Instead, quoting from the Citizenship Clause, Black wrote:

These two pathways to citizenship are specified in the Citizenship Clause of the Constitution's Fourteenth Amendment which reads:

The 39th Congress proposed the principle underlying the Citizenship Clause due to concerns expressed about the constitutionality of the Civil Rights Act during floor debates in Congress.

The text of the Citizenship Clause was first offered in the Senate as an amendment to Section 1 of the joint resolution as passed by the House.

Specifically, the Saenz Court said that the Citizenship Clause protects a citizen's right to resettle in other states and then be treated equally:

Because those insular areas that are inhabited are unincorporated territories, their native-born inhabitants are not constitutionally entitled to United States citizenship under the Citizenship Clause.

Both Democrats and Republicans have introduced legislation aimed at narrowing the application of the Citizenship Clause.

Some legislators, unsure whether such Acts of Congress would survive court challenges, have proposed that the Citizenship Clause be changed through a constitutional amendment.

This decision established an important precedent in its interpretation of the Citizenship Clause of the Fourteenth Amendment to the Constitution.

The United States v Wong Kim Ark Case 1898 shed light on the validity of the Citizenship Clause.