Chief Justice Melville Fuller and Justice John Marshall Harlan, the lone dissenter in Plessy v. Ferguson, ruled against Wong Kim Ark. They focused on the fact that the Fourteenth Amendment was passed largely to ensure citizenship for recently freed African Americans. They wrote that “the subjects of the emperor of China … have never been allowed by our laws to acquire our nationality, and, except in sporadic instances, do not appear ever to have desired to do so.”