United States v. Wong Kim Ark
Supreme Court of the United States
Argued March 5, 8, 1897 Decided March 28, 1898
Full case name: United States v. Wong Kim Ark Citations: 169 U.S. 649; 18 S. Ct. 456; 42 L. Ed. 890; 1898 U.S. LEXIS 1515 Prior history: Appeal from the District Court of the United States for the Northern District of California
Holding
A child born in the United States to foreign parents who are subject to U.S. jurisdiction automatically becomes a U.S. citizen.
Court membership
Chief Justice: Melville Fuller Associate Justices: John Marshall Harlan, Horace Gray, David Josiah Brewer, Henry Billings Brown, George Shiras, Jr., Edward Douglass White, Rufus Wheeler Peckham, Joseph McKenna
Case opinions
Majority by: Gray Joined by: Brewer, Brown, Shiras, White, Peckham Dissent by: Fuller Joined by: Harlan McKenna took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. XIV

Wong Kim Ark

United States v. Wong Kim Ark, 169 U.S. 649 (1898), was a United States Supreme Court decision that set an important legal precedent about what determines American citizenship. Image File history File links Seal_of_the_United_States_Supreme_Court. ... Federal courts Supreme Court Circuit Courts of Appeal District Courts Elections Presidential elections Midterm elections Political Parties Democratic Republican Third parties State & Local government Governors Legislatures (List) State Courts Local Government Other countries Atlas  US Government Portal      The Supreme Court of the United States (sometimes colloquially referred to by the... Melville Weston Fuller (February 11, 1833 – July 4, 1910) was the Chief Justice of the United States between 1888 and 1910. ... This is about the pre-World-War-I US Supreme Court justice; for his grandson, the mid-20th-century holder of the same position, see John Marshall Harlan II. John Marshall Harlan (June 1, 1833 – October 14, 1911) was an American Supreme Court associate justice. ... Horace Gray (March 24, 1828-September 15, 1902) was an American jurist. ... David Josiah Brewer (January 20, 1837-March 28, 1910), was an American jurist. ... Henry Billings Brown (born South Lee, Massachusetts March 2, 1836 - died Bronxville, New York September 4, 1913) was a Republican United States Supreme Court justice from January 5, 1891 to May 28, 1906. ... Justice Shiras, 1900 George Shiras, Jr. ... Edward Douglass White (November 3, 1845 – May 19, 1921), American politician and jurist, was a United States Senator, Associate Justice of the Supreme Court of the United States and the ninth Chief Justice of the United States. ... This article is about the Associate Justice of the U.S. Supreme Court; for Justice Peckhams father of the same name who served in the U.S. House of Representatives, see Rufus Wheeler Peckham (1809-1873). ... Joseph McKenna (August 10, 1843–November 21, 1926) was an American politician who served in all three branches of the U.S. federal government, as a member of the U.S. House of Representatives, as U.S. Attorney General and as an Associate Justice of the Supreme Court. ... Amendment XIV in the National Archives The Fourteenth Amendment to the United States Constitution (Amendment XIV) is one of the post-Civil War amendments (known as the Reconstruction Amendments), first intended to secure rights for former slaves. ... Image File history File links No higher resolution available. ... Image File history File links No higher resolution available. ... Year 1898 (MDCCCXCVIII) was a common year starting on Saturday (link will display the full calendar) of the Gregorian calendar (or a common year starting on Monday of the 12-day-slower Julian calendar). ... Federal courts Supreme Court Circuit Courts of Appeal District Courts Elections Presidential elections Midterm elections Political Parties Democratic Republican Third parties State & Local government Governors Legislatures (List) State Courts Local Government Other countries Atlas  US Government Portal      The Supreme Court of the United States (sometimes colloquially referred to by the... Stare decisis (Latin: , Anglicisation: , to stand by things decided) is a Latin legal term, used in common law systems to express the notion that prior court decisions must be recognized as precedents, according to case law. ... “Citizen” redirects here. ...

Facts

Wong Kim Ark^[1] (黃金德; Toisanese: wong11 gim33 'ak3; Cantonese: wong4 gam1 dak1; Mandarin: huáng jīn dé) was born in San Francisco, California, sometime between 1868 and 1873^[2]. His father, Wong Si Ping and his mother, Wee Lee^[3] were immigrants from Taishan, China and were not United States citizens. Toisanese or the Taishan dialect (台山話 Toisanese: Hoi4 saan6 wa1, Cantonese: toi4 saan1 wa6), or Seiyap (四邑), is a Chinese dialect (or group of very similar dialects) spoken in and around Taishan, in Guangdong province. ... Standard Cantonese is a variant, and is generally considered the prestige dialect of Cantonese Chinese. ... Map of eastern China and Taiwan, showing the historic distribution of Mandarin Chinese in light brown. ... San Francisco redirects here. ... Not to be confused with the unrelated Mount Taishan Taishan (台山 pinyin: Táishān; Cantonese: Toisan; local: Hoisan ) is a coastal city in Guangdong Province, China. ... The word citizen may refer to: A person with a citizenship Citizen Watch Co. ...

In 1890 Wong's parents returned to live in China. Later that year Wong himself traveled to China and, having returned, was granted entry "upon the sole ground that he was a native-born citizen of the United States". Four years later, however, the circumstances had changed, as Wong, who was employed in San Francisco as a cook, sailed to China on another temporary visit in 1894. When he returned to the U.S. in August 1895, he was detained at the Port of San Francisco by the Collector of Customs and denied permission to enter the country "...because the said Wong Kim Ark, although born in the city and county of San Francisco, state of California, United States of America, is not, under the laws of the state of California and of the United States, a citizen thereof, the mother and father of the said Wong Kim Ark being Chinese persons, and subjects of the emperor of China, and the said Wong Kim Ark being also a Chinese person and a subject of the Emperor of China". Year 1890 (MDCCCXC) was a common year starting on Wednesday (link will display the full calendar) of the Gregorian calendar (or a common year starting on Monday of the Julian calendar). ... 1894 (MDCCCXCIV) was a common year starting on Monday (see link for calendar). ... Year 1895 (MDCCCXCV) was a common year starting on Tuesday (link will display full calendar) of the Gregorian calendar (or a common year starting on Sunday of the 12-day-slower Julian calendar). ... The Port of San Francisco lies on the western edge of the San Francisco Bay at the Golden Gate. ... Customs is an authority or agency in a country responsible for collecting customs duties and for controlling the flow of animals and goods (including personal effects and hazardous items) in and out of a country. ...

Background

The Congress of the United States had enacted a law, known as the Chinese Exclusion Act, prohibiting persons of the Chinese race from coming into the United States or becoming naturalized U.S. citizens. Chinese immigrants already in the U.S. were allowed to stay, but were ineligible for naturalization and if they left the U.S., they generally could not return. Congress in Joint Session. ... The first page of the Chinese Exclusion Act. ... For other uses, see Race (disambiguation). ... In law, naturalization refers to an act whereby a person acquires a citizenship different from that persons citizenship at birth. ...

However, the Fourteenth Amendment to the United States Constitution, ratified in 1868 after the Civil War, states the following concerning citizenship: 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. Amendment XIV in the National Archives The Fourteenth Amendment to the United States Constitution (Amendment XIV) is one of the post-Civil War amendments (known as the Reconstruction Amendments), first intended to secure rights for former slaves. ... Combatants United States of America (Union) Confederate States of America (Confederacy) Commanders Abraham Lincoln, Ulysses S. Grant Jefferson Davis, Robert E. Lee Strength 2,200,000 1,064,000 Casualties 110,000 killed in action, 360,000 total dead, 275,200 wounded 93,000 killed in action, 258,000 total...

Issue

The Supreme Court, in the Wong Kim Ark case, was called upon to decide whether an American-born person of Chinese ancestry could constitutionally be denied U.S. citizenship and excluded from the country.

Holding

In a 6-2 decision, the Court held that under the Fourteenth Amendment, a child born in the United States of parents of foreign descent who, at the time of the child's birth are subjects of a foreign power but who have a permanent domicile and residence in the United States and are carrying on business in the United States, and are not employed in any diplomatic or official capacity under a foreign power, and are not members of foreign forces in hostile occupation of United States territory, becomes a citizen of the United States at the time of birth.

Rationale

The 14th Amendment's citizenship clause, according to the court's majority, had to be interpreted in light of English common law tradition that had excluded from citizenship at birth only two classes of people: (1) children born to foreign diplomats and (2) children born to enemy forces engaged in hostile occupation of the country's territory. The majority held that the "subject to the jurisdiction" phrase in the 14th Amendment specifically encompassed these conditions (plus a third condition, namely, that Indian tribes were not considered subject to U.S. jurisdiction^[4]) - and that since none of these conditions applied to Wong's situation, Wong was a U.S. citizen, regardless of the fact that his parents were not U.S. citizens (and were, in fact, ineligible ever to become U.S. citizens because of the Chinese Exclusion Act). The opinion emphasized the fact that "...during all the time of their said residence in the United States, as domiciled residents therein, the said mother and father of said Wong Kim Ark were engaged in the prosecution of business, and were never engaged in any diplomatic or official capacity under the emperor of China". This article concerns the common-law legal system, as contrasted with the civil law legal system; for other meanings of the term, within the field of law, see common law (disambiguation). ... This article is about the people indigenous to the United States. ...

Since Wong (according to the majority opinion) was a U.S. citizen from birth, the restrictions of the Chinese Exclusion Act did not apply to him. An act of Congress, the majority held, does not trump the Constitution; such a law "cannot control [the Constitution's] meaning, or impair its effect, but must be construed and executed in subordination to its provisions."

Minority opinion

Chief Justice Melville Fuller, in a dissenting opinion joined by Justice John Harlan, argued that the history of U.S. citizenship law had broken with English common law tradition after independence—citing as an example the embracing in the U.S. of the right of expatriation (giving up of one's native citizenship) and the rejection of the contrary British doctrine of perpetual allegiance. The minority argued that the principle of citizenship by descent (that is, the concept of a child inheriting his or her father's citizenship regardless of birthplace) had been more pervasive in U.S. legal history since independence. Melville Weston Fuller (February 11, 1833 – July 4, 1910) was the Chief Justice of the United States between 1888 and 1910. ... This is about the pre-World-War-I US Supreme Court justice; for his grandson, the mid-20th-century holder of the same position, see John Marshall Harlan II. John Marshall Harlan (June 1, 1833 – October 14, 1911) was an American Supreme Court associate justice. ... This article concerns the History of British nationality law. ... Jus sanguinis (Latin for right of blood) is a right by which nationality or citizenship can be recognised to any individual born to a parent who is a national or citizen of that state. ...

Pointing to the language of the Civil Rights Act of 1866, which declared to be citizens "all persons born in the United States and not subject to any foreign power, excluding Indians not taxed", and which was enacted into law only two months before the 14th Amendment was proposed by Congress, the minority argued that "it is not open to reasonable doubt that the words 'subject to the jurisdiction thereof,' in the amendment, were used as synonymous with the words 'and not subject to any foreign power' . . . ." They thus reasoned that the majority opinion exactly contradicted the original intended meaning of the 14th Amendment. This article does not cite any references or sources. ...

In the view of the minority, excessive reliance on birthplace as the principal determiner of citizenship would lead to an untenable state of affairs in which "...the children of foreigners, happening to be born to them while passing through the country, whether of royal parentage or not, or whether of the Mongolian, Malay or other race, were eligible to the presidency, while children of our citizens, born abroad, were not". Jus soli (Latin for right of the territory), or birthright citizenship, is a right by which nationality or citizenship can be recognised to any individual born in the territory of the related state. ... This article or section does not cite its references or sources. ... Federal courts Supreme Court Circuit Courts of Appeal District Courts Elections Presidential elections Midterm elections Political Parties Democratic Republican Third parties State & Local government Governors Legislatures (List) State Courts Local Government Other countries Atlas  US Government Portal      For other uses, see President of the United States (disambiguation). ...

The dissenters acknowledged that other children of foreigners — including freed slaves — had, through the years, acquired U.S. citizenship through birth on U.S. soil. But they still saw a difference between those people and U.S.-born individuals of Chinese ancestry, because of (1) strong cultural traditions discouraging Chinese immigrants from assimilating into mainstream American society, (2) Chinese laws of the time which made acquiring a new citizenship or renouncing allegiance to the Chinese emperor a capital crime and (3) the provisions of the Chinese Exclusion Act making Chinese immigrants already in the United States ineligible for citizenship. This article or section is in need of attention from an expert on the subject. ... Capital punishment, or the death penalty, is the execution of a convicted criminal by the state as punishment for crimes known as capital crimes or capital offences. ...

Effect

Signatures of Wong Kim Ark's four sons on U.S. immigration documents.

As a result of Wong Kim Ark's U.S. citizenship being confirmed by the Supreme Court, three of his four sons were subsequently recognized as U.S. citizens and allowed to come to the United States: Wong Yook Sue (黃郁賜, Toisanese: wong11 nguk3 ti33, Cantonese: wong4 yuk1 tsi3); Wong Yook Thue (黃沃修, Toisanese: wong11 nguk3 siu33, Cantonese: wong4 yuk1 sau1); and Wong Yook Jim (黃沃沾, Toisanese: wong11 nguk3 dim33, Cantonese: wong4 yuk1 zim1). A fourth son — his eldest, Wong Yoke Fun (黃毓煥, Toisanese: wong11 nguk3 vun22, Cantonese: wong4 yuk1 wun6) — was rejected by U.S. officials, who claimed to see discrepancies in the testimony at his immigration hearing and refused to accept Wong Kim Ark's claim that the boy was his son.^[5] Image File history File links Size of this preview: 391 × 599 pixelsFull resolution (574 × 880 pixel, file size: 9 KB, MIME type: image/png) Signatures of Wong Kim Arks four sons: Wong Yoke Fun (黃毓煥); Wong Yook Sue (黃郁賜); Wong Yook Thue (黃沃修); and Wong Yook Jim (黃沃沾). Taken from photocopies of four... Image File history File links Size of this preview: 391 × 599 pixelsFull resolution (574 × 880 pixel, file size: 9 KB, MIME type: image/png) Signatures of Wong Kim Arks four sons: Wong Yoke Fun (黃毓煥); Wong Yook Sue (黃郁賜); Wong Yook Thue (黃沃修); and Wong Yook Jim (黃沃沾). Taken from photocopies of four...

Prior to Wong Kim Ark the Supreme Court had held that birthplace by itself was not sufficient to grant citizenship (Elk v Wilkins, 112 U.S. 94, 1884). U.S. citizenship law since Wong Kim Ark has acknowledged both jus soli (citizenship through place of birth) and jus sanguinis (citizenship inherited from parents). Wong Kim Ark's case was subsequently cited in two major Supreme Court decisions on citizenship: Perkins v. Elg, 307 U.S. 325 (1939) (involving a U.S.-born woman who was alleged to have lost her U.S. citizenship when her Swedish parents took her back to Sweden with them when she was a baby); and Afroyim v. Rusk, 387 U.S. 253 (1967) (involving a naturalized U.S. citizen who subsequently moved to Israel and was alleged to have lost his U.S. citizenship after voting in an Israeli election). Jus soli (Latin for right of the territory), or birthright citizenship, is a right by which nationality or citizenship can be recognised to any individual born in the territory of the related state. ... Jus sanguinis (Latin for right of blood) is a right by which nationality or citizenship can be recognised to any individual born to a parent who is a national or citizen of that state. ... Year 1939 (MCMXXXIX) was a common year starting on Sunday (link will display the full calendar) of the Gregorian calendar. ... Afroyim v. ... Year 1967 (MCMLXVII) was a common year starting on Sunday (link will display full calendar) of the 1967 Gregorian calendar. ... Voting is a method of decision making wherein a group such as a meeting or an electorate attempts to gauge its opinion—usually as a final step following discussions or debates. ...

Wong Kim Ark was also cited in Plyler v. Doe, 457 U.S. 202 (1982), a Supreme Court decision which struck down a Texas state law that had sought to deny public education to undocumented alien children (i.e., children born abroad who had come to the United States illegally along with their parents — not children born in the U.S. to illegal alien parents). The court's majority opinion in Plyler said that, according to the Wong court, the 14th Amendment's phrases "subject to the jurisdiction thereof" and "within its jurisdiction" were essentially equivalent and that both referred primarily to physical presence. It held that that illegal immigrants residing in a state are "within the jurisdiction" of that state, and added in a footnote that "no plausible distinction with respect to Fourteenth Amendment 'jurisdiction' can be drawn between resident aliens whose entry into the United States was lawful, and resident aliens whose entry was unlawful."^[6] Plyler v. ... Year 1982 (MCMLXXXII) was a common year starting on Friday (link displays the 1982 Gregorian calendar). ...

(1) Wong Kim Ark's signature on a 1914 U.S. immigration document (2) Wong Kim Ark's name, written by an interpreter on a 1926 U.S. immigration document (3) Wong Kim Ark's signature in English on a 1910 U.S. immigration document

In response to concerns over illegal immigration in the United States (and the associated fear that children of illegal immigrants could serve as "anchor babies"), bills have been introduced from time to time in Congress which have challenged the conventional interpretation of the citizenship clause of the 14th Amendment and have sought to actively and explicitly deny citizenship at birth to U.S.-born children of foreign visitors or illegal aliens. No such bill has ever come close to being enacted; even if one did, it would presumably achieve its intended result only if the Supreme Court, in a new case, were to conclude that Wong Kim Ark had been wrongly decided and that the precedent set in 1898 should be repudiated. Some attempts have also been made to supersede Wong Kim Ark by amending the Constitution itself, but no such amendment has ever been approved by Congress in order to be voted upon by state legislatures. Image File history File links No higher resolution available. ... Image File history File links No higher resolution available. ... Illegal alien and illegal aliens redirect here. ... Anchor baby or jackpot baby are terms used to refer to a child born in the United States to illegal immigrants or other non-citizens. ... A bill is a proposed new law introduced within a legislature that has not been ratified, adopted, or received assent. ... Stare decisis (Latin: , Anglicisation: , to stand by things decided) is a Latin legal term, used in common law systems to express the notion that prior court decisions must be recognized as precedents, according to case law. ... Year 1898 (MDCCCXCVIII) was a common year starting on Saturday (link will display the full calendar) of the Gregorian calendar (or a common year starting on Monday of the 12-day-slower Julian calendar). ... This page lists all ratified and unratified amendments to the United States Constitution, as well as some proposals for amendments. ...

Wong Kim Ark in 1931.

It has been suggested by some critics of U.S. citizenship policy relating to U.S.-born children of illegal immigrants that Wong Kim Ark does not hold such children to be U.S. citizens, because Wong's parents were legal non-citizen residents of the United States at the time of his birth.^[7] Those advocating this view assert that a subsequent case before the courts, dealing with "anchor babies", would easily be distinguished from Wong Kim Ark by virtue of this difference in the parents' legal status. Proponents of the conventional view argue that the Wong Kim Ark majority defined the "jurisdiction" exception to the jus soli rule very narrowly; that references in the majority opinion to the legal resident status of Wong's parents were obiter dicta and not an essential part of the holdings of the case; that the court majority's reason for mentioning the legal resident status of Wong's parents was simply to illustrate that they were in the United States as ordinary people and not as representatives of a foreign government; and that the 1982 Plyler case affirmed the conventional, mainstream interpretation of Wong Kim Ark with regard to the question of what being "subject to the jurisdiction" of the United States means. In the end, no one can really know how the Supreme Court might rule in a new case challenging the citizenship of U.S.-born children of illegal immigrants until and unless such a case were actually heard, and ruled upon, by the court. Image File history File links Wong_Kim_Ark_1931. ... Image File history File links Wong_Kim_Ark_1931. ... In law, to distinguish a case means to differentiate the facts of the case before the court from the facts of a case of precedent where is material depends on the legal issue. ... In law, the term dicta is used to refer to a judges statement of legal opinion that is not directly relevant to the case being heard. ... Year 1982 (MCMLXXXII) was a common year starting on Friday (link displays the 1982 Gregorian calendar). ... Plyler v. ...

It has also been suggested by some that Wong Kim Ark supports the view that non-U.S.-born children of American parentage are not natural-born citizens of the United States and that such an individual may therefore not legally become President or Vice-President, even though Congress has enacted laws providing that foreign-born children of U.S. citizens are (in many cases) U.S. citizens by birth via jus sanguinis. Proponents of this view sometimes point to the passage from the Supreme Court's minority opinion about U.S.-born children of foreigners being eligible for the Presidency, but not foreign-born children of U.S. citizens; note, though, that this statement, being part of the minority opinion, is not in any way legally binding as a precedent. In general, a natural-born citizen of a country is someone who is legally recognized as that countrys citizen as of the moment of birth, rather than by acquiring citizenship afterwards through naturalization. ... Federal courts Supreme Court Circuit Courts of Appeal District Courts Elections Presidential elections Midterm elections Political Parties Democratic Republican Third parties State & Local government Governors Legislatures (List) State Courts Local Government Other countries Atlas  US Government Portal      For other uses, see President of the United States (disambiguation). ... The Vice President of the United States is the second-highest executive official of the United States government, the person who is, in the words of Adlai Stevenson, a heartbeat from the presidency. ... Jus sanguinis (Latin for right of blood) is a right by which nationality or citizenship can be recognised to any individual born to a parent who is a national or citizen of that state. ...

References

1873 (MDCCCLXXIII) was a common year starting on Wednesday (see link for calendar). ... 1894 (MDCCCXCIV) was a common year starting on Monday (see link for calendar). ... Year 1910 (MCMX) was a common year starting on Saturday (link will display calendar) of the Gregorian calendar (or a common year starting on Friday [1] of the 13-day-slower Julian calendar). ... The Tong Zhi Emperor, born Zai Chun (April 27, 1856–January 12, 1875) was the tenth emperor of the Manchu Qing Dynasty, and the eighth Qing emperor to rule over China, from 1861 to 1875. ... The Chinese calendar is a lunisolar calendar, incorporating elements of a lunar calendar with those of a solar calendar. ... is the 293rd day of the year (294th in leap years) in the Gregorian calendar. ... 1871 (MDCCCLXXI) was a common year starting on Sunday (see link for calendar). ... Year 1931 (MCMXXXI) was a common year starting on Thursday (link will display full 1931 calendar) of the Gregorian calendar. ... is the 274th day of the year (275th in leap years) in the Gregorian calendar. ... 1870 (MDCCCLXX) was a common year starting on Saturday (link will display the full calendar) of the Gregorian calendar (or a common year starting on Monday of the 12-day slower Julian calendar). ... Year 1868 (MDCCCLXVIII) was a leap year starting on Wednesday (link will display the full calendar) of the Gregorian Calendar (or a leap year starting on Monday of the 12-day slower Julian calendar). ... East Asian age reckoning is a concept that originated in China and is used in East Asian countries. ... 1870 (MDCCCLXX) was a common year starting on Saturday (link will display the full calendar) of the Gregorian calendar (or a common year starting on Monday of the 12-day slower Julian calendar). ... Year 1931 (MCMXXXI) was a common year starting on Thursday (link will display full 1931 calendar) of the Gregorian calendar. ... Year 1895 (MDCCCXCV) was a common year starting on Tuesday (link will display full calendar) of the Gregorian calendar (or a common year starting on Sunday of the 12-day-slower Julian calendar). ... In common law countries, habeas corpus () (Latin: [We command that] you have the body) is the name of a legal action, or writ, through which a person can seek relief from unlawful detention of themselves or another person. ... Year 1910 (MCMX) was a common year starting on Saturday (link will display calendar) of the Gregorian calendar (or a common year starting on Friday [1] of the 13-day-slower Julian calendar). ... Year 1890 (MDCCCXC) was a common year starting on Wednesday (link will display the full calendar) of the Gregorian calendar (or a common year starting on Monday of the Julian calendar). ... Year 1901 (MCMI) was a common year starting on Tuesday (link will display calendar) of the Gregorian calendar (or a common year starting on Monday [1] of the 13-day-slower Julian calendar). ... Year 1902 (MCMII) was a common year starting on Wednesday (link will display calendar) of the Gregorian calendar (or a common year starting on Tuesday [1] of the 13-day-slower Julian calendar). ... For the rap album, see 1924 (album). ... The Indian Citizenship Act of 1924 granted full U.S. citizenship to Americas indigenous peoples. ... Elk v. ... Year 1884 (MDCCCLXXXIV) was a leap year starting on Tuesday (link will display the full calendar) of the Gregorian calendar (or a leap year starting on Sunday of the 12-day-slower Julian calendar). ... The San Bruno police station next to the BART station at the Shops at Tanforan. ... Year 2005 (MMV) was a common year starting on Saturday (link displays full calendar) of the Gregorian calendar. ... It has been suggested that this article or section be merged with freedom of information legislation. ... U.S. Citizenship and Immigration Services (USCIS) is a part of the U.S. Department of Homeland Security (DHS), and performs some of the functions formerly carried out by the United States Immigration and Naturalization Service, which was part of the Department of Justice. ... Year 2007 (MMVII) is the current year, a common year starting on Monday of the Gregorian calendar and the AD/CE era in the 21st century. ... is the 298th day of the year (299th in leap years) in the Gregorian calendar. ... The Heritage Foundation is a public policy research institute based in Washington, D.C., in the United States. ...

External links

• "United States v. Wong Kim Ark" on Wikisource.
• Full text of the Supreme Court opinion at Findlaw.com
• "The Progeny of Citizen Wong," SF Weekly, November 4, 1998 — an article about a great-granddaughter of Wong Kim Ark (a granddaughter of his son Wong Yook Jim)