<P> In Elk v. Wilkins, 112 U.S. 94 (1884), the Supreme Court denied the birthright citizenship claim of an American Indian . The court ruled that being born in the territory of the United States is not sufficient for citizenship; those who wish to claim citizenship by birth must be born subject to the jurisdiction of the United States . The court's majority held that the children of Native Americans were </P> <P> no more "born in the United States and subject to the jurisdiction thereof," within the meaning of the first section of the Fourteenth Amendment, than the children of subjects of any foreign government born within the domain of that government, or the children born within the United States of ambassadors or other public ministers of foreign nations . </P> <P> Thus, Native Americans who voluntarily quit their tribes would not automatically become U.S. citizens . Native Americans were granted U.S. citizenship by Congress half a century later in the Indian Citizenship Act of 1924, which rendered the Elk decision obsolete . </P> <P> In the case of United States v. Wong Kim Ark, 169 U.S. 649 (1898), the Supreme Court ruled that a person who </P>

Being born in the us makes you a citizen