE IMPLICATIONS AND MEANINGS OF BLACK LITIGIOUSNESS IN SLAVERY AND FREEDOM 48 Law and Social Inquiry 1428 (November, 2023) De la Fuente, Alejandro, and Ariela J. Gross. Becoming Free, Becoming Black: Race, Freedom, and Law in Cuba, Virginia, and Louisiana. New York: Cambridge University Press, 2020. Pp. xiv + 282. Edwards, Laura F. The People and Their Peace: Legal Culture and the Transformation of Inequality in the Post-Revolutionary South. Chapel Hill: University of... 2023  
Daisy J. Ramirez NO SOY DE AQUÍ, NI SOY DE ALLÁ: U.S. CITIZEN CHILDREN ARE PAYING THE PRICE FOR OUR NATION'S BROKEN IMMIGRATION SYSTEM 25 Scholar: St. Mary's Law Review on Race and Social Justice 369 (2023) Introduction - Jasmin's Story. 371 I. Historical Framework of our Nation's Immigration Acts. 380 A. The Immigration and Nationality Act of 1965. 381 B. Immigration Reform and Control Act of 1986. 383 C. Illegal Immigration Reform and Immigrant Responsibility Act of 1996. 386 II. Why are there so many U.S. Citizen Children with Undocumented... 2023  
Carliss N. Chatman TEACHING SLAVERY IN COMMERCIAL LAW 28 Michigan Journal of Race and Law 1 (Spring, 2023) Public status shapes private ordering. Personhood status, conferred or acknowledged by the state, determines whether one is a party to or the object of a contract. For much of our nation's history, the law deemed all persons of African descent to have a limited status, if given personhood at all. The property and partial personhood status of... 2023  
Hardeep Dhillon , American Bar Foundation, Chicago, IL, USA, Email: hdhillon@abfn.org THE MAKING OF MODERN US CITIZENSHIP AND ALIENAGE: THE HISTORY OF ASIAN IMMIGRATION, RACIAL CAPITAL, AND US LAW 41 Law and History Review 1 (February, 2023) This article unravels an important historical conjuncture in the making of modern US citizenship and alienage by drawing on the state's regulation of naturalization as it relates to Asian immigration in the early twentieth century. My primary concern is to examine the socio-legal formations that constructed the thick distinctions between the modern... 2023  
Matthew J. Lindsay THE RIGHT TO MIGRATE 27 Lewis & Clark Law Review 95 (2023) Since the late-19th century, the Supreme Court has insisted that the preservation of national sovereignty requires a constitutional chasm between immigration law and ordinary law. If the Court is to bridge that chasm, it must reimagine the longstanding premise of the federal immigration power that the presence of noncitizens in U.S. territory... 2023  
Gregory Ablavsky , W. Tanner Allread WE THE (NATIVE) PEOPLE?: HOW INDIGENOUS PEOPLES DEBATED THE U.S. CONSTITUTION 123 Columbia Law Review 243 (March, 2023) The Constitution was written in the name of the People of the United States. And yet, many of the nation's actual people were excluded from the document's drafting and ratification based on race, gender, and class. But these groups were far from silent. A more inclusive constitutional history might capture marginalized communities' roles as... 2023  
Gage Raley COULD THE SUPREME COURT DEFY THE "LEGAL CONSENSUS" AND UPHOLD A TRUMP-LIKE EXECUTIVE ORDER ON BIRTHRIGHT CITIZENSHIP? 17 Charleston Law Review 95 (Fall, 2022) C1-2CONTENTS Introduction. 95 I. How the Court could Distinguish (or even discard) Wong Kim Ark and Plyler. 98 II. The Broad Principles of Birthright Citizenship. 103 III. Why the Basic Principle of Birthright Citizenship may not apply to children of illegal immigrants. 112 Conclusion. 116 2022 Yes
Cassandra Burke Robertson , Irina D. Manta INTEGRAL CITIZENSHIP 100 Texas Law Review 1325 (June, 2022) Does the Constitution's promise of birthright citizenship to all born in the United States cover the United States Territories? Residents of the Territories have regularly sought judicial recognition of their equal birthright citizenship under the Fourteenth Amendment, most recently in some prominent cases reaching federal appellate courts. When... 2022 Yes
  § 6:5. Alienage-Other state legislation Government Discrimination: Equal Protection Law and Litigation § 6:5 (2022) In alien discrimination cases not touching on matters of vital state interest, the Court imposes a more rigorous standard of review. Occasionally, early cases found a suspect classification requiring a compelling state interest to justify such actions as discriminatory property ownership rules; restricting the employment or liberty of aliens; alien... 2022  
Steven Sacco ABOLISHING CITIZENSHIP: RESOLVING THE IRRECONCILABILITY BETWEEN "SOIL" AND "BLOOD" POLITICAL MEMBERSHIP AND ANTI-RACIST DEMOCRACY 36 Georgetown Immigration Law Journal 693 (Winter, 2022) C1-2Table of Contents I. Introduction. 694 II. Citizenship as Racism and Anti-Democracy. 698 A. Citizenship as Race. 698 1. Race Becomes Citizenship. 700 2. Citizenship Becomes Race. 711 3. Citizenship Racializes Citizens. 714 B. Citizenship as Anti-Democracy. 718 1. Citizenship Is Anti-Egalitarian. 718 a. Citizenship Is a Caste System. 718 b.... 2022  
Burt Neuborne FEDERALISM AND THE "SECOND FOUNDING:" CONSTITUTIONAL STRUCTURE AS A "DOUBLE SECURITY" FOR "DISCRETE AND INSULAR" MINORITIES 77 New York University Annual Survey of American Law 59 (202) Constitutional Law courses are usually taught in two phases. The standard course opens with a review of the structural aspects of the Constitution - separation of powers, federalism, procedural due process, and the scope of judicial review - and then turns to the scope of substantive constitutional protection - religious freedom; free speech;... 2022  
Anthony M. Ciolli TERRITORIAL PATERNALISM 40 Mississippi College Law Review 103 (2022) C1-2Table of Contents I. BACKGROUND. 104 II. TERRITORIAL SELF-GOVERNMENT AND POLITICAL POWER. 109 III. LIFE IN THE TERRITORIES. 113 IV. SHORT-TERM STRATEGIES TO EMPOWER THE TERRITORIES. 116 A. Representation in the Federal Judiciary. 119 B. Full Utilization of Territorial Government Powers. 125 C. Cooperation with State Governments and Other... 2022  
Amanda Frost "BY ACCIDENT OF BIRTH": THE BATTLE OVER BIRTHRIGHT CITIZENSHIP AFTER UNITED STATES v. WONG KIM ARK 32 Yale Journal of Law & the Humanities 38 (Summer, 2021) In theory, birthright citizenship has been well established in U.S. law since 1898, when the Supreme Court held in United States v. Wong Kim Ark that all born on U.S. soil are U.S. citizens. The experience of immigrants and their families over the last 120 years tells a different story, however. This article draws on government records documenting... 2021 Yes
Amanda Frost "BY ACCIDENT OF BIRTH": THE BATTLE OVER BIRTHRIGHT CITIZENSHIP AFTER UNITED STATES v. WONG KIM ARK 32 Yale Journal of Law & the Humanities 38 (Summer, 2021) In theory, birthright citizenship has been well established in U.S. law since 1898, when the Supreme Court held in United States v. Wong Kim Ark that all born on U.S. soil are U.S. citizens. The experience of immigrants and their families over the last 120 years tells a different story, however. This article draws on government records documenting... 2021 Yes
  102.3 SUPREME COURT DECISIONS 8 Foreign Affairs Manual 102.3 (2021) a. The U.S. Supreme Court has considered the issues of acquisition and retention of U.S. citizenship on various occasions. They include: (1) Decisions on the extent of birthright citizenship before and after the ratification of the Fourteenth Amendment; (2) Decisions interpreting statutory provisions granting citizenship to children born abroad to... 2021 Yes
Gabriel J. Chin , Paul Finkelman BIRTHRIGHT CITIZENSHIP, SLAVE TRADE LEGISLATION, AND THE ORIGINS OF FEDERAL IMMIGRATION REGULATION 54 U.C. Davis Law Review 2215 (April, 2021) In accord with the traditional restriction of citizenship of nonwhites, for decades some conservative lawmakers and scholars have urged Congress to deny citizenship to U.S.-born children of unauthorized migrants. For its part, the Trump Administration promised to pursue birthright citizenship reform. The most prominent and compelling argument... 2021 Yes
Gabriel J. Chin , Paul Finkelman BIRTHRIGHT CITIZENSHIP, SLAVE TRADE LEGISLATION, AND THE ORIGINS OF FEDERAL IMMIGRATION REGULATION 54 U.C. Davis Law Review 2215 (April, 2021) In accord with the traditional restriction of citizenship of nonwhites, for decades some conservative lawmakers and scholars have urged Congress to deny citizenship to U.S.-born children of unauthorized migrants. For its part, the Trump Administration promised to pursue birthright citizenship reform. The most prominent and compelling argument... 2021 Yes
Jordan Gross INCORPORATION BY ANY OTHER NAME? COMPARING CONGRESS' FEDERALIZATION OF TRIBAL COURT CRIMINAL PROCEDURE WITH THE SUPREME COURT'S REGULATION OF STATE COURTS 109 Kentucky Law Journal 299 (2020-2021) Table of Contents 299 Introduction. 300 I. Colonialist Containment of Indigenous Justice. 304 A. Destabilized Sovereignty. 304 B. Imported Justice. 306 C. Appropriated Jurisdiction. 309 II. State and Tribal Court Procedural Reform by Federal Fiat. 322 A. The Supreme Court Federalizes State Court Criminal Procedure. 322 B. Congress Federalizes... 2021 Yes
Eric C. Nystrom, David S. Tanenhaus "OUR MOST SACRED LEGAL COMMITMENTS": A DIGITAL EXPLORATION OF THE U.S. SUPREME COURT DEFINING WHO WE ARE AND HOW THEY SHOULD OPINE 89 University of Cincinnati Law Review 832 (2021) The whole part, the whole point, the whole function, the whole duty of the Supreme Court is to teach. To give reasons for what we do. You could learn a lot. On the other hand we teach by keeping the press out. We teach that we are judged by what we write. We don't go around giving press conferences how great my decision was or how bad the... 2021  
Angela Onwuachi-Willig, Anthony V. Alfieri (RE)FRAMING RACE IN CIVIL RIGHTS LAWYERING, STONY THE ROAD: RECONSTRUCTION, WHITE SUPREMACY, AND THE RISE OF JIM CROW, BY HENRY LOUIS GATES, JR., PENGUIN PRESS, 2019 130 Yale Law Journal 2052 (June, 2021) This Review examines the significance of Henry Louis Gates, Jr.'s new book, Stony the Road: Reconstruction, White Supremacy, and the Rise of Jim Crow, for the study of racism in our nation's legal system and for the regulation of race in the legal profession, especially in the everyday labor of civil-rights and poverty lawyers, prosecutors, and... 2021  
  § 40F:135. Complaint in district court-For declaratory and injunctive relief-To declare that Citizenship Clause of the Fourteenth Amendment to the United States Constitution applies to American Samoa [28 U.S.C.A. §§ 2201, 2202; U.S. Const. Amend. XIV, § 1 FEDPROF Federal Procedural Forms 40F:135 (2021) Certainly this question can admit of but one answer. It is the name given to our great republic, which is composed of States and territories. The District of Columbia, or the territory west of the Missouri, is not less within the United States than Maryland or Pennsylvania second section [i.e., the Apportionment Clause] refers to no persons... 2021  
  § 40F:135. Complaint in district court-For declaratory and injunctive relief-To declare that Citizenship Clause of the Fourteenth Amendment to the United States Constitution applies to American Samoa [28 U.S.C.A. §§ 2201, 2202; U.S. Const. Amend. XIV, § 1 FEDPROF Federal Procedural Forms 40F:135 (2021) Certainly this question can admit of but one answer. It is the name given to our great republic, which is composed of States and territories. The District of Columbia, or the territory west of the Missouri, is not less within the United States than Maryland or Pennsylvania second section [i.e., the Apportionment Clause] refers to no persons... 2021  
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