702. As many who have examined the citizenship laws of the United States, and the historical record in other countries, have concluded, jus soli citizenship can and does coincide with racialized citizenship and immigration regimes, and with race-based differentiations in the rights and privileges of citizens. See, e.g., David Scott FitzGerald, The History of Racialized Citizenship, in Ayelet Shachar, Rainer Baubock, Irene Bloemraad, and Maarten Vink, eds., The Oxford Handbook of Citizenship 148 (2017). The point is that the Fourteenth Amendment’s Citizenship Clause with its jus soli guarantee was affirmatively intended to serve as a bulwark against racist ideology in the attribution of citizenship by birth. 703. Letter of constitutional law scholars in response to Trump administration consideration of executive order regarding “birthright” citizenship. 704. United States v. Wong Kim Ark, 169 U.S. 649 (1898); letter of constitutional law scholars in response to Trump administration consideration of executive order regarding “birthright” citizenship. 705. Plyler v. Doe, 457 U.S. 202, 214 (1982). 706. Id. (citing Cong. Globe, 39th Cong., 1st Sess. 1292 (1866)). 707. Adamson v. California, 332 U.S. 46, 74 (1947) (Black, J., dissenting). 708. Patrick Weil, The Sovereign Citizen: Denaturalization and the Origins of the American Republic 181-82 (2013). 709. Id. (“The legality of parental residence status was never raised as an issue either in majority or in dissenting opinions despite numerous opportunities presented to the different Justices.”). 710. Beatrice McKenzie, To Know a Citizen: Birthright Citizenship Documents Regimes in U.S. History, in Benjamin N. Lawrance and Jacqueline Stevens, eds., Citizenship in Question: Evidentiary Birthright and Statelessness 122 et seq. (2016). 711. See, e.g., Michael Anton, Citizenship shouldn’t be a birthright, The Washington Post (July 18, 2018), https:// www.washingtonpost.com/opinions/citizenship-shouldnt-be-a-birthright/2018/07/18/7d0e2998-891211e8-85ae-511bc1146b0b_story.html?utm_term=.0efaff5a4d18; Alexandra M. Wyatt, Birthright Citizenship and Children Born in the United States to Alien Parents: An Overview of the Legal Debate, Congressional Research Service (Oct. 28, 2015), at 13 (“Those who seek reinterpretation of the Citizenship Clause would seem to face substantially greater legal and constitutional hurdles than those who would maintain the birthright citizenship status quo. Nevertheless, it is not necessarily clear that the question has been truly settled.”). 712. Alexandra M. Wyatt, Birthright Citizenship and Children Born in the United States to Alien Parents: An Endnotes Overview of the Legal Debate, Congressional Research Service (Oct. 28, 2015), at 21; Polly J. Price, Stateless in the United States: Current Reality and Future Prediction, 46 Vand. J. Transnat’l L. 442 (2013) (analyzing Birthright Citizenship Act of 2013, H.R. 140, “the leading model for legislation to limit birthright citizenship in the United States,” which would amend § 301 of the INA). 713. Alexandra M. Wyatt, Birthright Citizenship and Children Born in the United States to Alien Parents: An Overview of the Legal Debate, Congressional Research Service (Oct. 28, 2015), at 21. 714. Afroyim v. Rusk, 387 U.S. 253, 267-68 (1967). 715. Record No. TC-05-2012-0077, concerning an appeal of a writ of amparo filed by Mrs. Juliana Dequis (or Deguis) Pierre, challenging Ruling No. 473/2012 rendered by the Civil, Commercial and Labor Branch of the Court of First Instance in the Judicial District of Monte Plata on July ten (10), two thousand twelve (2012), §11.1.4.1 (p. 89 of 147) (translation by Haitian American Lawyers Association of New York, Inc., 2014). 716. Id. 717. The figure given is 87.3%. Id. at 23 (“These figures show an overwhelming prevalence of Haitian immigrants.”). 718. Id. at 24. 719. Id. at 89. 720. Jonathan M. Katz, What happened when a nation erased birthright citizenship, The Atlantic (Nov. 12, 2018), https://www.theatlantic.com/ideas/archive/2018/11/ dominican-republic-erased-birthright-citizenship/575527/. 721. Id.; Inter-Am. C.H.R., Annual Report 2017, Chapter V – Follow-up on the recommendations by the IACHR regarding the situation of human rights in the Dominican Republic (2018), http://www.oas.org/en/iachr/docs/annual/2017/ docs/IA2017cap.5RD-en.pdf. 722. Katz, supra note 720; “Placeless” is borrowed from Lyndsey Stonebridge, Placeless People: Writing, Rights and Refugees (2018). 723. Margaret Stock, National Foundation of American Policy, The Cost to Americans and America of Ending Birthright Citizenship (NFAP Policy Brief, Mar. 2012),1, https://www.nfap.com/pdf/NFAPPolicyBrief.BirthrightCitizenship.March2012.pdf. 724. See Polly J. Price, Stateless in the United States: Current Reality and Future Prediction, 46 Vand. J. Transnat’l L. 442, 492 (2013). 725. Id. at 495. 726. Id. 193