If "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," focusing on the specific phrase "subject to the jurisdiction thereof,""
attempting to make a claim that "Birth in the United States does not by itself entitle a person to Citizenship" and that a person must also be subject to the jurisdiction and taxation of the United States to claim citizenship status."
Upon returning to this topic, Department of Justice lawyers argued the phrase "subject to the jurisdiction thereof" should be interpreted "to exclude Indigenous Peoples, citing the 1884 Supreme Court case of Elk v. Wilkins, in which the court decided that
"because members of Indian tribes owe 'immediate allegiance' to their tribes, they are not 'subject to the jurisdiction' of the United States and are not constitutionally entitled to Citizenship," setting an ominous tone,
Comments
If Indigenous people aren't citizens, then nobody is.
https://storage.courtlistener.com/recap/gov.uscourts.wawd.343943/gov.uscourts.wawd.343943.36.0.pdf