{"id":322,"date":"2026-07-01T21:42:31","date_gmt":"2026-07-01T21:42:31","guid":{"rendered":"https:\/\/americanservicereview.com\/?p=322"},"modified":"2026-07-01T21:42:31","modified_gmt":"2026-07-01T21:42:31","slug":"three-cheers-for-barbara","status":"publish","type":"post","link":"https:\/\/americanservicereview.com\/?p=322","title":{"rendered":"Three cheers for Barbara!"},"content":{"rendered":"
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First: Chief Justice John Roberts\u2019 majority opinion for the court in the landmark Trump v. Barbara<\/em> decision yesterday reached the right result \u2013 a complete repudiation of President Donald Trump\u2019s lawless executive order 14160 seeking to end birthright citizenship. Hurrah! <\/p>\n

Read more Aiding and abetting impunity<\/a><\/p>\n

Second: the court based its ruling on the right document \u2013 the Constitution itself, and not a mere statute. Hurrah! <\/p>\n

Third: the court gave America the right reason for its action: equal birthright citizenship for all born on American soil and under the American flag. Hurrah!<\/p>\n

As a partial guide to this momentous decision, the table below excerpts 14 key passages from the chief justice\u2019s landmark majority opinion, alongside parallel precursor passages in Akhil\u2019s Feb. 23 filed by Vik and parallel precursor passages in our various March SCOTUSblog columns. <\/p>\n

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\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
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Barbara<\/em><\/p>\n<\/div>\n<\/th>\n

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Us<\/em><\/p>\n<\/div>\n<\/th>\n<\/tr>\n<\/thead>\n

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The Reconstruction Congress did not start from scratch. In the midst of the Civil War, President Lincoln\u2019s Attorney General, Edward Bates, had issued a landmark opinion that sought to displace Dred Scott<\/em>. . . Bates rejected the premise that \u201ccitizenship is ever hereditary.\u201d 10 Op. Atty. Gen. 382, 399 (1862). \u201c[E]very person born in the country,\u201d he wrote, \u201cis, at the moment of birth, prima facie<\/em> a citizen . . . without any reference to race or color, or any other accidental circumstances.\u201d . . . To Bates, it was soil\u2014not blood\u2014that \u201cfurnishes the rule, both of duty and of right.\u201d<\/p>\n<\/div>\n<\/td>\n

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By late 1862, Lincoln\u2019s administration openly began to push back against blood-based and hereditary caste-like citizenship rules. Sidestepping Dred Scott<\/em>, Lincoln\u2019s Attorney General Edward Bates in November 1862 issued a landmark opinion basing American citizenship on soil and not blood. Birthright citizenship, asserted Bates . . . generally depended on where a person was born. All free folk born under the American flag were birthright citizens. \u201cEvery person born in the country,\u201d wrote Bates, \u201cis, at the moment of birth, prima facie<\/em> a citizen . . . without any reference to race or color, or any other accidental circumstance.\u201d<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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A year after General Lee\u2019s surrender at Appomattox, Congress sought to turn Bates\u2019s opinion into law. The result was the Civil Rights Act of 1866. The Act declared that \u201call persons born in the United States and not subject to any foreign power, excluding Indians not taxed, are hereby . . . citizens of the United States.\u201d<\/p>\n<\/div>\n<\/td>\n

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At war\u2019s end, Reconstruction Republicans in Congress squarely sided with the party\u2019s leading lights\u2014 Lincoln, Bates, Chase, and Seward\u2014in a watershed 1866 Civil Rights Act that opened as follows: \u201c[A]ll persons born in the United States and not subject to any foreign power, excluding Indians not taxed, are hereby declared to be citizens of the United States.\u201d<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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The specter of Dred Scott<\/em>, however, loomed over Congress\u2019s efforts. Opponents of the Act contended that Congress could not grant such expansive citizenship (and set aside this Court\u2019s precedent) by statute alone. . . . To quiet those concerns . . . Congress turned to the Fourteenth Amendment. . . . What the Civil Rights Act began, the Fourteenth Amendment would finish. Like the Act, the Fourteenth Amendment was intended to repudiate Dred Scott<\/em>. This time, however, the goal was even grander\u2014to put the \u201cgreat question of citizenship\u201d \u201cbeyond the legislative power\u201d altogether, to settle the issue once and for all.<\/p>\n<\/div>\n<\/td>\n

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But would a mere executive memo and a simple congressional statute suffice? What if the Supreme Court tried to resurrect Taney\u2019s Dred Scott<\/em> opinion and declare the memo and the statute unconstitutional? What if some future president tried to rescind the memo or ignore the statute? In the late 1860s, America adopted a constitutional amendment to settle the matter conclusively.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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A child born on American soil and subject to American law was made an American citizen. . . . To be \u201csubject to\u201d the jurisdiction of the United States, then, is to \u201cliv[e] under\u201d its \u201cdominion,\u201d . . . a meaning reinforced by the<\/p>\n

Clause\u2019s territorial focus on those born \u201cin\u201d the United States. The Citizenship Clause uses jurisdiction in its ordinary sense\u2014referring to the power of the United States to govern those within its territory.<\/p>\n<\/div>\n<\/td>\n

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A baby born on American soil under an American flag is typically subject to ordinary American law in the ordinary way\u2014subject, that is, to American jurisdiction. . . . The key initial preposition, in<\/em>, is geographic.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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[A]mbassadors (and their families) . . . were considered\u2014by a fiction of extraterritoriality\u2014to remain on foreign soil.<\/p>\n<\/div>\n<\/td>\n

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[A] baby born to a diplomat was treated as if she were born inside the embassy\u2014 foreign soil under a foreign flag, akin to foreign-occupied territory or a foreign public vessel [thanks to a] \u201cfiction of law\u201d [and a] \u201cfiction of extraterritoriality.\u201d<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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A foreign mother could enter the British Isles, give birth, and leave with her child the very next day, and that child would remain a British subject. Why? Because the child owed an implied allegiance to the sovereign who protected him at his birth\u2014no matter how \u201cmomentary and uncertain\u201d his presence in the King\u2019s realms. Calvin\u2019s Case.<\/em><\/p>\n<\/div>\n<\/td>\n

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Under rulings going back centuries, including most famously Calvin\u2019s Case<\/em> in 1608, English jurists had made clear that a baby born on English soil was almost invariably born an English subject, even if her parents were, say, French folk sojourning in England.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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[T]he antebellum era\u2019s foremost case on the topic, Lynch v. Clarke<\/em>, 1 Sand. Ch. 583 (N. Y. Ch. 1844). Lynch<\/em> reiterated that \u201cthe common law rule was the law of the land\u201d for the children of \u201ccitizens\u201d and \u201cforeigners\u201d alike\u2014including those foreigners here merely on a \u201ctemporary sojourn.\u201d<\/p>\n<\/div>\n<\/td>\n

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A high-profile antebellum New York opinion, Lynch v. Clarke<\/em>, 1 Sand. Ch. 583 (N.Y. Ch. 1844), relied on English jurisprudence to hold that a baby born in New York to noncitizen parents was indeed a birthright New York citizen.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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[N]early everyone within the territorial boundaries of the United States was \u201camenable to\u201d the Nation\u2019s jurisdiction. . . . The ordinary legal meaning of the text of the Clause thus neatly captures the common law rule, with its broad reach and narrow exceptions. The same groups included (and excluded) by jus soli were included (and excluded) by the conventional understanding of jurisdiction.<\/p>\n<\/div>\n<\/td>\n

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These touchstones\u2014the soil and the flag\u2014cleanly explain both the scope and the limits of the Constitution\u2019s grand birthright-citizenship guarantee.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n

With the right constitutional rule in view, the exceptions turn out to have a deep logic and coherence. . . .Two originalist touchstones \u2013 the soil and the flag \u2013 cleanly explain both the scope and the limits of the Constitution\u2019s grand birthright-citizenship guarantee. As the 14th Amendment\u2019s framers and ratifiers repeated ad infinitum, all born (1) on American soil and (2) \u201cunder the flag\u201d are birthright citizens.<\/p>\n

\u2014 Sam Desai\u2019s March 16 posting in our SCOTUSblog column space<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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Our precedent\u2014the seminal case of United States v. Wong Kim Ark<\/em>, 169 U. S. 649 (1898)\u2014confirms this rule.<\/p>\n<\/div>\n<\/td>\n

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Beginning with Wong Kim Ark<\/em>, a long line of Supreme Court precedents tightly aligns with the arguments and evidence that amicus presents today.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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Not surprisingly, then, in the 128 years since, we have repeatedly understood the rule of Wong Kim Ark<\/em> to guarantee citizenship to all children born in the United States and subject to its power. See, e.g., United States ex rel. Hintopoulos v. Shaughnessy<\/em>, 353 U. S. 72, 73 (1957).<\/p>\n<\/div>\n<\/td>\n

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What does today\u2019s solicitor general say about Hintopoulos<\/em>? He doesn\u2019t. Hint<\/em>opoulos goes entirely unmentioned in merits that together span more than 70 pages, despite the fact that a by three of America\u2019s most accomplished immigration scholars highlighted Hintopoulos<\/em> above all other modern cases.<\/p>\n

\u2014 Our March 27 SCOTUSblog column entirely devoted to <\/em>Hintopoulos<\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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For a Congress intent on putting the question of citizenship \u201conce and forever [to] rest,\u201d a domicile-based qualification would have introduced significant uncertainty. Unlike the easy-to-apply common law, it would be \u201cdifficult, if not impossible, to lay down any general rule\u201d of domicile-based citizenship, as domicile \u201coften depend[s] upon the circumstances of each case, the combinations of which are infinite.\u201d . . . If Congress intended to hinge citizenship on each individual\u2019s domicile\u2014a question that \u201cis sometimes a matter of great difficulty to decide,\u201d it is reasonable to expect there would have been at least some discussion of the topic. Yet the word \u201cdomicile\u201d appears just twice in the discussion of the relevant provision of the Civil Rights Act. . . . Words appearing frequently in the Executive Order\u2014\u201cmother,\u201d \u201cfather,\u201d \u201clawful,\u201d temporary\u201d\u2014are absent from the Clause. For a simple reason: they did not matter.<\/p>\n<\/div>\n<\/td>\n

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In lieu of the 14th Amendment\u2019s clear, clean, geographic rule, Trump\u2019s executive order substitutes muddy, messy, genealogical rules pulled out of thin air. . . . \u201cParent,\u201d \u201cparents,\u201d \u201cdomicile\u201d\u2014these words appear nowhere in the Amendment. If the Amendment pivoted on any of these omitted words, as some have claimed, enormous questions would have arisen in the Amendment\u2019s drafting and ratification process. How and when would parentage and domicile be determined? How could a parentage test ensure the rock-solid, bullet-proof citizenship of all American-born children of American slaves? (In the 1860s, many enslaved parents were African-born and never-naturalized aliens, some of whom were, technically, illegal aliens, having been smuggled into America after 1807 by pirate slave-traders.) No discussion of such topics in fact occurred. That silence powerfully confirms that the Amendment means just what it says: All persons born inside the juridical U.S.A. and lacking diplomatic immunity\u2014all persons born under the flag\u2014are born equal citizens. It did not matter in 1868, and it does not matter today, whether an American newborn\u2019s mother or father or both or neither is a U.S. citizen or even a domiciliary; or whether either parent is Black or White or Yellow or a so-called \u201cGypsy,\u201d or was ever a slave.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n

The words \u201cparent,\u201d \u201cparents,\u201d \u201cmother,\u201d and \u201cfather\u201d appear nowhere in the text of the 14th Amendment\u2019s citizenship clause. . .. Yet Trump\u2019s made-up executive order uses the words \u201cmother\u201d and \u201cfather\u201d a combined ten times.<\/em><\/p>\n

Trump and his legal and academic defenders have simply fabricated a welter of detailed parental rules \u2013 about parental<\/em> citizenship, parental<\/em> legal status, parental<\/em> domicile, and parental<\/em> allegiance. Too many critics of Trump and his allies have taken the bait, themselves focusing rather too much attention on parents. To borrow a phrase, they have fallen into the \u201cParent Trap.\u201d<\/p>\n

\u2014 Our March 23 SCOTUSblog column with Sam Desai on the \u201cParent Trap\u201d<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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While the Clause does ensure state citizenship attaches for U. S. citizens in \u201cthe State wherein they reside,\u201d Amdt. 14, \u00a71, the explicit invocation of residence for state citizenship only highlights its absence from the criteria for U. S. citizenship. . . .\u201c[A] person can \u201cbe a citizen of the United States without being a citizen of a State.\u201d<\/p>\n<\/div>\n<\/td>\n

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U.S. citizenship in [the Fourteenth Amendment\u2019s birthright citizenship clause] is not remotely the same thing as state citizenship. . . . Indeed, a person can be a U.S. citizen without ever having been a state citizen.<\/p>\n

\u2014 Our March 16 SCOTUSblog column responding to Pete Patterson<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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In our estimation, the [1866] Act raises more questions than answers\u2014and was replaced by the Fourteenth Amendment, which \u201cbetter\u201d expresses the views of the Reconstruction Congress anyway.<\/p>\n<\/div>\n<\/td>\n

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The language of the [1866] act \u2013 \u201cnot subject to any foreign power\u201d \u2013 differs from the counterpart language of the amendment: \u201csubject to the jurisdiction [of the United States].\u201d A baby born with dual citizenship \u2013 and of course both the act and the amendment address the baby, not the parent or parents \u2013 might indeed in some sense be subject to a foreign power (and thus fall outside<\/em> the protective blanket of the act) but might also be undeniably subject to American jurisdiction (and thus fall within<\/em> the amendment\u2019s protective blanket).<\/p>\n

\u2014 Our March 16 SCOTUSblog column responding to Pete Patterson<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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Where the dissents see feudalism, the Framers of the Fourteenth Amendment saw emancipation.<\/p>\n<\/div>\n<\/td>\n

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Finally, we come to the biggest problem of all: Patterson\u2019s weird appeal to anti-feudalism. True, America\u2019s equal-birthright-citizenship regime does have deep roots in English common law dating back to the early 1600s \u2013 a feudal era in which Stuart kings claimed authority to rule birthright subjects based on the monarch\u2019s divine birthright. . . .. But in July 1776, the colonies unanimously declared a new, more republican, regime based in no small part on the bold idea that all men are created equal. . . . 19th-century Americans led by Lincoln eventually went even further than they had in 1776, and embraced a compelling vision of equal birthright citizenship. According to this mid-1860s Lincolnian vision, all babies born on American soil under the American flag were born equal \u2013 whether born Black or white, male or female, Jewish or Gentile. Also, and relatedly, all American babies born on American soil under the American flag were born equal, whether born to citizen parents or alien parents, whether born to long-time residents or wandering sojourners.<\/p>\n

This is the precise Lincolnian idea that Patterson defies when he insists that a baby born in America to alien sojourners is lesser than a baby born in America to citizen parents. . . . Patterson wants modern America to focus instead on blood and parentage \u2013 on a American-born baby\u2019s birth-lineage above and beyond her birth-location. But Patterson\u2019s focus on lineage and blood is itself a strong vestige of Old World ideology. Patterson\u2019s repudiation of Lincoln \u2013 under a banner of anti-feudalism, no less! \u2013 is thus somewhere between obtuse and absurd.<\/p>\n

\u2014 Our March 16 SCOTUSblog column responding to Pete Patterson<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n

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Citizenship, then and now, was the right to have rights\u2014to freely participate in our political community. The Framers of the Fourteenth Amendment extended that promise to \u201cevery free-born person in this land.\u201d . . . We keep that promise today.<\/p>\n

Read more The 2025-26 term by the numbers<\/a><\/p>\n<\/div>\n<\/td>\n

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The basic issues at stake go to the very foundation of the Constitution. At root, citizenship is the right to have rights, and the right to belong. . . . Amicus thus hopes the Court will not just rule the right way in this case, but will do so for the best and deepest reasons\u2014ringingly.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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The Reconstruction Congress did not start from scratch. In the midst of the Civil War, President Lincoln\u2019s Attorney General, Edward Bates, had issued a landmark opinion that sought to displace Dred Scott<\/em>. . . Bates rejected the premise that \u201ccitizenship is ever hereditary.\u201d 10 Op. Atty. Gen. 382, 399 (1862). \u201c[E]very person born in the country,\u201d he wrote, \u201cis, at the moment of birth, prima facie<\/em> a citizen . . . without any reference to race or color, or any other accidental circumstances.\u201d . . . To Bates, it was soil\u2014not blood\u2014that \u201cfurnishes the rule, both of duty and of right.\u201d<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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By late 1862, Lincoln\u2019s administration openly began to push back against blood-based and hereditary caste-like citizenship rules. Sidestepping Dred Scott<\/em>, Lincoln\u2019s Attorney General Edward Bates in November 1862 issued a landmark opinion basing American citizenship on soil and not blood. Birthright citizenship, asserted Bates . . . generally depended on where a person was born. All free folk born under the American flag were birthright citizens. \u201cEvery person born in the country,\u201d wrote Bates, \u201cis, at the moment of birth, prima facie<\/em> a citizen . . . without any reference to race or color, or any other accidental circumstance.\u201d<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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A year after General Lee\u2019s surrender at Appomattox, Congress sought to turn Bates\u2019s opinion into law. The result was the Civil Rights Act of 1866. The Act declared that \u201call persons born in the United States and not subject to any foreign power, excluding Indians not taxed, are hereby . . . citizens of the United States.\u201d<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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At war\u2019s end, Reconstruction Republicans in Congress squarely sided with the party\u2019s leading lights\u2014 Lincoln, Bates, Chase, and Seward\u2014in a watershed 1866 Civil Rights Act that opened as follows: \u201c[A]ll persons born in the United States and not subject to any foreign power, excluding Indians not taxed, are hereby declared to be citizens of the United States.\u201d<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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The specter of Dred Scott<\/em>, however, loomed over Congress\u2019s efforts. Opponents of the Act contended that Congress could not grant such expansive citizenship (and set aside this Court\u2019s precedent) by statute alone. . . . To quiet those concerns . . . Congress turned to the Fourteenth Amendment. . . . What the Civil Rights Act began, the Fourteenth Amendment would finish. Like the Act, the Fourteenth Amendment was intended to repudiate Dred Scott<\/em>. This time, however, the goal was even grander\u2014to put the \u201cgreat question of citizenship\u201d \u201cbeyond the legislative power\u201d altogether, to settle the issue once and for all.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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But would a mere executive memo and a simple congressional statute suffice? What if the Supreme Court tried to resurrect Taney\u2019s Dred Scott<\/em> opinion and declare the memo and the statute unconstitutional? What if some future president tried to rescind the memo or ignore the statute? In the late 1860s, America adopted a constitutional amendment to settle the matter conclusively.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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A child born on American soil and subject to American law was made an American citizen. . . . To be \u201csubject to\u201d the jurisdiction of the United States, then, is to \u201cliv[e] under\u201d its \u201cdominion,\u201d . . . a meaning reinforced by the<\/p>\n

Clause\u2019s territorial focus on those born \u201cin\u201d the United States. The Citizenship Clause uses jurisdiction in its ordinary sense\u2014referring to the power of the United States to govern those within its territory.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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A baby born on American soil under an American flag is typically subject to ordinary American law in the ordinary way\u2014subject, that is, to American jurisdiction. . . . The key initial preposition, in<\/em>, is geographic.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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[A]mbassadors (and their families) . . . were considered\u2014by a fiction of extraterritoriality\u2014to remain on foreign soil.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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[A] baby born to a diplomat was treated as if she were born inside the embassy\u2014 foreign soil under a foreign flag, akin to foreign-occupied territory or a foreign public vessel [thanks to a] \u201cfiction of law\u201d [and a] \u201cfiction of extraterritoriality.\u201d<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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A foreign mother could enter the British Isles, give birth, and leave with her child the very next day, and that child would remain a British subject. Why? Because the child owed an implied allegiance to the sovereign who protected him at his birth\u2014no matter how \u201cmomentary and uncertain\u201d his presence in the King\u2019s realms. Calvin\u2019s Case.<\/em><\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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Under rulings going back centuries, including most famously Calvin\u2019s Case<\/em> in 1608, English jurists had made clear that a baby born on English soil was almost invariably born an English subject, even if her parents were, say, French folk sojourning in England.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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[T]he antebellum era\u2019s foremost case on the topic, Lynch v. Clarke<\/em>, 1 Sand. Ch. 583 (N. Y. Ch. 1844). Lynch<\/em> reiterated that \u201cthe common law rule was the law of the land\u201d for the children of \u201ccitizens\u201d and \u201cforeigners\u201d alike\u2014including those foreigners here merely on a \u201ctemporary sojourn.\u201d<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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A high-profile antebellum New York opinion, Lynch v. Clarke<\/em>, 1 Sand. Ch. 583 (N.Y. Ch. 1844), relied on English jurisprudence to hold that a baby born in New York to noncitizen parents was indeed a birthright New York citizen.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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[N]early everyone within the territorial boundaries of the United States was \u201camenable to\u201d the Nation\u2019s jurisdiction. . . . The ordinary legal meaning of the text of the Clause thus neatly captures the common law rule, with its broad reach and narrow exceptions. The same groups included (and excluded) by jus soli were included (and excluded) by the conventional understanding of jurisdiction.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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These touchstones\u2014the soil and the flag\u2014cleanly explain both the scope and the limits of the Constitution\u2019s grand birthright-citizenship guarantee.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n

With the right constitutional rule in view, the exceptions turn out to have a deep logic and coherence. . . .Two originalist touchstones \u2013 the soil and the flag \u2013 cleanly explain both the scope and the limits of the Constitution\u2019s grand birthright-citizenship guarantee. As the 14th Amendment\u2019s framers and ratifiers repeated ad infinitum, all born (1) on American soil and (2) \u201cunder the flag\u201d are birthright citizens.<\/p>\n

\u2014 Sam Desai\u2019s March 16 posting in our SCOTUSblog column space<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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Our precedent\u2014the seminal case of United States v. Wong Kim Ark<\/em>, 169 U. S. 649 (1898)\u2014confirms this rule.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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Beginning with Wong Kim Ark<\/em>, a long line of Supreme Court precedents tightly aligns with the arguments and evidence that amicus presents today.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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Not surprisingly, then, in the 128 years since, we have repeatedly understood the rule of Wong Kim Ark<\/em> to guarantee citizenship to all children born in the United States and subject to its power. See, e.g., United States ex rel. Hintopoulos v. Shaughnessy<\/em>, 353 U. S. 72, 73 (1957).<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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What does today\u2019s solicitor general say about Hintopoulos<\/em>? He doesn\u2019t. Hint<\/em>opoulos goes entirely unmentioned in merits that together span more than 70 pages, despite the fact that a by three of America\u2019s most accomplished immigration scholars highlighted Hintopoulos<\/em> above all other modern cases.<\/p>\n

\u2014 Our March 27 SCOTUSblog column entirely devoted to <\/em>Hintopoulos<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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For a Congress intent on putting the question of citizenship \u201conce and forever [to] rest,\u201d a domicile-based qualification would have introduced significant uncertainty. Unlike the easy-to-apply common law, it would be \u201cdifficult, if not impossible, to lay down any general rule\u201d of domicile-based citizenship, as domicile \u201coften depend[s] upon the circumstances of each case, the combinations of which are infinite.\u201d . . . If Congress intended to hinge citizenship on each individual\u2019s domicile\u2014a question that \u201cis sometimes a matter of great difficulty to decide,\u201d it is reasonable to expect there would have been at least some discussion of the topic. Yet the word \u201cdomicile\u201d appears just twice in the discussion of the relevant provision of the Civil Rights Act. . . . Words appearing frequently in the Executive Order\u2014\u201cmother,\u201d \u201cfather,\u201d \u201clawful,\u201d temporary\u201d\u2014are absent from the Clause. For a simple reason: they did not matter.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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In lieu of the 14th Amendment\u2019s clear, clean, geographic rule, Trump\u2019s executive order substitutes muddy, messy, genealogical rules pulled out of thin air. . . . \u201cParent,\u201d \u201cparents,\u201d \u201cdomicile\u201d\u2014these words appear nowhere in the Amendment. If the Amendment pivoted on any of these omitted words, as some have claimed, enormous questions would have arisen in the Amendment\u2019s drafting and ratification process. How and when would parentage and domicile be determined? How could a parentage test ensure the rock-solid, bullet-proof citizenship of all American-born children of American slaves? (In the 1860s, many enslaved parents were African-born and never-naturalized aliens, some of whom were, technically, illegal aliens, having been smuggled into America after 1807 by pirate slave-traders.) No discussion of such topics in fact occurred. That silence powerfully confirms that the Amendment means just what it says: All persons born inside the juridical U.S.A. and lacking diplomatic immunity\u2014all persons born under the flag\u2014are born equal citizens. It did not matter in 1868, and it does not matter today, whether an American newborn\u2019s mother or father or both or neither is a U.S. citizen or even a domiciliary; or whether either parent is Black or White or Yellow or a so-called \u201cGypsy,\u201d or was ever a slave.<\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n

The words \u201cparent,\u201d \u201cparents,\u201d \u201cmother,\u201d and \u201cfather\u201d appear nowhere in the text of the 14th Amendment\u2019s citizenship clause. . .. Yet Trump\u2019s made-up executive order uses the words \u201cmother\u201d and \u201cfather\u201d a combined ten times.<\/em><\/p>\n

Trump and his legal and academic defenders have simply fabricated a welter of detailed parental rules \u2013 about parental<\/em> citizenship, parental<\/em> legal status, parental<\/em> domicile, and parental<\/em> allegiance. Too many critics of Trump and his allies have taken the bait, themselves focusing rather too much attention on parents. To borrow a phrase, they have fallen into the \u201cParent Trap.\u201d<\/p>\n

\u2014 Our March 23 SCOTUSblog column with Sam Desai on the \u201cParent Trap\u201d<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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While the Clause does ensure state citizenship attaches for U. S. citizens in \u201cthe State wherein they reside,\u201d Amdt. 14, \u00a71, the explicit invocation of residence for state citizenship only highlights its absence from the criteria for U. S. citizenship. . . .\u201c[A] person can \u201cbe a citizen of the United States without being a citizen of a State.\u201d<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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U.S. citizenship in [the Fourteenth Amendment\u2019s birthright citizenship clause] is not remotely the same thing as state citizenship. . . . Indeed, a person can be a U.S. citizen without ever having been a state citizen.<\/p>\n

\u2014 Our March 16 SCOTUSblog column responding to Pete Patterson<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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In our estimation, the [1866] Act raises more questions than answers\u2014and was replaced by the Fourteenth Amendment, which \u201cbetter\u201d expresses the views of the Reconstruction Congress anyway.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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The language of the [1866] act \u2013 \u201cnot subject to any foreign power\u201d \u2013 differs from the counterpart language of the amendment: \u201csubject to the jurisdiction [of the United States].\u201d A baby born with dual citizenship \u2013 and of course both the act and the amendment address the baby, not the parent or parents \u2013 might indeed in some sense be subject to a foreign power (and thus fall outside<\/em> the protective blanket of the act) but might also be undeniably subject to American jurisdiction (and thus fall within<\/em> the amendment\u2019s protective blanket).<\/p>\n

\u2014 Our March 16 SCOTUSblog column responding to Pete Patterson<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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Where the dissents see feudalism, the Framers of the Fourteenth Amendment saw emancipation.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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Finally, we come to the biggest problem of all: Patterson\u2019s weird appeal to anti-feudalism. True, America\u2019s equal-birthright-citizenship regime does have deep roots in English common law dating back to the early 1600s \u2013 a feudal era in which Stuart kings claimed authority to rule birthright subjects based on the monarch\u2019s divine birthright. . . .. But in July 1776, the colonies unanimously declared a new, more republican, regime based in no small part on the bold idea that all men are created equal. . . . 19th-century Americans led by Lincoln eventually went even further than they had in 1776, and embraced a compelling vision of equal birthright citizenship. According to this mid-1860s Lincolnian vision, all babies born on American soil under the American flag were born equal \u2013 whether born Black or white, male or female, Jewish or Gentile. Also, and relatedly, all American babies born on American soil under the American flag were born equal, whether born to citizen parents or alien parents, whether born to long-time residents or wandering sojourners.<\/p>\n

This is the precise Lincolnian idea that Patterson defies when he insists that a baby born in America to alien sojourners is lesser than a baby born in America to citizen parents. . . . Patterson wants modern America to focus instead on blood and parentage \u2013 on a American-born baby\u2019s birth-lineage above and beyond her birth-location. But Patterson\u2019s focus on lineage and blood is itself a strong vestige of Old World ideology. Patterson\u2019s repudiation of Lincoln \u2013 under a banner of anti-feudalism, no less! \u2013 is thus somewhere between obtuse and absurd.<\/p>\n

\u2014 Our March 16 SCOTUSblog column responding to Pete Patterson<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Barbara<\/em><\/p>\n<\/div>\n<\/div>\n

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Citizenship, then and now, was the right to have rights\u2014to freely participate in our political community. The Framers of the Fourteenth Amendment extended that promise to \u201cevery free-born person in this land.\u201d . . . We keep that promise today.<\/p>\n<\/div>\n<\/div>\n

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Us<\/em><\/p>\n<\/div>\n<\/div>\n

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The basic issues at stake go to the very foundation of the Constitution. At root, citizenship is the right to have rights, and the right to belong. . . . Amicus thus hopes the Court will not just rule the right way in this case, but will do so for the best and deepest reasons\u2014ringingly.<\/p>\n

Read more Closing out the term<\/a><\/p>\n

\u2014 Akhil\u2019s Brief<\/em><\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

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