not primary and paramount, but secondary and subordinate; it was only an incident of State citizenship. Story wrote in his Commentaries: “It has always been well understood among jurists in this country that the citizens of each State in the Union are _ipso facto_ citizens of the United States.” Said Mr. Calhoun, in his speech on the “Force Bill,” delivered in 1833, “A citizen at large, one whose citizenship extends to the entire geographical limits of the country without having a local citizenship in some State or Territory, a sort of citizen of the world, such a citizen would be a perfect nondescript; not a single individual of this description can be found in the entire mass of our population.” Mr. Justice Curtis, in his dissenting opinion in the Dred Scott case, took the position that citizenship of the United States was dependent entirely upon citizenship of some one of the several States as such. Mr. Calhoun and Mr. Curtis agreed that the power of Congress, under the constitution, “to establish an uniform rule of naturalization,” was simply the power “to remove the disabilities of foreign birth.” On the other hand, Mr. Justice Marshall, in 1832, held, in the case of Gassies vs. Ballon, that a naturalized citizen of the United States, residing in any State of the Union, was a citizen of that State. Marshall and Curtis, in their respective views, represented the difference which obtained between the advocates of State rights and their opponents, on the question of citizenship of the United States. By the adoption of the Fourteenth Amendment this was all changed, and is now placed beyond controversy. The principle is inverted.[60] Citizenship of the United States now depends in no way upon citizenship in any State or Territory, but merely upon birth in the United States, coupled with subjection to the jurisdiction thereof, or upon naturalization. The term “subject to jurisdiction,” must be construed in the sense in which the term is used in international law, as accepted in the United States as well as in Europe; and by this law the children born abroad of American citizens are regarded as citizens of the United States, with the right, on reaching full age, to elect one allegiance and repudiate the other, such election to be final. If the Fourteenth Amendment furnished an exhaustive and comprehensive definition of citizenship, such children would not be citizens. That it does not furnish such definition is intimated by Mr. Justice Miller in the Slaughter-House cases, and by Mr. Justice Field in his dissenting opinion. In the same cases it was decided that the privileges and immunities appurtenant to citizenship of the United States were different and distinct from those appurtenant to State citizenship; being merely those special and limited privileges and immunities arising from the special and limited scope under the constitution of the federal or United States authority. The theory laid down in the Slaughter-House cases suggests a query as