National Archives at San Francisco

Departure Statement of Wong Kim Ark, 1894

“All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside.”

14th Amendment to the U.S. Constitution

Birthright citizenship was put to test in the case of Wong Kim Ark, who was born in San Francisco, CA, in 1873, to immigrant parents who returned to China when he was a teen. In August 1895, upon his return to the United States after visiting with family in China, Wong Kim Ark was denied entry on the claim that he was not a citizen despite his San Francisco birth. His appeal eventually went all the way to the Supreme Court resulting in the 1898 precedent-setting ruling affirming birthright citizenship and protecting U.S.- born descendants of immigrants from being denied this citizenship, regardless of the ethnicity, nationality, or status of their parents.

The National Archives at San Francisco has court records and immigration records related to Wong Kim Ark. Follow these links to the National Archives Catalog to read the full text, view, and download related documents: 

This departure statement from 1894 details Wong Kim Ark's plan to visit China and return to the United States. Three individuals signed the statement attesting to his identity and it was notarized by Robert M. Edwards. 

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Departure Statement of Wong Kim Ark, 1894. National Archives Identifier: 2641490.

You can explore more records held in the National Archives at San Francisco by searching our online Catalog or by visiting our research room in person. We encourage researchers to contact us to learn more about our holdings or to schedule an appointment.

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