June 2: Declared to be Citizens of the United States

The Fourteenth Amendment conferred citizenship on those born in the United States, but one group was left out: Native Americans. In 1884, a case challenging that position made its way to the Supreme Court. John Elk brought a case against a registrar in Omaha for refusing to register him to vote because he was not considered a citizen. In a 7–2 decision, the Supreme Court ruled that the Fourteenth Amendment did not apply to Elk because, as an Indian, he was not subject to the jurisdiction of the United States.