be born or they may be created by naturalization" and that the Constitution "does not, in words, say who shall be natural-born citizens." Under the common law, according to the court, "it was never doubted that all children born in a country of parents who were its citizens became themselves, upon their birth, citizens also. These were natives, or natural-born citizens, as distinguished from aliens or foreigners." The court observed that some authorities "include as citizens children born within the jurisdiction without reference to the citizenship of their parents"—but since Minor was born in the United States and her parents were U.S. citizens, she was unquestionably a citizen herself, even under the narrowest possible definition, and the court thus noted that the subject did not need to be explored in any greater depth. The court then asked whether the right to vote was one of the "privileges or immunities of citizens of the United States" at the time of the Fourteenth Amendment's adoption in 1868. Citing a variety of historical sources, it found that it was not. The court reasoned that the Constitution of the United States did not explicitly give citizens an affirmative right to vote and that, throughout the history of the nation from the adoption of the Constitution, a wide variety of persons—including women—were recognized as citizens but denied the right to vote. For example, at the time of the adoption of the Constitution, none of the original Thirteen Colonies gave all citizens the right to vote, all attaching restrictions based on factors such as sex, race, age, and ownership of land. The opinion continues that "it cannot for a moment be doubted that if it had been intended to make all citizens of the United States voters, the framers of the Constitution would not have left it to implication. So important a change in the condition of citizenship as it actually existed, if intended, would have been expressly declared." Subsequent history The Nineteenth Amendment to the Constitution, ratified in 1920, prohibited sex-based denial or abridgment of any United States citizen's right to vote—thus effectively overruling the key holding in Minor v. Happersett. In some later voting rights cases, however, Minor was cited in opposition to the claim that the federal Constitution conferred a general right to vote, and in support of restrictive election laws involving poll taxes, literacy tests, and the role of political parties in