Before the Fourteenth Amendment, there were two citizens; one was a citizen of a State, born in the United States of America (a native citizen); the other was a citizen of the United States, born in a foreign country (a naturalized citizen).

There were (and still are) two more citizens before the Fourteenth Amendment. One was a citizen who a State naturalized according to the particular State’s own rules for naturalization, as opposed to the rule of naturalization established by Congress. The other citizen was a citizen of a State naturalized in a state court according to the rule of naturalization established by Congress.