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jurisdictionwillcitizenshipappellant
jurisdictionwillcitizenship

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Tuaua v. United States

Facts

American Samoa has been a United States territory since 1900, when its traditional leaders ceded authority to the U.S. government. Individuals born in American Samoa are designated as 'non-citizen nationals' under section 308(1) of the Immigration and Nationality Act of 1952, unlike those born in other U.S. territories who are considered American citizens at birth. The appellants challenged this designation, arguing that the Fourteenth Amendment's Citizenship Clause grants them citizenship by birthright.

The South Pacific islands of American Samoa have been a United States territory since 1900, when the traditional leaders of the Samoan Islands of Tutuila and Aunu'u voluntarily ceded their sovereign authority to the United States Government. See Instrument of Cession by the Chiefs of Tutuila Islands to United States Government, U.S.-Tutuila, Apr. 17, 1900. Today the American Samoan territory is partially self-governed, possessing a popularly elected bicameral legislature and similarly elected governor. 1 Complaint at 13 27, Tuaua v. United States, 951 F. Supp. 2d 88 (D.D.C. 2013) (No. 12-cv-01143). The territory, however, remains under the ultimate supervision of the Secretary of the Interior.

Issue

Does the Citizenship Clause of the Fourteenth Amendment extend birthright citizenship to individuals born in American Samoa?

Does the Citizenship Clause of the Fourteenth Amendment extend birthright citizenship to individuals born in American Samoa?

Rule

The Citizenship Clause of the Fourteenth Amendment states that 'all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States.'

The Citizenship Clause of the Fourteenth Amendment provides that '[a]ll 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.' U.S. CONST. amend. XIV, 1, cl. 1.

Analysis

The court analyzed the text and structure of the Fourteenth Amendment, concluding that the phrase 'in the United States' is ambiguous regarding its application to unincorporated territories like American Samoa. The court emphasized that imposing citizenship would contradict the democratic will of the American Samoan people, who have expressed their opposition through their elected representatives. The court found it impractical to extend citizenship in this context.

The court analyzed the text and structure of the Fourteenth Amendment, concluding that the phrase 'in the United States' is ambiguous regarding its application to unincorporated territories like American Samoa. The court emphasized that imposing citizenship would contradict the democratic will of the American Samoan people, who have expressed their opposition through their elected representatives. The court found it impractical to extend citizenship in this context.

Conclusion

The court affirmed the district court's judgment, concluding that the Citizenship Clause does not extend birthright citizenship to those born in American Samoa.

The judgment of the district court is affirmed; the Citizenship Clause does not extend birthright citizenship to those born in American Samoa.

Who won?

The United States prevailed in the case, as the court upheld the designation of individuals born in American Samoa as non-citizen nationals, respecting the democratic choice of the American Samoan people.

The United States prevailed in the case, as the court upheld the designation of individuals born in American Samoa as non-citizen nationals, respecting the democratic choice of the American Samoan people.

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