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So domicile cant be the rule, because then you cant unproblematically grant citizenship to the children of formerly enslaved people. Birthright citizenship was enshrined in 1866 by way of the Fourteenth Amendment, which reads: All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. Sauer was similarly flustered by a query from Justice Neil Gorsuch, who asked if the government considered Native Americans as birthright citizens

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