In my work “Diversity of Citizenship and a Citizen of a State who is not a Citizen of the United States”, I showed in the cases of Bondurant v. Watson (103 U.S. 281, 1880) and Sun Printing & Publishing Association v. Edwards (194 U.S. 377, 1904) that one who is a citizen of the United States and a citizen of a State (Fourteenth Amendment), as well as one who is a citizen of a State who is not a citizen of the United States (Article IV, Section 2, Clause 1 of the Constitution), has the requisite citizenship to give a circuit court of the United States jurisdiction in a diversity of citizenship suit.

In my work “Diversity of Citizenship includes a Citizen of a State who is not a Citizen of the United States”, I made the following statement: “A citizen of the United States is to identified his citizenship in a federal court by averring that he or she is a citizen of the United States AND a citizen of a State of the Union. . . . The reason for this is that a citizen of the United States can be a citizen of the United States without being a citizen of a State, as in the case of living overseas (aboard)."

In this work I show that unless one who is a citizen of the United States does not aver in a diversity of citizenship suit that he or she is a citizen of the United States that he or she will be presumed to be a citizen of a State; Brown v. Keene (33 U.S. (Peters 8) 112, 1834), and that if one is a citizen of the United States, he or she still must aver that he or she is a citizen of the United States AND a citizen of a State of the Union in a diversity of citizenship suit; that the Fourteenth Amendment did not change this requirement; Wood v. Wagon (6 U.S. (2 Cranch) 1, 1804), Robertson v. Cease (97 U.S. 646, 1878), Steigleder v. McQuesten (198 U.S. 141, 1905).