The DC Circuit upheld the district court, ruling that the Fourteenth Amendment’s Citizenship Clause does not extend birthright citizenship to those born in American Samoa, because the Citizenship Clause is textually ambiguous as to whether “in the United States” encompasses America’s unincorporated territories, and it is “impractical and anomalous” to impose citizenship by judicial fiat where doing so would override the democratic prerogatives of the American Samoan people.
https://brian-d-lerner-blog.com/tag/u-s-citizen/
https://brian-d-lerner-blog.com/tag/child-citizenship-act/
https://brian-d-lerner-blog.com/tag/certificate-of-citizenship/