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Trump v. Barbara · ¶38

That law was clear. Any child who was born “under the protection of ” the United States—that is, any child for whom no extraterritorial fiction applied—was made a citizen, for he owed a natural “allegiance” (and thus “obedience”) to the Nation. Lynch, 1 Sand. Ch., at 668; see Cong. Globe, 39th Cong., 1st Sess., at 570 (Sen. Morrill) (the “essential elements of citizenship” are “allegiance on the one side and protection on the other”).
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slip opinion, revised 7/01/26
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