Black people were treated as if they did not fully belong, even if they lived in the United States or were born here. Since 1619, when Africans were first forced to come to what is now the United States, early laws excluded formerly enslaved Black people from becoming citizens. The law has long been used to define and limit who is considered a citizen and to exclude those who are not. For example, in 1787, the U.S. Constitution included language noting that enslaved Black people would be counted as three-fifths of a person.12 In 1790, the law limited citizenship to “free white person[s].”13 Because the law made being white a requirement for becoming a citizen, it sent the message that only white people truly belonged—a message that still shapes U.S. laws today. In 1857, the U.S. Supreme Court ruled in the case of Dred Scott v. Sanford that enslaved Black people were not citizens.14 Dred Scott was an enslaved Black man who went to court to argue that he should be free because he had lived in places where slavery was illegal. He also argued that, as a free person, he should have the same rights as any other American citizen.15 A famous line in the decision from Chief Justice Roger B. Taney stated that Black people “had no rights which the white man was bound to respect.16 The exclusion of formerly enslaved Black people from citizenship established the foundation for racially discriminatory citizenship and immigration laws. In 1868, after the Civil War, the Fourteenth Amendment to the U.S. Constitution provided citizenship for Black people, overturning the Dred Scott case and replacing the “three-fifths” language from the Constitution. However, even after the Fourteenth Amendment overturned the Dred Scott decision and acknowledged that Black people born in the United States were U.S. citizens at birth, laws continued to prevent individuals of African descent from exercising the same rights as white citizens.17 In the following years, Congress continued to pass discriminatory laws about who could become a citizen through naturalization laws and who could come to the United States through immigration laws. In 1882, Congress passed the Chinese Exclusion Act, which prevented people from China from coming to the United States for ten years. 18 This law was the first to exclude a racial group from entering the United States. In 1924, the Johnson-Reed Act19 excluded Asians and severely restricted the number of immigrants who were not white from migrating to the United States.20 In this way, the United States’ past naturalization and immigration laws had the racist goal of excluding non-white immigrants. Before the Civil Rights Movement, another example of widely practiced exclusion was the United States’ policy of limiting how many people could come from certain countries. This was called the quota system. During the Civil Rights Movement, the Immigration and Nationality Act of 1965 ended this quota system because it privileged European immigrants over other immigrants coming to the United States.21 The Immigration and Nationality Act was born out of the Black-led Civil Rights Movement, which resulted in increased rights and privileges for immigrants of all races.22 In signing the act, President Lyndon B. Johnson stated that the quota system “violated the basic principle of American democracy—the principle that values and rewards each man on the basis of his merit as a man. It has been un-American in the highest sense, because it has been untrue to the faith that brought thousands to these shores even before

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