from
a Negro residing as a free man in one of the States at the date of
ratification of the Constitution. That basic document did not
contemplate the possibility of Negro citizenship.[3] By the Fourteenth
Amendment this deficiency of the original Constitution was cured.[4]

JUDICIAL ELUCIDATION OF THE CITIZENSHIP CLAUSE

By the decision in 1898 in United States _v._ Wong Kim Ark,[5] all
children born in the United States to aliens, even temporary sojourners,
if they are not exempt from territorial jurisdiction, are citizens
irrespective of race or nationality. But children born in the United
States to alien enemies in hostile occupation or to diplomatic
representatives of a foreign state, not being "subject to the
jurisdiction thereof," i.e., of the United States, are not citizens.[6]
Likewise persons born on a public vessel of a foreign country while
within the waters of the United States are not considered as having been
born within the jurisdiction of the United States, and hence are not
citizens thereof.[7] Conversely, a Chinese born on the high seas aboard
an American vessel of Chinese parents residing in the United States was
declared not to be a citizen on the ground of not having been born "in
the United States."[8] But a child who was born in like circumstances of
parents who were citizens of the United States was declared, shortly
before the Civil War, to be a citizen thereof.[9]

NATIONAL AND STATE CITIZENSHIP

With the ratification of the Fourteenth Amendment a distinction between
citizenship of the United States and citizenship of a State was clearly
recognized and established. "Not only may a man be a citizen of the
United States without being a citizen of a State, but an important
element is necessary to convert the former into the latter. He must
reside within the State to make him a citizen of it, but it is only
necessary that he should be born or naturalized in the United States to
be a citizen of the Union. It is quite clear, then, that there is a
citizenship of the United States, and a citizenship of a State, which
are distinct from each other, and which depend upon different
characteristics or circumstances in the individual."[10] National
citizenship, although not created by this amendment, was thereby made
"paramount and dominant."[11]

CORPORATIONS

Citizens of the United States within the meaning of this article must be
natural and not artificial persons; a corporate body is not a c