"The citizenship status of blacks was never quite clear. Obviously, they were not quite resident aliens, for they had no country but the United States. The federal government generally avoided taking a stand on black citizenship when the subject arose. A few blacks got federal passports implying that they were citizens... The Articles of Confederation stated that 'the free inhabitants of these states... shall be entitled to all privileges of immunities of free citizens in the several states', and Congress voted down South Carolina's proposal to insert the word 'white' into this clause. Chief Justice Taney, in the infamous 1857 Dred Scott decision, asserted that blacks had never been, and could never be, citizens of the United States. He was wrong."