Trump v. Barbara · ¶440

As for the other constitutional provisions that use the term “citizen,” it appears that the question simply did not come up. A reason why the issue did not arise regarding the qualifications of Members of Congress may be that for- eign-born individuals who were interested in holding office could easily become citizens. Under the Naturalization Act of 1790, a foreigner became an American citizen simply by proving two years of residence and good moral character. Act of Mar. 26, 1790, 1 Stat. 103–104.

slip opinion, revised 7/01/26
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