"Citizens of the United States and of the State Wherein They Reside"

"Supreme Court Justice Horace Gray wrote the majority opinion, which was joined by six other justices. Gray argued that common-law doctrine held that a person became a citizen by virtue of jus soli, his birth in the United States, rather than his blood line. 'The right of citizenship [in the United States] never descends in the legal sense, either by the common law, or under the common naturalization acts. It is incident to birth in the country, or it is given personally by statute.'
"In other words, even though Wong's parents were 'subjects of the Emperor of China,' non-citizens, and indeed not eligible to become U.S. citizens, at birth he became a citizen of the United States."

Erika Lee in The New York Daily News looks back to the 1898 case of Wong Kim Ark v. United States.