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Let’s put aside the American-born children of non-citizen members of Indian tribes, for they were granted citizenship by an act of Congress in 1924. And that, as we’ve seen, was only after Elk v. Wilkins, in which the Supreme Court reasoned that the 14th Amendment did not make them U.S. citizens because they were not “subject to the jurisdiction” of the United States in the sense of “complete,” “direct and immediate allegiance.”Share
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