United States v. Wong Kim Ark

169 U.S. 649 (1898)
Decided March 28, 1898
Justice Gray delivered the opinion of the Court

Case Background

This case involved Wong Kim Ark, born in San Francisco in 1873 to Chinese immigrant parents. The central question was whether a child born in the United States to foreign parents automatically becomes a U.S. citizen.

Central Holding

The Court ruled that Wong Kim Ark was a U.S. citizen by birth, based on the 14th Amendment's citizenship clause. The key principles established were:

  1. Citizenship is determined by "birth within the allegiance" of the United States
  2. Children born on U.S. soil are citizens, regardless of parents' nationality
  3. The 14th Amendment was intended to confirm existing citizenship principles, not create new restrictions

Significant Constitutional Text

"All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States"

The Court emphasized that citizenship depends on "birth locally within the dominions of the sovereign."

Legal Significance

This decision established the principle of "birthright citizenship" that remains in effect today, affirming that children born in the U.S. are automatically American citizens. This case is fundamental to understanding constitutional citizenship rights and the interpretation of the 14th Amendment.