The phrase, “who might herself be lawfully naturalized,” has given rise to much controversy, and its significance has not been definitively declared. Some authorities hold it to apply only to the Oriental races excluded as such from citizenship; others hold that it should be interpreted to call for an examination of the wife as to her views on the subject of anarchism, polygamy, etc. But the general tendency seems still to hold that the family is one, _and the husband that one_; that, therefore, _any_ sort of wife comes into citizenship automatically with the naturalization of her husband. “A WOMAN WITHOUT A COUNTRY” The nonresident American-born wife of a foreigner may, upon his death or the termination of the marriage in any other legal manner, resume her American citizenship by registration with a United States consul. But what of the woman, born an American citizen, married to an alien who continues to live? The United States statute of 1907 undertakes to expatriate her--“any American woman who marries a foreigner shall take the nationality of her husband.” But, in absence of specific treaty, or of legislation in the husband’s country to that effect, that pronouncement is without force or validity outside of the United States; Congress has no power to confer or inflict the citizenship of any other nation upon anybody. “The operation of this statute might easily deprive a woman of her American citizenship--even if she had it by right of birth--and leave her with none.”[33] It seems rather extraordinary that of all the judges of American naturalization courts replying to the questionnaire of the Americanization Study, whose results are discussed elsewhere in this volume,[34] not one referred directly to this aspect of the citizenship of the American woman. The person without a country is an alien everywhere his foot may fall--no matter under what roof or flag he may seek shelter. He is subject to the local laws and limitations governing aliens; but he has no homeland whose flag he may call his own; no government anywhere to which he may appeal for protection; he is dependent without recourse upon the hospitality, grace, and mercy of the public authorities and the people of the land where he chances to make his habitation. THE AMERICAN UNDER THREE JURISDICTIONS In notable contrast with this dismal prospect, the American citizen, native or naturalized, is quite otherwise. He is subject to _three_ concurrent jurisdictions. This fact is a source of great puzzlement to many an applicant for citizenship, and constitutes one of the stumbling-blocks which beset him in his initial understanding of our system of government. First, the nature of his relation to the United States. In the case of Minor _vs._ Happersett,[35] decided in 1875, the Supreme Court of the United States said: