Under the enforcement clause Congress has legislated against peonage, that is, a condition of enforced servitude by which the servitor is restrained of his liberty and compelled to labor in liquidation of some contract, debt, or obligation. But without such legislation, State statutes imposing imprisonment or servitude for non-performance of contractual obligations are invalid as in conflict with the provisions of the amendment.—Emlin McClain, in the _Cyclopedia of American Government_, Vol. III, p. 536. In the early days many of the American colonies permitted imprisonment for debt, and one of the greatest patriots and philanthropists of colonial times, Robert Morris, was imprisoned for debt by the State of Pennsylvania. 77 James Bryce has written of our government: “The American Union is ... a state which, while one, is nevertheless composed of other states even more essential to its existence than it is to theirs.” 78 Constitution of the United States, Amendment XIV. Sec. 1. A person may attain to citizenship in the United States in any of seven different ways: 1. By birth—i.e. natural born. 2. By naturalization, which usually requires continuous residence for five years. 3. By treaty regulation. 4. By statute of Congress. 3. By annexation of territory. 6. By marriage—if a foreign woman marries an American citizen. 7. By honorable discharge from the army or navy, upon which the court admits to citizenship regardless of the time of residence in the United States. In the United States we recognize a dual citizenship—citizenship in the United States, and citizenship in a State. Any person who is a citizen of the United States is also a citizen of the State wherein he or she resides. Nine different States grant the right of suffrage and State citizenship to such foreigners as take out their first naturalization papers. These States are Alabama, Arkansas, Indiana, Kansas, Missouri, Nebraska, Oregon, South Dakota, and Texas. Citizenship must not be confused with the right of suffrage. Neither one necessarily includes the other. All citizens cannot vote—children for example. All voters are not necessarily citizens, those in the above nine States for example. Aliens in the United States have practically all the civil rights that are enjoyed by citizens, but they do not have political rights. An alien may purchase, own, and convey property. He may sue and be sued in the courts.