Trump v. Barbara · ¶185

Because a person could have only one domicile, domicile was a natural criterion for citizenship. In the 19th century, dual citizenship was considered highly undesirable, if not a contradiction in terms. “[T]he general view was that ‘no one can have two countries.’” R. Mensel, Jurisdiction in Nineteenth Century International Law and Its Meaning in the Citizenship Clause of the Fourteenth Amendment, 32 St. Louis U. Pub. L. Rev. 329, 334 (2013) (alterations omitted). Dual citizenship led to a number of foreign-policy concerns, such as conflicting claims on the dual citizen during a war. Report of 1868, at 100; Inhabitants of Abington, 40 Mass., at 177–178. Therefore, the United States did not “recogniz[e] a ‘double allegiance.’” H. R. Rep. No. 784, 43d Cong., 1st Sess., 23 (1874). Instead, under “our law” a citizen was “bound to be ‘true and faithful’ alone to our Government.” Ibid.;…

slip opinion, revised 7/01/26
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