The case was U.S. v. Wong Kim Ark (1898). The Fuller Court had begun in a time of extreme hostility toward persons of Chinese descent, as the Chinese Exclusion cases showed. However, the justices softened their stance in a decision involving Wong Kim Ark, a man born to Chinese parents in San Francisco. The issue began when Ark left San Francisco to visit China and then sought to reenter the United States.

A customs inspector denied Ark reentry to the United States based on the Chinese Exclusion cases, such as Chae Chan Ping v. United States (1889). A lower federal court ruled that Ark could not be denied entrance to the United States because he was born there. The government appealed to the U.S. Supreme Court, which affirmed the lower court in U.S. v. Wong Kim Ark.

The Court relied on the explicit language of the Fourteenth Amendment, which states: “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.” The Court wrote that this amendment “affirms the ancient and fundamental rule of citizenship by birth within the territory, in the allegiance and under the protection of the country, including all children born of resident aliens.”