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Elizabeth B. Wydra

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Truths and Untruths About the Constitutional Origins of Birthright Citizenship

Posted: 01/21/2011 1:41 pm

As Americans and our elected leaders engage in debate over immigration and the constitutional guarantee of citizenship at birth, there is something we should all be able to agree on: misleading statements about constitutional history do not help us understand the Constitution better or allow us to tackle immigration reform in good faith.

It was thus disheartening to see Rep. Lamar Smith, new chairman of the House Judiciary Committee, seriously mislead the public in a letter to the editor printed in the Los Angeles Times. Writing about the Constitution's guarantee of citizenship at birth for all children born on U.S. soil and "subject to the jurisdiction" of the United States, Rep. Smith asserted: "during the debate on the 14th Amendment in 1866, a senator who helped draft the amendment said it would 'not of course include persons born in the United States who are foreigners.'" However, this was an incomplete quote. Had Rep. Smith included the entire quote -- or better yet, included the entire quote and helped explain its significance -- it would not have supported his reading of the 14th Amendment. Perhaps that is why he cut the quote off where he did.

Such distortions of history are unhelpful at best. Here is the full quote from the 1866 Congressional Globe, which is attributed to Sen. Jacob Howard, principal draftsman of the Citizenship Clause of the 14th Amendment:

Every person born within the limits of the United States, and subject to their jurisdiction, is by virtue of natural law and national law a citizen of the United States. This will not, of course, include persons born in the United States who are foreigners, aliens, who belong to the families of ambassadors or foreign ministers accredited to the Government of the United States, but will include every other class of persons.

The reason why this is important is because anti-citizenship advocates seize upon the phrase "subject to the jurisdiction thereof" in the 14th Amendment's guarantee that "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States." They argue that illegally present immigrants are not "subject to the jurisdiction" of the United States. The incomplete portion of the quote used by Rep. Smith in his L.A. Times letter appears to support the view that the Citizenship Clause was drafted to exclude children of "foreigners" who are not subject to U.S. jurisdiction.

But the full sentence shows otherwise. Sen. Howard's description of the only class of children born on U.S. soil who would not be U.S. citizens automatically at birth was merely a summary of the widely accepted understanding that children of foreign diplomats would not be birthright citizens. This is because of the legal fiction that diplomats, while physically present here, are sort of floating along in a little bubble of their home country -- hence the concept of diplomatic immunity. Sen. Howard used the terms "foreigners" and "aliens" in the sentence quoted above to describe those "who belong to the families of ambassadors or foreign ministers accredited to the Government of the United States." If Howard were intending to list several categories of excluded persons (e.g., foreigners, aliens or families of diplomats) he could have said so. Instead, the language he used strongly suggests he was describing a single excluded class, limited to families of diplomats.

Indeed, the history of the Constitution's Citizenship Clause shows that citizenship at birth for children of "foreigners" was expressly contemplated. For example, Sen. Edgar Cowan expressed concern that the citizenship proposal would expand the number Chinese in California and Gypsies in his home state of Pennsylvania by granting birthright citizenship to their children, even (as he put it) the children of those who owe no allegiance to the United States and routinely commit "trespass" within the United States. Supporters of the Citizenship Clause did not take issue with Cowan's understanding of the effect of the Clause, but instead defended it as a matter of sound policy. Sen. John Conness of California declared: "The proposition before us... relates simply in that respect to the children begotten of Chinese parents in California, and it is proposed to declare that they shall be citizens... I am in favor of doing so..."

In contrast to the current debate over the meaning of the Citizenship Clause, the legislative debates occurring at the time Congress approved the Clause demonstrate that both its proponents and opponents agreed that it recognizes and protects birthright citizenship for the children of aliens born on U.S. soil.

And since 1898, the U.S. Supreme Court has also agreed. In United States v. Wong Kim Ark, the Court held that a U.S.-born child of Chinese immigrants was entitled to citizenship, explaining that the "14th Amendment affirms the ancient and fundamental rule of citizenship by birth within the territory... including all children here born of resident aliens." In 1982, the Court explained in Plyler v. Doe that the 14th Amendment extends to anyone "who is subject to the laws of a state," including the U.S.-born children of illegal aliens. Similarly, in the 1985 case INS v. Rios-Pineda, the Court stated that a child born on U.S. soil to an undocumented immigrant was a U.S. citizen from birth.

Complete quotes and adequate explanations do not always fit the word limit for letters to the editor or make for good TV soundbites. But it is the duty of our elected officials to be straight with the American people, especially when discussing the meaning of our Constitution. Looking at the facts -- the text and history of the 14th Amendment's Citizenship Clause and more than a century of Court precedent -- I think it is unquestionable that the Constitution guarantees citizenship at birth to children born on U.S. soil (with the exception of children born to diplomats), including children born to parents who are undocumented immigrants. Rep. Smith and other anti-citizenship activists are certainly entitled to disagree -- but they aren't entitled to create their own version of history.

 
 
 
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01:28 PM on 01/27/2011
This article fails to mention a few things.

Senator Edward Cowan, stated: "A foreigner in the United States] has a right to the protection of the laws; but he is not a citizen in the ordinary acceptance of the word..."

Also: In Elk versus Wilkins (1884) the Supreme Court considered:

The question then is, whether an Indian, born a member of one of the Indian tribes within the United States, is, merely by reason of his birth within the United States, and of his afterwards voluntarily separating himself from his tribe and taking up his residence among white citizens, a citizen of the United States, within the meaning of the first section of the fourteenth amendment of the constitution.

The Court concluded that Indi¬ans were not citizens under the Fourteenth Amendment. While recog¬nizing that Indians were born in the United States in a geographi¬cal sense, they were not citizens just as children born within the United States of ambassadors or other public ministers of foreign nations were not citizens. The Court declared that citizenship must be directly bestowed upon the Indians by the United States. In other words, Indians were legal aliens in their own land.

In 1887 Congress passed the Dawes Act which allowed Indians to become citizens if they had abandoned their tribes and adopted the habits of civilized life. It was generally assumed that "civilized life" meant that they could speak English, had become Christian, and were actively engaged in farming.
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Lindsay Schutz
You call me "liberal" like its an insult...
01:38 PM on 01/23/2011
Would the removal of the "anchor baby clause" apply to the children born here to "undocumented" Irish, Swedes, Russians, etc or just to children of mexican/hispanic descent?
06:16 PM on 01/24/2011
To all.
01:13 PM on 01/23/2011
Whether you are here legally or illegally, you are subject to U.S. jurisdiction (unless you have diplomatic immunity.) An illegal immigrant can be arrested if he steals or commits murder or ticketed if he speeds. It's very simple.
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hagagaga
My comments are funnier than yours.
09:29 AM on 01/23/2011
How is there room for interpretation with "all persons born or naturalized in the United States, and subject to the jurisdiction thereof?"
01:46 AM on 01/23/2011
I don't see the validity of the "anchor baby" issue. People here illegally have a baby that's born American, they are allowed to stay here "anchored" by their American baby because we won't seperate the parents and baby. Let's assume that any baby born here is entitled to American citizenship by fact of birth, whatever the status of the parents. No unemancipated minor child has a right to self determination, they can't enter into contracts, or even a DVD Club. The excercise of their legal authority falls to the parents (or guardian). If the Parents want to go home, they excercise the legal authority for their child and take it home, nobody forces them to abandon their American child before they can go, or refuses to allow them to leave. All we need to do is change enforcement practices. Tell the illegal alien parents that they are being deported and operate on the assumption that they are taking their child home with them, just like any other tourists. It is then up to the parents to excercise their lawful authority for their child and either take it home or abandon it to the custody of whatever State they are in. Most states have some provision for mothers to lawfully abandon their baby with no legal repercussions. No anchor.
10:16 AM on 01/23/2011
they are allowed to stay here "anchored" by their American baby because we won't seperate the parents and baby.
===========================
If the parents are deported, they take the child with them.

Although it is far more likely only one parent is deported, ICE raids work places, not apartment houses.
01:17 PM on 01/23/2011
One does not need to be able to enter into a contract to have basic rights in this country. A minor cannot enter into a contract, but it is not legal to beat them. They have rights to safety. According to our Constitution, they also have the right to citizenship.

You are welcome to disagree with this and work for an amendment to change it. But legal wrangling won't change that fact.
12:34 PM on 01/24/2011
Nice straw man argument you have there but I didn't say anything about taking away civil or human rights or taking away legal protections or denying citizenship to someone born here. I said self determination, a non emancipated minor child doesn't decide where they live, the parent exercises that authority on behalf of the child. If you go on vacation to Disneyworld and your four year old child decides they want to stay and not go back home, their decision has no legal standing and you take your child home. That's why I reject the concept of "anchor babies" because we aren't going to seperate a family. If the parents are being deported, they take the child with them, the child doesn't keep them here. I have no problem with the child having US citizenship, if the parents want it, or dual citizenship. Anybody born here should have that option. I haven't seen any numbers to know if anchor babies are even a serious problem.
I also don't care where anybody comes from, illegal, undocumented, border unobservent, whatever, they go back, no exceptions, no credit for time here, nothing. Do not pass go, do not collect $200. It looks like the country can support more people than are here legally, let's fast track people that are on the list as we get rid of illegals. Let's set up a NICS check system for Social Security numbers, one phone call verifies ID info.
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ninthraphael
i have my god! He/she doesn't look like yours!
05:28 PM on 01/22/2011
we have people who serve us and mislead us....unfortunately they are now in majority. we elected them...
maybe america needs purification and that all requirements to being a US citizen would be based on the color of his skin..why not do that, and let's see a complete transformation of the USA.and maybe just maybe they will be able to see why america became the greatest nation......to a nation of __________(fill in the blank.
07:13 PM on 01/22/2011
This is a joke, right?
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ninthraphael
i have my god! He/she doesn't look like yours!
02:59 AM on 01/23/2011
you mean a nation of joke?
03:02 AM on 01/22/2011
Wydra’s quote of Howard’s speech is also incomplete, omitting:

“It settles the great question of the citizenship and removes all doubt as to what persons are or are not citizens of the United States. This has long been a great desideratum in the jurisprudence and legislation in this country.â€

In 1866, those recognized under "national law†as citizens of the United States were persons naturalized and the children of citizens born abroad (Naturalization Act) and “persons born in the United States and not subject to any foreign power†(Civil Rights Act).

But if Howard really intended the Clause to remove “all doubt as to what persons are or are not citizens,†why did he NOT include the words “or naturalized†in the Clause that the Senate approved on the same day he presented it on May 30, 1866? (Inserted a week later June 8, 1866)

And why did Howard NOT provide for the status of children of citizens born abroad?

Analyzing why Howard enclosed the phrase “and subject to the jurisdiction thereof†between a pair of commas and why Sen. Doolittle--directly quoting “the language which he [the author] usesâ€--read the phrase as “all persons subject to the jurisdiction of the United States†(either at birth or after birth) might provide the key, for the phrase may well be the SECOND of the COMPOUND subject of the Clause, structured as an ELLIPTICAL (repeated noun phrase "all persons" omitted) for the complete construction Doolittle quoted.
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dtairtime
It is what it is
09:12 PM on 01/21/2011
So Ms Wydra, if you are so secure in your interpretation of the intent of this amendment, why not allow the SCOTUS to rule on it and remove the on-going debate?

It's going to happen (hopefully soon) and trying to use your pulpit to sway people, as many have been doing for years now, won't help your open borders, big business cause on this one. The SC has to look at the law, the intent and precedence - which hopefully will end this practice we are doing as the LAST nation on earth to do so with good reasons - it's too bad that so many people are profiting so much on this massive inflow of cheap labor that it has been hard.
10:48 AM on 01/22/2011
Can't Ms Wydra do the same thing that conservatives are doing e.g. Smith? We still have a First Amendment I think. Are you aware that Scalia only looks at the wording in the law? He will not consider any legislative history or statements by the drafters of legislation. Until the current gang of conservatives took over the court, previous decisions tended to be sustained unless there were new facts or issues. That corporations are people set that tradition on its head.
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Mikel Moore
My microbio is empty, by choice...
12:05 PM on 01/23/2011
Since, by what you say, evidently neither precedence nor historical context are relevant to him, I wonder if Scalia rejects The Federalist Papers--what then becomes of originalism?
02:57 PM on 01/22/2011
dtairtime wrote: "So Ms Wydra, if you are so secure in your interpreta­tion of the intent of this amendment, why not allow the SCOTUS to rule on it and remove the on-going debate?"
===================
They have. The main cases being: Wong Kim Ark, Perkins v. Elg, Plyler v. Doe and Afroym v. Rusk.

My bet is that for any case seeking to redefine the basic concept of jurisdiction, the lower appeals court will uphold historical interpretations and that SCOTUS won't even grant cert on the issue.
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dsws
No owning ideas. Limit only commercial use.
04:40 PM on 01/22/2011
F&F for citing actual cases.
05:21 PM on 01/21/2011
Even if the we take the 14th amendment as you feel it should be taken. It still needs to be changed. Either change it to where 1 parent must be an American citizen or after birth put the child in foster care to be adopted and send the mother back where she belongs. The 14th Amendment does not cover the mother. Or let her as the childs guardian sign away the childs rights to citizenship to take the baby back with her.
05:59 PM on 01/21/2011
So you want to create a permanent underclass of non-citizens in the U.S.?

We had that once.

They were called "slaves."
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hrpmap
Retired man still active..
06:04 PM on 01/21/2011
Slavery forces some one to stay and work, we want them to go home, or stay home.
06:23 PM on 01/21/2011
I don't get how you came up with that from my comment. The child will be an American citizen raised by American citizens. And the birth mother will go back to being a citizen of whatever country she came from.
06:16 PM on 01/21/2011
Oh, and it's a myth that the U.S. does not deport the parents of citizen children. They do so all the time.
06:32 PM on 01/21/2011
I am sure they do a portion of the time but I hardly thimk it is all the time as you say. But what I mean is they have the baby and boom they need to be on the next plane, train, or bus back where they came from. I mean they are already costing US taxpayers for the birth of the child, which is money that could have been used for an American citizen that deserved it.
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hrpmap
Retired man still active..
06:38 PM on 01/21/2011
And rightfully so.
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Jerry Vasquez
A Unapologetic liberal
05:15 PM on 01/21/2011
As much as I hate to agree with those on the right, about anything, revisiting that portion of the
14th amendment might be in order. How ever this country doesn't pass laws that apply retroactively
so that will not solve the problem of the roughly 14-20 million already here.
05:39 PM on 01/21/2011
You're right but let's take things one step at a time. Amending the 14th amendment would stop a lot of the illegal immigrants who come here only to give birth.
06:09 PM on 01/21/2011
Studies have shown that most illegal parents who have children born in the U.S. do so after they have been here for over 9 months.

They come here for JOBS, not to have children.
05:58 PM on 01/21/2011
nor will changing the 14th amendment stop others from coming here.

They come for jobs.
01:35 AM on 01/22/2011
I see that none of you people live on the border. Mexican women have the choice to either give birth in the US for free at a US hospital. or pay about $200 at a Mexican one. They also get the benefit of US citizenship for their kids. All they have to do is simply walk/ or drive across the border and go to the ER when their water breaks. Many do that.
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hrpmap
Retired man still active..
04:57 PM on 01/21/2011
What part of jurisdiction do you not understand? Sone one commits a crime in their home where where the jurisdiction is and by treaty we send them back.
05:57 PM on 01/21/2011
So if an illegal alien commits murder, say, in the U.S., we sent them back for trial and punishment?

Is that your argument? if so, then you failed.
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dtairtime
It is what it is
08:37 PM on 01/21/2011
If you would have read hrpmap's posting you would have noted that is NOT what was said.

What was said is that say for instance a Mexican national, here illegally, commits a crime in this country or one from earlier in his life in Mexico. The Mexican consulate can ask to have that person remanded back to Mexico.

Also think about this: Can an illegal be drafted by our armed services if we had the draft? The answer is no. Can they vote? No Can they contribute and later draw on SS? No

They are NOT under our jurisdiction any more then I am under Mexico's when I am in their country. Which is to say I am obliged to follow their rules but they have no authority over me.
04:55 PM on 01/21/2011
The amendment as voted on was intended to keep states from denying former slaves full citizenship in the U.S. Again, I am not opposed to the amendment as it is currently enforced, but it should also be noted that the U.S. is pretty much the only country that still has this law, with Ireland changing it most recently. Change it or don't change it, but unless the English language was completely different back then, the meaning is clear. If they only intended it to refer to the families of diplomants, then they would have put in two other descriptors for the same class of persons they were referring to. Any English teacher would knock off 10 points on this article for poor reading comprehension.
05:41 PM on 01/21/2011
Agreed but it's probably not poor compregension. It's more likely the author knows full well what that quote means but she is intentionally trying to spin the meaning to fit her own agenda.
06:01 PM on 01/21/2011
If the birthright citizenship clause of the 14th amendment was only intended to apply to slaves and their children, then why didn't it explicitly state that?
10:24 AM on 01/22/2011
Thats like asking why doesn't the Constitution explicitly state that there is a right to privacy. But lets toss your question back at you..

If the cluase only means diplomants and their children, then why didn't it only state that?
04:51 PM on 01/21/2011
""Instead, the language he used strongly suggests he was describing a single excluded class, limited to families of diplomats.""
_____________________________________

I'm not opposed to the amendment as it is currently enforced however even I have to admit that you are tortouring the English language in order to twist it to support your side. While you are arguing against incomplete quotes, you may also want to write a section on how claiming that something doesn't say what it says still doesn't change the actual meaning.
05:06 PM on 01/21/2011
Sorry but you are mistaken. The syntax of the original statement is not crystal clear, but her interpretation is correct and in no way twists language.
10:25 AM on 01/22/2011
Wow, that is ridiculous. If the statement isn't clear, then you can't say with 100% certainty that her interpretation is correct.
05:56 PM on 01/21/2011
You can not take quotes from the debates on 1866 and parse them as if they are twitter posts. This is 19th century oratory, filled with florid excesses of expression, long winded bombast and convoluted syntax. Furthermore, the speech was transcribed by hand, interpreted, as it were, by the recorder, further interpreted and grammatically adjusted by the typesetter and copy editor. Arguing over the syntax of one quote is pointless. However, if you read the subsequent statements by Cowan, Coness, et all, you will see that their understanding of Howard's words was completely different than what the revisionists propose. It is clear that Howard was only speaking of one distinct class, those with diplomatic immunity from our jurisdiction.
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IllTakeTheRedEye
Do you know what a nonemployer business is?
04:25 PM on 01/21/2011
Biased
04:02 PM on 01/21/2011
The 14th amendment does not apply to illegal aliens. It never has.

It does apply to ALL persons* born in this country.

The child of an ilegal alien who is born in the U.S. is not illegal, since there is no law that makes it illegal to be born here. Furthermore, any person born in this country is, by simple definition, not an alien. an alien is someone who was born outside this country.

*The only exceptions to this rule are for those diplomats and their families residing or visiting this country who have been granted diplomatic immunity from our jurisdiction, as per treaty.
04:14 PM on 01/21/2011
Nicely done, you get a fan.
05:43 PM on 01/21/2011
More horrible mangling of the english language? This quote was in direct reference to birthright citizenship. It clearly states that the 14th amendment does not apply to the children of foreigners or aliens.
03:08 PM on 01/22/2011
Only for those accredited with the status of diplomatic immunity, For all others, it applies.
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BigRex
We need to talk about your TPS reports.
11:40 PM on 01/22/2011
And yet those in the debates seemed to understand, better that you I might add, that it applied to the children of immgrants such as the chinese workers in California. Ofcourse...in recognizing that it would deflate your argument that it doesn't apply to "foreigners or aliens"