"Residents of Puerto Rico, Guam, the U.S. Virgin Islands, and the Northern Marianas Islands are deemed U.S. citizens under the Immigration and Nationality Act. But American Samoans are not. Congress has not granted birthright citizenship to residents of American Samoa or Swains Island, both of which are classified only as "outlying possessions." It is this disparate treatment that was before the court, after three American Samoans living in Utah brought a challenge to the Immigration and Nationality Act, contending that the statutory denial of citizenship is unconstitutional under the Fourteenth Amendment's Citizenship Clause. The Citizenship Clause was adopted after the Civil War primarily to protect the birthright citizenship of Black Americans, which was rejected by the Supreme Court prior to the Civil War. However, the meaning of the clause for residents of the territories has historically been contested — as has the force of constitutional protections in the territories altogether. In this case, Fitisemanu v. U.S., the American Samoans contend that the residents of all the territories should be considered "in the United States" for the purpose of citizenship. While American Samoans who live in the States may apply for citizenship, before they successfully do so they are denied many of the rights attached to citizenship, such as the right to vote, run for office, or serve on juries. The plaintiffs in this case say their career opportunities have been curtailed and that, as non-citizens, they are unable to sponsor immigration visas for their families. Applying for citizenship itself is onerous, can take several years, and is not guaranteed."