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This is written for you, to you and by you. Anyone who claims the elite title of "Shoe Addict" is classified to have one if not all of the following characteristics:
-You have trouble shutting your closet door(s).
-You keep all your shoes in their original boxes with Polaroid pictures attached on the outside for proper identification.
-You have over 75 pair of shoes that you claim to wear.
-You classify shoes as a completely separate category from boots and don't include your boots in your actual "shoe" count.
-You try to justify and reason to yourself and others about the new pair of shoes you're about to buy explaining how you "just don't have anything like theeeese" in your closet.
As the weather continues to warm up, so will your feet. Even our ancestors wore sandals. The history of the sandal reaches back to ancient Roman and Greek times as the oldest known form of footwear. The shoes were made from a variety of natural resources such as certain types of sturdy leaves, twigs or bark and were eventually made from cork and rope. The oldest pair was found in a cave in Oregon and was estimated to be up to 10,000 years old.
Sandals today have come a long way from when our ancestors wore them. They have bombarded the fashion world with more shapes, colors, styles and designer names than you can count. Today's production of sandals (and most shoes), use hundreds of types of natural and manmade materials including plastic, rubber and even wood.
Today I'm firing the gunshot at the starting line for you; this summer, divide, conquer and purchase the cutest sandals you can find. It only takes a stroll down the block or a short ride on the subway to cross paths with the thousands of sandal styles that are out this season and will keep your feet feeling cool and looking hot all summer.
If you don't already know, 82nd Street in Jackson Heights is one of the best kept secrets in fashionable footwear. There isn't enough time in the world to visit store after glorious store of the hottest, trendiest, CUTEST sandals I've seen lately in any magazine or on anyone's feet for that matter. The sales are ON, stores are PACKED and sizes and styles are going FAST, so sashay on over to 82nd Street for the best feet anywhere!
All of the pictured styles are available at Prima Donna (37-47 82nd Street) and Bakers (37-44 82nd Street) in Jackson Heights. For more shopping, styling, and fashion tips, visit my blog at www.thedressrecycler.com.
Happy shopping!
-The Dress Recycler, "Your Bargain Fashion Superhero!


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You can choose a custom URL based on your display name, your YouTube username, any current vanity URLs that you have, or the name of your linked website (all subject to availability).
When sharing your custom URL, you can use whatever capitalization and accents you'd like. For example, both youtube.com/c/yourcustomname and youtube.com/c/YourCustómNámé would send viewers to the same channel.
Custom URL eligibility
To create a custom URL for your channel, your account needs to:
- Have 100 or more subscribers.
- Be at least 30 days old.
- Have an uploaded photo as a channel icon.
- Have uploaded channel art.
Set up a custom URL for your channel
If you're eligible for a custom URL, you'll see a notice in your advanced account settings, get an email notification, and may see a notification in your Creator Studio dashboard.
Before you start: Keep in mind that you can't edit a custom URL once it's created.
- Sign in to YouTube.
- Go to your advanced account settings by clicking your profile picture in the top right Settings Advanced settings.
- Under "Channel settings," select the link next to You're eligible for a custom URL. You'll only see this link if your channel is eligible.
- In the "Get a custom URL" box, you'll see the custom URL(s) you've been approved for. You can't change the part in the gray box, but you may need to add a few letters or numbers to make the URL unique to your channel.
- Carefully read and understand the "Custom URL Terms of Use" and select the box to agree to them, then click Change URL.
- Once a custom URL has been approved, you can't request to change it, so make sure this is the custom URL you want before clicking Confirm choice.
Once you have a custom URL, your audience can reach your channel by using that custom URL such as youtube.com/yourcustomname, which will take viewers to your channel homepage.
Remove custom URL & claim a new one
You can remove a custom URL for your channel up to 3 times per year.
- Sign in to YouTube and go to your "About me" page.
- Select the account with your YouTube channel in the top right. You may have to click All of your Brand Accounts if your account is not in the list.
- Find your current custom URL under "Sites" and click Edit .
- Next to the URL you want to remove, click X.
- Click OK.
If you're eligible, you can claim a new custom URL right away using the steps above. It may take a couple of days for the previous URL to deactivate.

subset: commoncrawl


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University memorial service for Sept. 11 victims, Dec. 9
Oct. 30, 2001 10:52 a.m.
The University will hold a memorial service for Princeton alumni who were lost in the Sept. 11 attacks. The service will take place at 1:30 p.m. Sunday, Dec. 9, in the University Chapel.
The event is open to friends and family members of the victims and the University community. For inquiries, call the Alumni Council at (609) 258-1900.


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The McCarran International Airport is located approximately five miles south of downtown Las Vegas. The major commercial airport serves the Las Vegas Valley and surrounding areas. Renting a vehicle at LAS has been made simple to benefit incoming guests. The 24 hour a day, McCarran Rent-A-Car Center can be found on Gillespie Street which is three miles from the airport.
Pick Up at Terminals
Rental cars can be picked up at either terminal one or terminal three depending on the customer's choice.
Terminal One
Terminal Three
Returning of a Rental Car
Returning a rental car is done at the McCarran Rent-A-Car Center.
Renting a car has been made simple at McCarran Rent-A-Center with shuttles going to and from the airport at a continuous rate. The large signs will help you locate your appropriate rental area.


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JR 4/04/2010 05:41:00 PM Tweet Edit
_______________________________________________________________« Prev Post Next Post »
These are awesome thanks for posting them
Interesting how Doc says that's the rotation. So less Sheed and no Marquis or Nate. Wouldn't have guessed that...
I hope less Sheed was due to the T and exchange he and Doc had. I still believe this team can win the championship but it will take big, productive minutes from him to get out of the east vs Clev and Orlando.


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Whether it's helping Mexican university students bridge the gap between industry and academia, or providing Ugandan children with basic health education programs, many teams this year have chosen to tackle the difficult problems facing the global education sector.
In recent years, social innovators have joined the ranks of talented teachers and school administrators in rethinking traditional school models, finding creative ways to improve educational quality and access.
A new policy paper by the McGraw-Hill Research Foundation might be of interest to those pursuing projects related to educational reform.
How Social Entrepreneurship is Helping to Improve Education Worldwide (available online) highlights the distinct contributions of social innovators in helping to improve early childhood education in low-income communities, creating alternate channels for funding, and providing basic skills to at-risk populations across the globe.
Author Rupert Scofield, President and CEO of the Foundation for International Community Assistance, draws from several interesting case studies that illustrate the potential for social enterprise to solve issues ranging from poor educational access to the growing achievement gap. The key to the success of these enterprises, Scofield writes, lies in their ability to effectively utilize business practices emphasizing sustainability and scalability – two important attributes of any winning IDEAS Challenge project! Here are a few examples:
In the Bronx, the Women's Housing and Economic Development Corporation (WHEDco) not only runs multiple afterschool programs and summer camps, but has also created hundreds of revenue-generating businesses within the community, helping to ensure the continued success and long-term sustainability of its programs.
In India, where harsh inequities prevail and 90 million women remain illiterate, the Mann Deshi Foundation provides vocational training and financial literacy to women in impoverished communities. It also runs the Mann Deshi Business School, which delivers microbusiness courses in mobile classrooms, and the Mann Deshi Mahlia Bank, which provides loans for its business school graduates to start microenterprises.
DonorsChoose.org is a charitable marketplace where teachers can make simple classroom requests, from pencils to microscope slides, for their students. As of August 2011, the website has generated $85 million benefitting more than 5 million schoolchildren in the U.S. The website notably allows individual donors to contribute to its overhead costs (with 76% choosing to do so), and has established diverse funding streams that include multiple corporate sponsors.
We hope that these examples of powerful — and sustainable — social innovations offer a bit of inspiration for those joining the education cause!


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The United States will shift the majority of its naval fleet to the Pacific by 2020 as part of a new strategic focus on Asia, Pentagon chief Leon Panetta told a summit in Singapore.
The decision to deploy more ships to the Pacific Ocean, along with expanding a network of military partnerships, was part of a "steady, deliberate" effort to bolster the US role in an area deemed vital to America's future, he said on Saturday.
And he insisted the switch in strategy was not a challenge to China, saying it was compatible with the development and growth of the fast-growing Asian power.
Panetta said "by 2020, the Navy will re-posture its forces from today's roughly 50/50 percent split between the Pacific and the Atlantic to about a 60/40 split between those oceans.
"That will include six aircraft carriers in this region, a majority of our cruisers, destroyers, littoral combat ships, and submarines."
The US Navy currently has a fleet of 285 ships, with about half of those vessels deployed or assigned to the Pacific.
Although the total size of the overall fleet may decline in coming years depending on budget pressures, Pentagon officials said the number of naval ships in the Pacific would rise in absolute terms.
The United States also planned to increase the number of military exercises in the Pacific and to conduct more port visits over a wider area extending to the Indian Ocean.
Panetta was speaking to mainly Asian defence officials and officers from 27 countries at the Shangri-La Dialogue, a summit organised by the London-based International Institute for Strategic Studies.
The speech appeared designed to reassure allies worried about Beijing's more assertive stance in the South China Sea that Washington will back its much-publicised "pivot" to Asia with concrete action.
Panetta said budget woes in Washington would not affect the plan to tilt towards Asia, which would take years to fully realise.
The United States planned new investments in capabilities needed "to project power and operate in the Asia-Pacific," including radar-evading fighter jets, a new long-distance bomber, electronic warfare and missile defences, he said.
"But make no mistake -- in a steady, deliberate, and sustainable way -- the United States military is rebalancing and is bringing an enhanced capability and development to this vital region," he added.
Military commanders are revising doctrine to take into account new weapons that "could deny our forces access to key sea routes and lines of communication."
Amid a growing US-China rivalry, American officials privately acknowledge the push for a larger military footprint is meant to reinforce US diplomacy when confronting Beijing's assertive stance in the South China Sea.
But Panetta insisted that Washington wanted dialogue with Beijing and not conflict.
"Some view the increased emphasis by the United States on the Asia-Pacific region as some kind of challenge to China. I reject that view entirely," he said.
"Our effort to renew and intensify our involvement in Asia is fully compatible... with the development and growth of China. Indeed, increased US involvement in this region will benefit China as it advances our shared security and prosperity for the future."
But in laying out core US principles in the region, Panetta made clear Washington opposed any attempt by Beijing to make unilateral moves in its push for territorial rights in the South China Sea.
Disputes had to be resolved through agreed-upon rules among all countries and based on international law, he said.
Panetta also said the United States is "paying close attention to the situation in Scarborough Shoal in the South China Sea," where the Philippines and China have been locked in an argument over territorial rights.
The Philippines is among a number of countries with overlapping territorial claims in the potentially resource-rich South China Sea.
Panetta alluded to US concerns over cyber intrusions that Washington has blamed on China, saying that in talks with Beijing the two sides had "agreed on the need to address responsible behaviour in cyberspace and in outer-space."


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Yankees on two-game slide heading into Subway Series
MILWAUKEE >> The New York Yankees were the first team this season to get to Brewers closer Francisco Rodriguez, and they still lost.
Manager Joe Girardi's bullpen had its own problems.
Mark Reynolds had a game-ending RBI single off reliever Adam Warren with two outs in the ninth inning, after Mark Teixeira homered off Rodriguez with two outs in the top half, to give Milwaukee a 6-5 win Sunday.
"You want to go up there with a zero and give your offense a chance to get back in there. I just couldn't quite do it," said Warren (1-2).
New York has lost two straight going into this week's Subway Series with the Mets.
Making matters worse was that the Yankees battered starting rotation took another blow after struggling left-hander CC Sabathia was placed on the disabled list before Sunday's game with a right knee injury. Ivan Nova (elbow) is already out for the season and Michael Pineda (upper back) is on the DL.
"This is tough. That's why I didn't want to say anything but I'll do more damage to the team by trying to hide it," Sabathia said. According to Girardi, Sabathia had a little fluid in the knee and "needed a little time off."
New York still came close to heading home with a win despite another blow to the rotation. But the bullpen gave up four hits and two runs in three-plus innings.
Rickie Weeks doubled just inside the first base line with one out before going to third on a wild pitch by Warren.
Reynolds, who briefly played for New York last year, held his right index finger in the air after his hard chopper bounced past diving third baseman Yangervis Solarte at third to drive in Weeks two batters later.
"Great team win, everybody chipping in," manager Ron Roenicke said.
The Yankees wasted the homer from Teixeira, who reached out for a low and away, full-count pitch from Rodriguez for a homer to right. It was the first run allowed all season by the veteran closer, and the first blown save after 15 successful opportunities.
Rodriguez (1-0) did pick up the win. The Brewers' typically stingy bullpen gave up two runs to New York, including Solarte's run-scoring single in the seventh that drew New York within a run.
In the end, the Brewers' bats picked up the relievers.
"Sometimes you've got to pick them up because he's been picking us up a lot," Reynolds said.
Phelps had a so-so outing in his second start of the season after making nine appearances out of the bullpen for the Yankees. Starting in place of Pineda, Phelps allowed eight hits and walked three in five-plus innings, allowing the leadoff runner to reach base five times.
But that performance might be good enough for the Yankees' depleted rotation. The lineup gave Phelps support early while taking advantage in a three-run first of starter Matt Garza, who allowed three walks and two hits in the inning, including Kelly Johnson's two-run double. Garza settled down to allow six hits, four walks and three runs in five innings.
"I thought our at-bats were still good," Girardi said. "We hit some balls hard but we just weren't able to bunch them together anymore."
Prior to the game, the Brewers gave Yankees shortstop Derek Jeter a gold-plated bat and a $10,000 check for his Turn 2 Foundation, which promotes healthy lifestyles among youth. The gifts were presented by Dick Groch, a special assistant to general manager Doug Melvin. Groch was the Yankees scout in 1992 who recommended the team draft Jeter in the first round that year.
NOTES: Yankees C John Ryan Murphy's groundout to second was overturned to an infield single in the eighth after manager Joe Girardi requested a replay review, which took 53 seconds. ... Carlos Gomez was hit in the left forearm by a pitch from Phelps in the third, causing him to writhe in pain a few seconds. He stayed in the game. ... The Yankees come home for the Subway Series against the Mets, sending Huroki Kuroda (2-3) to the hill. The Brewers have Monday off, with Marco Estrada (2-1) scheduled to start Tuesday against the Pirates.


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Sales: M-F 8:30AM-7PM SAT 8:30AM-6PM | Service and Parts Hours: M-F 7AM-6PM SAT 8AM-3PM
*Please contact dealer to verify price, options, and other vehicle details.
MPG Disclaimer: *Based on 2018 EPA mileage and driving range ratings. Use for comparison purposes only. Your MPGe/MPG and driving range will vary depending on driving conditions, how you drive and maintain your vehicle, battery age/condition, and other factors.
Prices shown are manufacturer suggested retail prices only and do not include taxes, license, or doc fee. Requires financing with an Allen Honda approved lender. Manufacturer vehicle accessory costs, labor and installation vary. Please contact us with any questions. Requires financing with an Allen Honda approved lender.
Each used car on a 2014 or newer with under 100,000 miles will have a 12 month 12,000 mile comprehensive warranty, 2 sets of keys, full tank of gas and a copy of the repairs performed at our state of the art service department.


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Here are the highlights from the workshop iPads for ELLs: Enhancing Critical Thinking which we co-presented at the 2011 Long Island Tech Summit on October 18th.
The workshop focused on three essential questions and provided a brief overview of the iPad and how it can help ELLs reach their full academic potential.
How can educational iPad applications strengthen and support critical thinking for English Language Learners?
When the the right educational iPad application is integrated into a content rich lesson, it provides multi-sensory access to that content, facilitating comprehension and allowing ELLs to participate more effectively in academic discourse. Apps can be used to scaffold activities that may otherwise be difficult for ELLs to understand. In addition, using multimedia apps to deliver content enhances traditional methods of delivery that are largely text-based. This opens up the door to critical thinking by lowering the language barrier and channeling the instructional focus to academic content.
The following quote sums up the need to provide content-based language instruction that challenges ELLs to think critically in order to attain academic parity with native English language speakers.
"Merely using the language and knowing the meaning is not enough. To become proficient in a language, learners need to use creative and critical thinking through the target language."
From: Muhammad Kamarul Kabilan. (June 2000) A. Creative and Critical Thinking in Language Classrooms The Internet TESL Journal, Vol. VI, No. 6,
How can teachers integrate iPads into their classroom toolbox?
Before selecting an app for use with students, educators must first identify the instructional goals and objectives of the lesson, not the other way around. Instead of discovering a fun or exciting app and trying to build a lesson around the app, take a lesson that has proven to be successful and find apps that can be integrated into the lesson to scaffold the content, differentiate the instruction and enhance the outcome.
For example an interesting project idea The Alternate History Project was showcased at a poster session at ISTE 2011 http://tinyurl.com/whatifhistory . Integrating social studies apps such US History Tools or On This Day as well as a graphic organizer app like Popplet and a digital media app such as Discovery Ed Streaming (Mobile.DiscoveryEducation.com) can help ELLs meet the goals of this project successfully.
How can iPads, digital media and Web 2.0 tools remove boundaries and promote academic achievement for ELLs?
Finally, it is important to explore the bigger picture of using instructional technology and to identify the purpose for using iPads in the classroom. Consider the following list of pedagogical goals in order to identify how this device can help promote equitable educational opportunity for ELLs.
- For Intervention (RtI)
- For Enrichment
- For Assistive Technology
- For Digital Literacy
- For Reading
- For Organizing Resources
If you'd like to read more about how teachers are using iPads with ELLs read ELL to Go by Jennifer Demski


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Hands-On: Verizon's Droid DNA Wows With High-Def Display
Verizon's Droid DNA
The brand-new HTC Droid DNA smartphone for Verizon, which was unveiled on Tuesday in New York City, has a laundry list of cutting-edge specs — not only is it the most high-definition smartphone yet, it runs lightning fast.
Mashable snagged some hands-on time with the latest HTC smartphone, which runs on Android 4.1 Jellybean, to see if the promised features translated well to the real world. And upon first impression, the answer is yes. Oh, yes.
Despite its 5-inch screen, the Droid DNA fits comfortably in your hand, even if they are on the smaller side. At 0.38 of an inch thick and weighing in at about 4.8 ounces, it doesn't feel as bulky as the Samsung Note II. Speaking of design, the black body with a slight red trim nicely echoes the look of the Android brand.
But the real game-changer is its stunning Super LCD3 display, which is the first phone display capable of showing 1080p video at full resolution. Its pixel density (440ppi) blows away the rest of the competition by a long shot — the iPhone 5 has 326 ppi. When watching movie trailers on the Droid DNA, checking out photos or even surfing the web, the resolution was crisp, bright and colors popped in ways we didn't even know they could on a small device.
The Droid DNA packs a powerful punch, thanks to its quad-core 1.5GHz Snapdragon S4 processor. Navigating through the hardware and software was intuitive too. It didn't take long to figure out holding the home button down launches Google in a web browser as a short cut.
There are also lots of newly-added camera perks. If you're taking pictures on the go and the lock screen pops up after being temporarily dormant, you don't have to re-enter your password to log back in — you can bypass the lock screen entirely, so you don't miss the shot you want. Another sweet perk is the countdown timer, which gives you a few seconds to prep before the picture is taken.
Although we will have a longer, in-depth review of the Droid DNA in the next few days, we were impressed with the device with what little time we had with it at the launch event.
The Droid DNA will be available for purchase the day before Thanksgiving for $199 on a two-year contract. Pre-orders start today.


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perhaps you've noticed things look a bit different around here, that's because i've implemented a brand spanking sparkly shiny new look . the layout is a bit simpler – with all the categories and archives far easier to navigate. this mini-makeover left me with precious little time to do an actual post… but things will be back to normal soon, i promise.
i would love and appreciate any comments and feedback.


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Tech Week Ahead: New Samsung Smartwatch Coming
WSJ's Scott Austin looks ahead to the week ahead in tech, including the possibility of a Verizon-Vodaphone megadeal happening and a new Samsung smartwatch. Photo: Getty Images. Photo: Getty Images
This transcript has been automatically generated and may not be 100% accurate.
... while commit Digits I'm Steve Russolillo we all get back to the old grind after Labor day ... in the world of tech kicks into high gear to Wall Street Journal tech editor Scott Austin has some key stories to watch for ... Scott thanks so much for joining us Eva ... so what we have here a delivered a ... potentially Verizon and Vodafone some big stories now that ... summer's coming soon and that will start off with Verizon and Vodafone ... which could be one of the largest ... deals on record ... hundred thirty billion dollars this of course is Verizon Communications trying to take over for ... the forty five percent stake in Verizon Wireless the lucrative U S carrier ... away from Vodafone the U K company ... and die ... you know this broke earlier this week on Wall Street Journal ... um ... you know it it's it's an amazing deal has been talked about for for earlier years say that and they then there'd been talks and they came back in now been ... renewed and it seems like they're actually serious now ... Verizon is really ... trying to raise upwards of ... twenty fifty billion dollars ... I'm good at it to me or is it the place ... I said of his deal here and especially to be uh hundred and thirty billion dollars which is just astonishing to think about the world of ... MMA right now and have deals and to sort of dried up southern view of this magnitude is it is amazing in earnest here I think that ... there are at a price difference about thirty billion dollars so you coming together on that price but even just the complexity ... of putting this deal together and again the reason this debt ... alseep of actually happens but ... while council does seem like it's it's it's accelerated to have your talks on removing that where I'd another thing you're watching Samsung ... the strength of the interesting you know it is the sort of Samsung next week ... on Wednesday planting its flag in that in this more I watch ... a re now ... there's a lot of talk about wearable devices ... how we Ardi know that Apple is working on its own smartwatch have essentially ... can next to your phone in Apple's case would be to the I phone ... and do everything you do everything offenders is now they've all the time but note the jets and ... in its name in your phone or anything but ... I'm you know I think what will see next week from Samsung and this is going to be unveiled in Berlin ... ahead of a big consumer electronics ... conference call I think ... I don't think you're going to see anything that's so store in air that we haven't necessarily seen before ... they're couple major power watches on the market ... up from a couple ... and another one from Sony Sony smartwatch ... this one ... from Sen fund is expected to be fairly similar to the touch screen and some messaging features we get an email or Facebook or Twitter messages ... and then of course the gavel for post of apps ... and yet we'll we'll be his seat and the use cases for this ... is that you know I think will be some type of doctors but ... I you know maybe some people and businesses can use it or you're riding a bike or you're eighteen you can see some use but it's the kind of take solace in the preface the rest of the visitor kicks off a month full of gadgets next to last at last but not least that Yahoo a new logo for Yahoo to twenty thirty days for the euro and for our right to not getting if they're not getting rid of their exclamation point ... and getting rid of that ... fear not I would say I got to hang ... them a less than a month ago said that there are ... going to come out in thirty days with the new year so everyday since then they've come now ... with a different look so it's not can actually be none of this with the vicinity of the actual some of them are are ... people it's a pretty pretty for ... others ... looked TNT said ... the deal with drastically different but you know the point of this is kind of that sort of a marketing campaign can make in a way ... to get people thinking about how it's kind of growing in a way that ... you gotta lot coverage over to seize the area it was actually talking about Yahoo now ... and is is Grissom ... Myers where you ... are really trying to reinvent the company ... in a different way and bring a different mindset ... that says Coulter so they'll will will see on Thursday Yahoo Unveils that ... the big drum roll and ... I'm curious on the reaction ... of course was that there will certainly be correct and either way ... Scott Austin thank you so much ... that's it for digits I'm Steber slow ...


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A Quick Claw is an item that raises the speed of a Pokémon and gives it a 20% chance to attack first if its speed is lower than that of its opponent. It is not affected by Trick Room.
- FR/LG: Safari Zone
- G/S/C: National Park
- R/S/E: Rustboro City or Battle Frontier (Emerald)
- D/P/Pt: Jubilife City
|This article is a stub.
Please help the Pokémon Wiki by expanding it.
Community content is available under CC-BY-SA unless otherwise noted.


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Birthright citizenship in the United States
Birthright citizenship in the United States refers to a person's acquisition of United States citizenship by virtue of the circumstances of his or her birth. It contrasts with citizenship acquired in other ways, for example by naturalization later in life. Birthright citizenship may be conferred by jus soli or jus sanguinis. Under United States law, U.S. citizenship is automatically granted any person born within and subject to the jurisdiction of the U.S. This includes the territories of Puerto Rico, the Marianas (Guam and the Northern Mariana Islands) and the U.S. Virgin Islands, and also applies to children born elsewhere in the world to U.S. citizens (with certain exceptions).[1][2]
Current U.S. law 1
Statute, by birth within U.S. 1.1
- U.S. territories 1.1.1
- Outlying possessions 1.1.2
Statute, by parentage 1.2
- Children born overseas to married parents 1.2.1
- Children born overseas out of wedlock 1.2.2
- Eligibility for office of President 1.3
- Statute, by birth within U.S. 1.1
Legal history 2
- English common law 2.1
- Federal law 2.2
- Dred Scott v. Sanford 2.3
- 1862 opinion of the Attorney General of the United States 2.4
- Civil Rights Act of 1866 2.5
- Fourteenth Amendment to the United States Constitution 2.6
- Expatriation Act of 1868 2.7
- 1873 opinion of the Attorney General 2.8
- Indian Citizenship Act of 1924 2.9
U.S. Supreme Court case law 3
- Sailor's Snug Harbor 3.1
- The Slaughter-House Cases 3.2
- Elk v. Wilkins 3.3
- United States v. Wong Kim Ark 3.4
- Canadians transferred to U.S. hospitals 4
Current controversy 5
- Original meaning 5.1
- Modern dispute 5.2
- See also 6
- Notes 7
- References 8
- Sources 9
- Further reading 10
- External links 11
Current U.S. law
Citizenship in the United States is a matter of federal law, governed by the United States constitution.
Since the adoption of the Fourteenth Amendment to the constitution on July 9, 1868, the citizenship of persons born in the United States has been controlled by its Citizenship Clause, which states:
"All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside."[3]
Statute, by birth within U.S.
As of 2011, United States Federal law (8 U.S.C. § 1401) defines who is a United States citizen from birth. The following are among those listed there as persons who shall be nationals and citizens of the United States at birth:
- "a person born in the United States, and subject to the jurisdiction thereof" or
- "a person born in the United States to a member of an Indian, Eskimo, Aleutian, or other aboriginal tribe" (see Indian Citizenship Act of 1924).
- "a person of unknown parentage found in the United States while under the age of five years, until shown, prior to his attaining the age of twenty-one years, not to have been born in the United States"
- "a person born in an outlying possession of the United States of parents one of whom is a citizen of the United States who has been physically present in the United States or one of its outlying possessions for a continuous period of one year at any time prior to the birth of such person"
U.S. territories
The 14th amendment applies to incorporated territories, so people born in incorporated territories of the U.S. (currently, only the Palmyra Atoll) are automatically U.S. citizens at birth.[4]
There are special provisions governing children born in some current and former U.S. territories or possessions, including Puerto Rico, the Panama Canal Zone, the Virgin Islands, Guam, and the Northern Mariana Islands. There are also special considerations for those born in Alaska and Hawaii before those territories acquired statehood. For example, 8 U.S.C. § 1402 states that "[a]ll persons born in Puerto Rico on or after January 13, 1941, and subject to the jurisdiction of the United States, are citizens of the United States at birth".[5]
Outlying possessions
According to 8 U.S.C. § 1408 persons born (or found, and of unknown parentage, under the age of 5) in an outlying possession of the U.S. (which is defined by 8 U.S.C. § 1101 as American Samoa and Swains Island) are U.S. nationals but not citizens, unless otherwise provided in section 1401. The U.S. State Department publication titled Acquisition of U.S. Nationality in U.S. Territories and Possessions explains the complexities of this topic.[6]
Statute, by parentage
Under certain circumstances, children may acquire U.S. citizenship from their parents. From 1940 until 1978, a child born abroad who acquired U.S. citizenship at birth but had only one U.S. citizen parent had to fulfill a "retention requirement" of residing, or being physically present, in the United States or its outlying possessions for a certain number of years before reaching a specified age. Otherwise the child would not retain the U.S. citizenship (hence the name "retention requirement"). The retention requirement was changed several times, eliminated in 1978, and subsequently eliminated with retroactive effect in 1994.[7]
Children born overseas to married parents
The following conditions affect children born outside the U.S. and its outlying possessions to married parents (special conditions affect children born out of wedlock: see below):[8]
- If both parents are U.S. citizens, the child is a citizen if either of the parents has ever had a residence in the U.S. prior to the child's birth
- If one parent is a U.S. citizen and the other parent is a U.S. national, the child is a citizen if the U.S. citizen parent has lived in the U.S. for a continuous period of at least one year prior to the child's birth
If one parent is a U.S. citizen and the other parent is not, the child is a citizen if
- the U.S. citizen parent has been "physically present"[9] in the U.S. before the child's birth for a total period of at least five years, and
- at least two of those five years were after the U.S. citizen parent's fourteenth birthday.[10]
Children born overseas out of wedlock
There is an asymmetry in the way citizenship status of children born overseas to unmarried parents, only one of whom is a U.S. citizen, is handled.
Title 8 U.S.C. § 1409 paragraph (c) provides that children born abroad after December 24, 1952 to unmarried American mothers are U.S. citizens, as long as the mother has lived in the U.S. for a continuous period of at least one year at any time prior to the birth.
8 U.S.C. § 1409 paragraph (a) provides that children born to American fathers unmarried to the children's non-American mothers are considered U.S. citizens only if the father meets the "physical presence" conditions described above, and the father takes several actions:
- Unless deceased, has agreed to provide financial support to the child until he reaches 18,
Establish paternity by clear and convincing evidence and, while the person is under the age of 18 years
- the person is legitimated under the law of the person's residence or domicile,
- the father acknowledges paternity of the person in writing under oath, or
the paternity of the person is established by adjudication of a competent court.
- 8 U.S.C. § 1409 paragraph (a) provides that acknowledgment of paternity can be shown by acknowledging paternity under oath and in writing; having the issue adjudicated by a court; or having the child otherwise "legitimated" by law.
Because of this rule, unusual cases have arisen whereby children have been fathered by American men overseas from non-American women, brought back to the United States as babies without the mother, raised by the American father in the United States, and later held to be deportable as non-citizens in their 20s.[11][12] The final element has taken an especially significant importance in these circumstances, as once the child has reached 18, the father is forever unable to establish paternity to deem his child a citizen.[13]
This distinction between unwed American fathers and American mothers was constructed and reaffirmed by Congress out of concern that a flood of illegitimate Korean and Vietnamese children would later claim American citizenship as a result of their parentage by American servicemen overseas fighting wars in their countries.[14] In many cases, American servicemen passing through in wartime may not have even learned they had fathered a child.[14] In 2001, the Supreme Court, by 5–4 majority in Nguyen v. INS, first established the constitutionality of this gender distinction.[11][12]
Eligibility for office of President
According to the Constitution of the United States only natural born citizens are eligible to serve as President of the United States or as Vice President. The text of the Constitution does not define what is meant by natural born: in particular it does not specify whether there is any distinction to be made between persons whose citizenship is based on jus sanguinis (parentage) and those whose citizenship is based on jus soli (birthplace). As a result, controversies have arisen over the eligibility of a number of candidates for the office.
Legal history
Throughout much of the history of the United States, the fundamental legal principle governing citizenship has been that birth within the territorial limits of the United States confers United States citizenship, although slaves and the children of slave mothers, under the principle of partus sequitur ventrem, were excluded.[15] The United States did not grant citizenship after the American Civil War to all former slaves until the passage of the Civil Rights Act of 1866, which was subsequently confirmed by the Fourteenth Amendment. American Indian tribal members are not covered specifically by the constitutional guarantee. Those living in tribes on reservations were generally not considered citizens until passage of the Indian Citizenship Act of 1924, although by that time nearly two-thirds of American Indians were already citizens.
English common law
Many claim that birthright citizenship, as with much United States law, has its roots in English common law.[16] Calvin's Case, 77 Eng. Rep. 377 (1608),[18] was particularly important as it established that, under English common law, "a person's status was vested at birth, and based upon place of birth—a person born within the king's dominion owed allegiance to the sovereign, and in turn, was entitled to the king's protection."[19] This same principle was adopted by the newly formed United States, as stated by Supreme Court Justice Noah Haynes Swayne: "All persons born in the allegiance of the king are natural-born subjects, and all persons born in the allegiance of the United States are natural-born citizens. Birth and allegiance go together. Such is the rule of the common law, and it is the common law of this country as well as of England...since as before the Revolution.[20]" United States v. Rhodes, 27 Fed. Cas. 785 (1866). However, Calvin's Case is distinguishable, as a Scotsman was granted title to English land as his King and England's King (James) were one and the same.[21] Calvin was not born in England.[21] Moreover, in Calvin's Case, Lord Coke cited examples in which the native-born children of parents, either invading the country or who were enemies of the country, were not natural-born subjects because the birth lacked allegiance and obedience to the sovereign.[22]
Federal law
The Naturalization Act of 1790 (1 Stat. 103) provided the first rules to be followed by the United States in the granting of national citizenship. Since that time, laws concerning immigration and naturalization in the United States have undergone a number of revisions.[23]
Dred Scott v. Sanford
Justice Roger B. Taney in the majority opinion in Dred Scott v. Sanford 60 U.S. (How. 19) 393 (1857) held that African Americans, whether slave or free, had never been and could never become citizens of the United States, as they were excluded by the Constitution. The political scientist Stuart Streichler writes that Taney's decision was based on "a skewed reading of history.".[24] Justice Benjamin R. Curtis in his dissent showed that under the Articles of Confederation, free blacks had already been considered citizens in five states and carried that citizenship forward when the Constitution was ratified.[25]
He wrote:
The first section of the second article of the Constitution uses the language "a natural-born citizen." It thus assumes that citizenship may be acquired by birth. Undoubtedly, this language of the Constitution was used in reference to that principle of public law, well understood in the history of this country at the time of the adoption of the Constitution, which referred Citizenship to the place of birth. At the Declaration of Independence, and ever since, the received general doctrine has been, in conformity with the common law, that free persons born within either of the colonies, were the subjects of the King; that by the Declaration of independence, and the consequent acquisition of sovereignty by the several States, all such persons ceased to be subjects, and became citizens of the several States ... The Constitution has left to the States the determination what person, born within their respective limits, shall acquire by birth citizenship of the United States...[26]
1862 opinion of the Attorney General of the United StatesIn 1862, Secretary of the Treasury Salmon P. Chase sent a question to Attorney General Edward Bates asking whether or not "colored men" can be citizens of the United States. Attorney General Bates responded on November 29, 1862, with a 27-page opinion concluding, "I conclude that the free man of color, mentioned in your letter, if born in the United States, is a citizen of the United States, ...[27][italics in original]" In the course of that opinion, Bates commented at some length on the nature of citizenship, and wrote,
... our constitution, in speaking of natural born citizens, uses no affirmative language to make them such, but only recognizes and reaffirms the universal principle, common to all nations, and as old as political society, that the people born in a country do constitute the nation, and, as individuals, are natural members of the body politic.
If this be a true principle, and I do not doubt it, it follows that every person born in a country is, at the moment of birth, prima facie a citizen; and who would deny it must take upon himself the burden of proving some great disfranchisement strong enough to override the natural born right as recognized by the Constitution in terms the most simple and comprehensive, and without any reference to race or color, or any other accidental circumstance.[28][italics in original]
Civil Rights Act of 1866
The Civil Rights Act of 1866 declared: "...all persons born in the United States, and not subject to any foreign power, excluding Indians not taxed, are hereby declared to be citizens of the United States."[29] ("Indians not taxed" referred to tribal members living on reservations.)
Fourteenth Amendment to the United States Constitution
Since the adoption of the Fourteenth Amendment to the Constitution on July 9, 1868, citizenship of persons born in the United States has been controlled by its Citizenship Clause, which states:
"All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside."[3]
Expatriation Act of 1868
This act, a companion piece to the Fourteenth Amendment, was approved on 27 July 1868.[30]
The Expatriation Act of 1868 led President Ulysses S. Grant to write in 1873, that the United States had "led the way in the overthrow of the feudal doctrine of perpetual allegiance".[31]
Dr. Edward J. Erler of California State University, San Bernardino, and Dr. Brook Thomas of the University of California at Irvine, have argued that this Act was an explicit rejection of birth-right citizenship as the ground for American citizenship,[32] basing that argument on the debate that surrounded the passage of this act.[33][34]
1873 opinion of the Attorney General
In 1873, The Attorney General of the United States published the following legal opinion concerning the Fourteenth Amendment:
"The word 'jurisdiction' must be understood to mean absolute and complete jurisdiction, such as the United States had over its citizens before the adoption of this amendment. Aliens, among whom are persons born here and naturalized abroad, dwelling or being in this country, are subject to the jurisdiction of the United States only to a limited extent. Political and military rights and duties do not pertain to them."[35]
Indian Citizenship Act of 1924
The Indian Citizenship Act of 1924[36] provided "That all noncitizen Indians born within the territorial limits of the United States be, and they are hereby, declared to be citizens of the United States". This same provision (slightly reworded) is contained in present-day law as section 301(b) of the Immigration and Nationality Act of 1965 (8 USC 1401(b)).
U.S. Supreme Court case law
Sailor's Snug Harbor
In the case of Inglis v. Trustees of Sailor's Snug Harbor, 28 U.S. 99 (1830) the Supreme Court decided the question of the disposition of the estate of a man born in New York State in 1776. The Supreme Court resolved complicated questions of how citizenship had been derived during the Revolutionary War. The court found that the jus soli is so consistent in American Law as to automatically grant American citizenship to children born in New York City between the Declaration of Independence and the Landing at Kip's Bay in 1776, but not to children born in New York during the British occupation that followed.[37]
"Nothing is better settled at the common law than the doctrine that the children even of aliens born in a country while the parents are resident there under the protection of the government and owing a temporary allegiance thereto are subjects by birth.."
The Slaughter-House Cases
In the Slaughter-House Cases, 83 U.S. 36 (1873) — a civil rights case not dealing specifically with birthright citizenship — a majority of the Supreme Court mentioned in passing that "the phrase 'subject to its jurisdiction' was intended to exclude from its operation children of ministers, consuls, and citizens or subjects of foreign States born within the United States".[38]
Elk v. Wilkins
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
"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."[39]
Thus, Native Americans who voluntarily quit their tribes would not automatically become U.S. citizens.[40] 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.
United States v. Wong Kim Ark
In the case of United States v. Wong Kim Ark, 169 U.S. 649 (1898), the Supreme Court ruled that a person who
- is born in the United States
- of parents who, at the time of his birth, are subjects of a foreign power
- whose parents have a permanent domicile and residence in the United States
- whose parents are there carrying on business and are not employed in any diplomatic or official capacity of the foreign power to which they are subject
becomes, at the time of his birth, a citizen of the United States by virtue of the first clause of the 14th Amendment of the Constitution.
Canadians transferred to U.S. hospitals
Since the majority of Canadians live in the relatively thin strip of land close to the long border with the United States, Canadians in need of urgent medical care are occasionally transferred to nearby American medical centers. In some circumstances, Canadian mothers facing high-risk births have given birth in American hospitals. Such children are American citizens by birthright.[41]
In these circumstances, Canadian laws are similar to those of the United States. Babies born in Canada of American parents are also Canadian citizens by birthright.[42]
In both of these situations, the birthright citizenship is passed on to their children, born decades later. In some cases, births in American hospital (sometimes called "border babies") have resulted in persons who lived for much of their lives in Canada, but not knowing that they had never had official Canadian citizenship. This group of people is sometimes called Lost Canadians.[43]
Another problem arises where a Canadian child, born to Canadian parents in a US border hospital, is treated as a dual citizen and added to the United States tax base on this basis despite having never lived, worked nor studied in that nation. While Canadian income tax is only payable by those who reside or earn income in Canada, the US Internal Revenue Service taxes its citizens worldwide. Campobello Island is particularly problematic as, while legally part of New Brunswick, the only year-round fixed link off the island leads not to Canada but to Lubec, Maine — leading to many Canadians whose families have lived on Campobello for generations not being able to claim to be born in Canada.[44]
Current controversy
Original meaning
During the original debate over the 14th Amendment Senator Jacob M. Howard of Michigan—the sponsor of the Citizenship Clause—described the clause as having the same content, despite different wording, as the earlier Civil Rights Act of 1866, namely, that it excludes American Indians who maintain their tribal ties and "persons born in the United States who are foreigners, aliens, who belong to the families of ambassadors or foreign ministers."[45] Others also agreed that the children of ambassadors and foreign ministers were to be excluded.[46][47] However, concerning the children born in the United States to parents who are not U.S. citizens (and not foreign diplomats), three senators, including Senate Judiciary Committee Chairman Lyman Trumbull, the author of the Civil Rights Act, as well as President Andrew Johnson, asserted that both the Civil Rights Act and the 14th Amendment would confer citizenship on them at birth, and no senator offered a contrary opinion.[48][49][50]
Most of the debate on this section of the Amendment centered on whether the wording in the Civil Rights Act or Howard's proposal more effectively excluded Aboriginal Americans on reservations and in U.S. territories from citizenship. Senator James R. Doolittle of Wisconsin asserted that all Native Americans are subject to the jurisdiction of the United States, so that the phrase "Indians not taxed" would be preferable,[51] but Trumbull and Howard disputed this, arguing that the U.S. government did not have full jurisdiction over Native American tribes, which govern themselves and make treaties with the United States.[52][53]
Edward Erler argues that since the Wong Kim Ark case dealt with someone whose parents were in the United States legally, there is no valid basis under the 14th Amendment for the practice of granting citizenship to U.S.-born children of illegal immigrants: "Even if the logic is that Wong Kim Ark became a citizen by birth with the permission of the United States when it admitted his parents to the country, no such permission has been given to those who enter illegally."[54] Angelo Ancheta, by contrast, criticizes the "consent-based theory of citizenship", saying that "The Fourteenth Amendment was designed to ensure citizenship for 'all persons' born in the United States, particularly in response to ambiguities in legal status that attached to being the descendants of an outsider class, namely slaves."[55]
Modern dispute
In the late 1990s opposition arose over the longstanding practice of granting automatic citizenship on a jus soli basis[56] as fears grew in some circles that the existing law encouraged parents-to-be to come to the United States to have children in order to improve the parents' chances of attaining legal residency themselves.[57][58] Some media correspondents[59][60] and public leaders, including former congressman Virgil Goode, have controversially dubbed this the "anchor baby" situation,[61][62] and politicians have proposed legislation on this basis that might alter how birthright citizenship is awarded.[63]
The [66]
Bills have been introduced from time to time in Congress which have sought to declare American-born children of foreign nationals not to be "subject to the jurisdiction of the United States", and thus not entitled to citizenship via the 14th Amendment, unless at least one parent was an American citizen or a lawful permanent resident.
Both Democrats and Republicans have introduced legislation aimed at narrowing the application of the Citizenship Clause. In 1993, Sen. Harry Reid (D-Nev.) introduced legislation that would limit birthright citizenship to the children of U.S. citizens and legally resident aliens, and similar bills have been introduced by other legislators in every Congress since.[66] For example, Citizenship Reform Act of 2005" (H.R. 698) in the 109th Congress,[67] the "Birthright Citizenship Act of 2007" (H.R. 1940)[68] in the 110th Congress, and the "Birthright Citizenship Act of 2009" (H.R. 1868)[69] in the 111th Congress. However, neither these nor any similar bill has ever been passed by Congress.
Some legislators, unsure whether such Acts of Congress would survive court challenges, have proposed that the Citizenship Clause be changed through a constitutional amendment.[70] Senate Joint Resolution 6, introduced on January 16, 2009 in the 111th Congress, proposes such an amendment;[71] however, neither this, nor any other proposed amendment, has yet been approved by Congress for ratification by the states.
The most recent judge to weigh in on the issue as to whether a constitutional amendment would be necessary to change the policy is Judge Richard Posner who remarked in a 2003 case that "Congress would not be flouting the Constitution if it amended the Immigration and Nationality Act to put an end to the nonsense." He explained, "A constitutional amendment may be required to change the rule whereby birth in this country automatically confers U.S. citizenship, but I doubt it." Posner also wrote, that automatic birthright citizenship is a policy that "Congress should rethink" and that the United States "should not be encouraging foreigners to come to the United States solely to enable them to confer U.S. citizenship on their future children."[72]
Professor Edward J. Erler of the California State University has argued that "Congress began to pass legislation offering citizenship to Indians on a tribe by tribe basis. Finally, in 1923, there was a universal offer to all tribes. Any Indian who consented could become an American citizen. This citizenship was based on reciprocal consent: an offer on the part of the U.S. and acceptance on the part of an individual. Thus Congress used its legislative powers under the Fourteenth Amendment to determine who was within the jurisdiction of the U.S. It could make a similar determination today, based on this legislative precedent, that children born in the U.S. to illegal aliens are not subject to American jurisdiction. A constitutional amendment is no more required now than it was in 1923."[73] Some others have disagreed with this interpretation, contending that while Congress can define territories (such as an Indian Reservation) as US jurisdiction, it has no power to define people as under US jurisdiction aside from where they were born.[74]
Republicans in the State of Arizona have indicated an intention to introduce state legislation which would seek to deny American citizenship to Arizona-born children of illegal immigrant parents by prohibiting the issuance of a birth certificate unless at least one parent has legal status.[75][76] However, critics argue that the child or parents could immediately sue the state for discrimination and that the federal courts would immediately force the state to issue the birth certificate.[74]
A report by an organization called the National Foundation for American Policy (NFAP) in 2012 asserted that revoking birthright citizenship would be bureaucratic, expensive, would result in a national ID card, and would not slow illegal immigration.[74] Under current law, if a citizen parent gives birth in a foreign country, they must prove their own citizenship in order for their baby to have citizenship. The NFAP estimated this to cost $600 per baby, not including legal fees. The report alleged that if birthright citizenship were eliminated, every baby in the United States would be subject to this cost. For the four million babies born each year in the U.S., this would total $24 billion per year. In addition, currently the US government does not keep any record of births, instead using the records of individual states to issue passports. The report alleged that the end of birthright citizenship would leave the states unable to verify whether a new baby should be granted citizenship, requiring the federal government instead to issue birth certificates, and likely a national ID card. Finally, the report claimed that eliminating birthright citizenship would not reduce illegal immigration. The report said that immigrants come to the United States for economic reasons, and illegal immigrants cannot use a citizen child to be granted citizenship. The report also said that all proposals to end birthright citizenship, aside from a constitutional amendment, would be unconstitutional and quickly be overturned in court.[74] The Center for Immigration Studies disputed these conclusions, asserting in its own 2012 report that the NFAP's claims were "unsupported", that a bureaucratic overhaul would not be necessary, and that ending automatic birthright citizenship would not cost parents money, result in a caste system, or create stateless children.[77]
See also
- Birther
- Birthright citizenship in other jurisdictions
- Birth tourism
- Citizenship in the United States
- Natural-born citizen
- United States nationality law
- All Senate debate quotes are from the Congressional Globe (precursor of the Congressional Record) for the 39th Congress, 1st Session. P. 2890-95.
- ^ See 8 U.S.C. § 1101(a)(36) and 8 U.S.C. § 1101(a)(38) Providing the term "State" and "United States" definitions on the U.S. Federal Code, Immigration and Nationality Act 8 U.S.C. § 1101a.
- ^ Weiner 1998, p. 238.
- ^ a b Meese 2005, p. 35
- ^ "U.S. Department of State Foreign Affairs Manual Volume 7 – Consular Affairs 1120 ACQUISITION OF U.S. NATIONALITY IN U.S. TERRITORIES AND POSSESSIONS" (PDF). U.S. Department of State. Retrieved 2014-07-18. 7 FAM 1121.2-1 Definition of Terms
- ^ "INA: Act 302 - Persons Born in Puerto Rico". U.S. Citizenship and Immigration Services. Retrieved 19 October 2012.
- ^ Acquisition of U.S. Nationality in U.S. Territories and Possessions
- ^ Henry J. Chang: U.S. Citizenship Acquired by Birth Abroad
- ^ including, in some circumstances, time spent overseas when a parent who is a U.S. government employee is posted overseas
- ^ Immigration and Nationality Act § 301(g); 8 USC § 1401(g). For children born prior to the enactment of Public Law 99-653 on November 14, 1986, the citizen parent's U.S. presence requirement is ten years, of which at least five years had to have been after the parent's fourteenth birthday.
- ^ a b Findlaw.com: Nguyen v. INS, 533 U.S. 53 (2001)
- ^ a b Nguyen v. INS, 533 U.S. 53 (2001) Cornell University Law School.
- ^ Under a fact situation similar to Nguyen, the effect might be different today if the child's 18th birthday were after February 27, 2001, as per the Child Citizenship Act of 2000, the child might automatically become a U.S. citizen upon admission to the country as a lawful permanent resident. This type of citizenship, however, is not considered "birthright" or natural, and the subject would most likely be construed as a "naturalized" citizen. See the U.S. Department of State's page on the Child Citizenship Act of 2000.
- ^ a b US v. Ahumada-Aguilar, 189 F.3d 1121 (9th Cir. 1999)
- ^ .
- ^ Schuck 2006, p. 96
- ^ Price, Polly J. (1997). "Natural Law and Birthright Citizenship in Calvin's Case (1608)". Yale Journal of Law and the Humanities 9.
- ^ Robert Calvin was born in Scotland around 1606. He inherited estates in England, but his rights thereto were challenged on the grounds that, as a Scot, he could not legally own English land.[17]
- ^ Justice, Elaine (October 7, 1996), "Price questions whether birthright citizenship will continue", Emory Report (Emory University), retrieved January 4, 2007.
- ^ The American Law Register. D.B. Canfield & Co. 1868. p. 237.
- ^ a b See Steve Sheppard, ed., The Selected Writings of Sir Edward Coke, (Liberty Fund 2003) p. 166.
- ^ Calvin's Case, 77 Eng. Rep. at 384, 399, 406-07 (1608).
- ^ The American Law Register. D.B. Canfield & Co. 1864. p. 599.
- ^ Streichler (2005) p. 123
- ^ Streichler (2005) p. 126
- ^ United States.; Supreme Court, Dred Scott, John F. A. Sanford, Benjamin Chew Howard (1857), ": Dred Scott, John F. A. Sanford, Benjamin Chew Howard", A Report of the Decision of the Supreme Court of the United States and the Opinions of the Judges Thereof, in, D. Appleton, pp. 576–582 .
- ^ Bates, Edward (1862), Opinion of Attorney General Bates on Citizenship, Government Printing Office, pp. 26–27.
- ^ Bates 1862, p. 12, Op. cit.
- ^ "The 1866 Civil Rights Act". 14 Stat. 27-30. April 9, 1866. Retrieved September 3,.
- ^ Expatriation Act, 14th-amendment.com, quoting Sanger 1869, pp. 223–224.
- ^ Snow (1893), Cases and Opinions on International Law, p. 218.
- ^ Transcript, Testimony of Edward J. Erler before the House Subcommittee on Immigration and Claims, June 25, 1997.
- ^ Erler 2003, pp. 191–192, Erler 2007, pp. 50–51
- ^ Thomas 2007, pp. 193–194.
- ^ 14 U.S. Attorney General Opinions 300.
- ^ 43 United States Statutes at Large 253.
- ^ Inglis v. Trustees of Sailor's Snug Harbor, 28 U.S. 99 (1830), U.S. Supreme Court Center, justia.com.
- ^ 83 U.S. at 73.
- ^ 112 U.S. at 102.
- ^ Urofsky, Melvin I.;
- ^ Some Canadian mothers forced to give birth in U.S., KOMO TV News, retrieved January 31, 2009
- ^ Citizenship Act PART I: THE RIGHT TO CITIZENSHIP, Federation of Law Societies of Canada, retrieved February 10, 2009
- ^ Citizenship and Immigration Canada True or False? Children born outside of Canada, Department of Citizenship and Immigration Canada, archived from the original on 2009-03-02, retrieved October 26, 2010
- ^ http://www.pressherald.com/news/Challenges-for-Campobello-Island-A-crossing-to-bear.html?pagenum=full
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 4, p. 2893 Senator Reverdy Johnson said in the debate: "Now, all this amendment provides is, that all persons born in the United States and not subject to some foreign Power—for that, no doubt, is the meaning of the committee who have brought the matter before us—shall be considered as citizens of the United States...If there are to be citizens of the United States entitled everywhere to the character of citizens of the United States, there should be some certain definition of what citizenship is, what has created the character of citizen as between himself and the United States, and the amendment says citizenship may depend upon birth, and I know of no better way to give rise to citizenship than the fact of birth within the territory of the United States, born of parents who at the time were subject to the authority of the United States."
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 4, p. 2897.
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 1, p. 572.
^ Congressional Globe, 1st Session, 39th Congress, pt. 1, p. 498. The debate on the Civil Rights Act contained the following exchange:
Mr. Cowan: "I will ask whether it will not have the effect of naturalizing the children of Chinese and Gypsies born in this country?"
Mr. Trumbull: "Undoubtedly."
Mr. Trumbull: "I understand that under the naturalization laws the children who are born here of parents who have not been naturalized are citizens. This is the law, as I understand it, at the present time. Is not the child born in this country of German parents a citizen? I am afraid we have got very few citizens in some of the counties of good old Pennsylvania if the children born of German parents are not citizens."
Mr. Cowan: "The honorable Senator assumes that which is not the fact. The children of German parents are citizens; but Germans are not Chinese; Germans are not Australians, nor Hottentots, nor anything of the kind. That is the fallacy of his argument."
Mr. Trumbull: "If the Senator from Pennsylvania will show me in the law any distinction made between the children of German parents and the children of Asiatic parents, I may be able to appreciate the point which he makes; but the law makes no such distinction; and the child of an Asiatic is just as much of a citizen as the child of a European."
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 4, pp. 2891-2. During the debate on the Amendment, Senator John Conness of California declared, "The proposition before us, I will say, Mr. President, relates simply in that respect to the children begotten of Chinese parents in California, and it is proposed to declare that they shall be citizens. We have declared that by law [the Civil Rights Act]; now it is proposed to incorporate that same provision in the fundamental instrument of the nation. I am in favor of doing so. I voted for the proposition to declare that the children of all parentage, whatever, born in California, should be regarded and treated as citizens of the United States, entitled to equal Civil Rights with other citizens.".
- ^ See veto message by President Andrew Johnson.
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 4, pp. 2890, 2892-4, 2896.
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 4, p. 2893. Senate Judiciary Committee Chairman Lyman Trumbull, participating in the debate, stated the following: "What do we [the committee reporting the clause] mean by 'subject to the jurisdiction of the United States'? Not owing allegiance to anybody else. That is what it means." He then proceeded to expound upon what he meant by "complete jurisdiction": "Can you sue a Navajoe Indian in court?...We make treaties with them, and therefore they are not subject to our jurisdiction....If we want to control the Navajoes, or any other Indians of which the Senator from Wisconsin has spoken, how do we do it? Do we pass a law to control them? Are they subject to our jurisdiction in that sense?....Would he [Sen. Doolittle] think of punishing them for instituting among themselves their own tribal regulations? Does the Government of the United States pretend to take jurisdiction of murders and robberies and other crimes committed by one Indian upon another?...It is only those persons who come completely within our jurisdiction, who are subject to our laws, that we think of making citizens."
- ^ Congressional Globe, 1st Session, 39th Congress, pt. 4, p. 2895. Howard additionally stated the word jurisdiction meant "the same jurisdiction in extent and quality as applies to every citizen of the United States now" and that the United States possessed a "full and complete jurisdiction" over the person described in the amendment.
- ^ Erler et al., The Founders on Citizenship and Immigration: Principles and Challenges in America, p. 67.
- ^ Angelo N. Ancheta, Race, Rights, and the Asian American Experience, p. 103.
^ Lee, Margaret (12 May 2006), U.S. Citizenship of Persons Born in the United States to Alien Parents, Congressional Research Service Report for Congress, retrieved August 16, 2008 (brief record)
^ Lee, Margaret (13 September 2005), U.S. Citizenship of Persons Born in the United States to Alien Parents, ilw.com, retrieved May 30, 2010 (full text)
- ^ "[...] During that debate, Senator
- ^ Border baby' boom strains S. Texas"'", Houston Chronicle, September 24, 2006, retrieved August 2, 2008
- ^ Simmons, Kathryn. "Anchor babies tie illegal immigrants to U.S." NBC2 News. November 25, 2005.
- ^ Erbe, Bonnie. "Anchor Babies hurt working class." Seattle Times. May 18, 2005.
- ^ Goode-Perriello Exchange, Sorensen Institute Candidates' Forum, September 3, 2008, retrieved October 3, 2008
- ^ "'"Rep. Gayle Harrell says immigration is 'No. 1 issue, Fort-Pierce Tribune, June 30, 2008, retrieved July 14, 2008
- ^ "GOP mulls ending birthright citizenship," Washington Times, November 3, 2005
- ^ "Unauthorized Immigrants and Their U.S.-Born Children," Pew Hispanic Center, August 11, 2010
- ^ Daniel González and Dan Nowicki. "Birthright citizenship change would have wide effects." Arizona Republic, March 20, 2011.
- ^ a b Jon Feere, "Birthright Citizenship in the United States: A Global Comparison." Center for Immigration Studies.
- ^ Citizenship Reform Act of 2005.
- ^ Birthright Citizenship Act of 2007.
- ^ Birthright Citizenship Act of 2009.
- ^ U.S. Representative Anthony Beilenson (D-CA). "Case for Correction By Constitutional Amendment." The Social Contract. Volume 7, Number 1 (Fall 1996).
- ^ S. J. Res. 6, thomas.loc.gov, January 16, 2009, retrieved February 27, 2009
- ^ Oforji v. Ashcroft, 354 F.3d 609, 620-1 (2003). See also, Jon Feere, "Birthright Citizenship in the United States: A Global Comparison," Center for Immigration Studies, August 2010, http://www.cis.org/birthright-citizenship
- ^ Hearing on the Citizenship Reform Act of 1997 (H.R. 7), Before the House Comm. on the Judiciary, Subcomm. on Immigration and Claims (June 25, 1997). See also, Jon Feere, "Birthright Citizenship in the United States: A Global Comparison," Center for Immigration Studies, August 2010, http://www.cis.org/birthright-citizenship
- ^ a b c d Margaret Stock (March 2012), "The Cost to Americans and America of Ending Birthright Citizenship", National Foundation for American Policy, retrieved March 5, 2012
- ^ "Arizona bill would deny citizenship to children of illegal immigrants", CNN, June 15, 2010.
- ^ "Arizona's Next Immigration Target: Children of Illegals", Time.com, June 11, 2010.
- ^ Jon Feere, "The Alleged Costs of Ending Universal Birthright Citizenship A Response to the National Foundation for American Policy," Center for Immigration Studies. (April 2012) http://www.cis.org/Alleged-Costs-of-Ending-Universal-Birthright-Citizenship
- Erler, Edward J. (2003), "From Subjects to citizens: The Social Origins of American Citizenship", in Pestritto, Ronald J., The American Founding and the Social Compact (illustrated ed.), Lexington Books, .
- Erler, Edward J.; .
- Erler, Edward J.; Thomas G. West, John A. Marini (2007), "American Citizenship and Postmodern Challenges", The Founders on Citizenship and Immigration: Principles and Challenges in America, Rowman & Littlefield, .
- Mayton, William T. (2008). "Birthright Citizenship and the Civic Minimum". Georgetown Immigration Law Journal (Washington, D.C.: Georgetown Immigration Law Journal) 22 (221).
- Sanger, George P., ed. (1869), Statutes at Large and Proclamations, of the United States of America. From December 1867-March 1869, Boston: Little, Brown, and Company.
- Schuck, Peter H. (2006), Diversity in America: Keeping Government at a Safe Distance, Harvard University Press, .
- Thomas, Brook (2007), Civic Myths: A Law-and-literature Approach to Citizenship (illustrated ed.), UNC Press, .
- .
Further reading
- Ancheta, Angelo N. (1998), Race, Rights, and the Asian American Experience, Brunswick, NJ: Rutgers University Press, .
- Carlisle, Rodney P.; Golson, J. Geoffrey (2007), A House Divided During the Civil War Era (illustrated ed.), ABC-CLIO, .
- .
- Ridgell, Reilly (1995), Pacific Nations and Territories: The Islands of Micronesia, Melanesia, and Polynesia, Bess Press, .
- Streichler, Stuart (2005), Justice Curtis in the Civil War Era, .
External links
- Ho, James C (March 10, 2007), "Can Congress Repeal Birthright Citizenship?", The Los Angeles Times (
- Articles containing potentially dated statements from 2011
- All articles containing potentially dated statements
- Pages containing cite templates with deprecated parameters
- CS1 errors: dates
- United States constitutional law
- Immigration to the United States
- United States nationality law
- Fourteenth Amendment to the United States Constitution


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KS Test Drive Delivery– All Walser Auto Campus dealerships located in Wichita KS offer a FREE new or used vehicle test drive delivery option for customers located in the greater Wichita metropolitan area and beyond. Test drive delivery based on schedule availability and distance. Some exclusions apply. Message dealer for details. KS Purchase Delivery – All Walser Auto Campus dealerships located in Wichita KS offer a FREE new or used vehicle home delivery option for customers located up to 120 miles of the selling dealership. Nationwide home delivery is available, please contact dealer for a personalized quote. Delivery availability may vary, some exclusions apply. Message dealer for details.
Austin Landers (service dept) and Michelle Anderson (sales) are awesome. I had issues with my mini. Austin went above and beyond helping me with decisions on how to handle what needed to be done. Long story short ended up with him sending me to sales where Michelle also went above and beyond to get me in a new 2021Mini Cooper S. I can't say enough on how Walser puts the customer first.
We had a great buying experience here. We were well taken care of by Blaize Foltz and everything was excellent. Premium car buying experience.
What a great dealership. Matt and Mason did an outstanding job. After a few bumps in the road during the process, things have turned out wonderfully. I couldn't be happier with this beautiful little MINI! Thank you to Matt, who helped me get this gorgeous Pepper White Cooper. And thank you so much to Mason for all your help! Plus the two gentlemen who delivered the vehicle to me in OKC, who were some of the nicest men ever: Daryl and friend (I'm so sorry that the other gentleman's name is escaping me)! Thank you to everyone ...
Probably the most painless car buying experience I've had in the last ten years. Steve Belisle was nothing short of professional. I would definitely recommend Mini of Wichita to anyone.
Found the perfect deal on exactly the car we wanted! The sales team communicated every step of the way and it was one of the least pressured and easiest car buying experiences we've ever had. Oh, did I mention that we're not in KS? Never thought buying a car out of state would be this easy.
Absolutely wonderful experience. Mandi was awesome. They worked with me from out of state. Put me up in a hotel when I came up to pick Belle up. You won't regret doing business here.
They worked out the best deal with me for the new Mini and the trade in. Got a perfect Mini that fits my budget and everything was done over the phone and 300 miles away. So the only thing was to sign the papers and get the keys. Out of all dealerships I had to deal with they didn't bs me or pressure me. Friendly and helpful customer service.
My teenage daughter dreamt of a Mini for her first car. We contacted the dealership after seeing a 2017 Clubman listed on the website. Due to Covid-19 and the fact that we live in southwest Kansas, the dealership worked with us to make our purchase easy and seamless. Our sales representative, Blaize, stayed in contact and had great attention to detail....right down to the big red bow he placed on my daughter's first Mini. Thank you for making our experience!
We purchased a 2019 Mini Cooper Countryman for my wife on 5/16/20. Our experience was amazing! We worked with Matthew, who is very friendly & passionate about his work & about Minis. He was easy going, funny, & he's a great representative for Walser & Mini!
Incredibly satisfied with the overall experience at MINI of Wichita. I worked with a very nice salesman (Mathew) who worked with me to find a car of my dreams. AND it was delivered to my house in Kansas City. Overall, so very happy!
BMW Assist eCall,BMW TeleServices,ConnectedDrive Services,Advanced RTTI,Remote Services,Apple CarPlay Compatibility,Media Display,MINI Connected,MINI Connected XL,Wireless Charging,MINI Navigation
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- Written by Michael Bahati
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5 Top ways to have a Successful Business in Paris
Paris is not only one of the most culturally diverse cities to live in, but is also increasingly becoming the center of economic and commercial activity in Europe. In the last decade alone, troves of new businesses and start-ups have popped up all over the city. Interestingly, people from outside France have moved into the city of Paris specifically, and the whole of France generally, to set up their businesses and commercial interests. The successes of most of such businesses have led to ever increasing numbers of entrepreneurs and businessmen alike to come and set up shop in Paris. Let's get started:
1. Partner with a local business contact.
When you first move to Paris, it would be difficult for you to understand the norms of how things work and govern in the city.
To get your feet running, make sure that you have a contact person or an employee who is Parisian and has experience in running things here.
This contact would be vital in not only getting your papers and stuff in order, but also acquainting you with the ins and outs of business life in Paris.
2. Tie in to the Culture.
More often than not, businesses who fail to completely integrate into the Parisian society fail to hit it big.
Integration doesn't simply mean that you get your papers in order, but rather, you should make your business venture socially and culturally aligned with how things go in Paris.
Things such as using French as the main language of concern, hiring local talent and observing etiquettes that the Parisian take pride in shall go a long way in settling you down for the long haul.
3. Do as the Parisian do.
Paris is a city that prides itself on the love of life, art and history.
The pace of doing business here is markedly different than what you would find in cities such as London and New York.
For your business to be successful here, you need to not only understand this difference, but also adhere to the pace of work here.
Don't push your employees too much, give them the freedom that Parisians take pride in, and see for yourself how this gets your business going in the right direction.
4. Make use of Tax breaks and Facilities for specific businesses.
If you are a technology related entrepreneur, someone who is working on a start up that has IT as the main component, the city of Paris offers extremely good co-working spaces and hubs from where you can not only operate at very good rates, but also get to network with other like-minded people in the industry.
Also, for specific business types, the city offers tax breaks and incentives that should definitely be looked at.
5. Market yourself properly.
Whereas the Parisians love to see an expat business that is integrated into the French society, but still you should maintain a certain unique international flavor about your business.
Market yourself as an international business that is culturally in unison with the Parisian way of life.
In a nutshell, use your international nature smartly as the differentiating factor.
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Level editor tool
Object type
Available in Happy Wheels since version
Text is a tool that is available in the Level Editor. With this you can type text or numbers and place it in a level.
There are currently 5 font types:
- Helvetica, regular.
- Helvetica, bold. This is the default font.
- Helvetica, a lot more bold.
- Clarendon, regular.
- Clarendon, bold.
The size of the text ranges from 10 (smallest) to 100 (largest). 15 is the default size.
Alignment can be changed on the text, with left alignment, middle alignment, and right alignment.
Text can be rotated, and colored. Opacity was added in V1.69. It can also be grouped and changed color. The default color is black.
- The text-detecting system doesn't work all that well. For example, if you type in 'rate 1/one', the text will still pop up although it should be intended for 'rate 5/five'. The same goes for the rest of the ratings. (However, this was possibly intended due to levels telling people to rate a specific number if they accomplished a certain action.) Also, if you type in a completely unrealistic voting number, such as 1337 or 9001, the message box will still appear although you can't actually rate a level 1337 or 9001.
- If you type in "rate [number]" in another other way (for example, typing rate in one text box and a number in the other) it will not detect it.
- When in a group, undoing entering the group will cause any text boxes in that group to be somehow deleted.
- If you move the text box with the arrow keys to the farthest left of the level at a certain coordinate while zoomed out, the x-coordinate might be set as a negative number.
- If you press the Group items while still in "typing mode", the text field will disappear. And if you try to undo the action by pressing Ctrl + Z, the text box will not return.
- The game is only in English, so you cannot type using Russian, Arabic, Chinese, Hebrew, Thai or any other non-English letters.
- You cannot type a colon (:) in text. it is unknown why.
- ASCII characters can not be entered.
- Users can use a period as a square (fonts 1-3) or circle (fonts 4 and 5) as it allows them to place a smaller square or circle than is possible using the shape or polygon tool.
- During the 1.64 update, Jim added a text-detecting system. If you type "rate [number]", then test the level and un-test it, a message box will appear saying: "There appears to be text in your level that abuses the rating system. Stop doing that. Misguided people apparently follow your instructions, and it's ruining Happy Wheels. I've been letting it slide, but including it in your level will now get it permanently deleted once noticed". But you can bypass the block by typing "rate [number]" in any other way. Fortunately, typing in a different way of saying "rate [number]" does not mean that this will not break the level rules.
- You cannot type a tilde "~" for an unknown reason, so the tilde can only be created with the Polytool.
- Jim's text-detecting system cannot detect the "Sign Your Name" text if you test and un-test the level. This is most likely because level importing has already been disabled at the time the system was implemented.
- When you click on the text tool button, the words, "HERE'S SOME TEXT" come up by default.
- There is no spell check in the text boxes.
- The "Rating system abuse" message will not appear if you type "Rate 0[#]". "Vote [Number]" was previously unrecognizable, but was later fixed to be recognized as abusing the rating system.
- Text does not count as either art or shapes, which could be useful detailing long levels.
- Opacity (visibility) was added in V1.69
- People sometimes use text to make art or other things instead of using the shape or poly tool.
- Although rare, but in groups, some text boxes do not seem to be placed accurately on different computers. For example, on a Windows machine, text boxes are placed more to the left, while on a Machintosh, they are placed more to the right.
- You can have a single textbox with a seemingly endless amount of character space, if you replace the "HERE'S SOME TEXT" phrase in its XML code with any amount of text and then load the level XML into the editor. Once in the editor, however, the textbox will not allow you to type more text in, nor will it allow you to re-enter any text that you just deleted, since it has already passed the limit.
Community content is available under CC-BY-SA unless otherwise noted.


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RIP former NYC Mayor Ed Koch. From the Times:
…He was a feisty, slippery egoist who could not be pinned down by questioners and who could outtalk anybody in the authentic voice of New York…
"The city was and is his family," said Maureen Connelly, a former press secretary and veteran political adviser. "We used to be scared about what would happen to Ed if he lost. We said it would be best if he just died in the saddle. But he never had any intention of getting off the horse."
[NYT, video h/t Jewyorican]