John Elk was a Winnebago Indian who, in 1880, tried to register to vote in Omaha, Nebraska. The local registrar of voters, Charles Wilkins, denied his application. Elk sued Wilkins, arguing that he was a U.S. citizen under the Fourteenth Amendment to the Constitution, that he had renounced his allegiance to his tribe, and that because he was born in the United States, the Fifteenth Amendment guaranteed him the right to vote. After the circuit court dismissed the case, Elk appealed to the U.S. Supreme Court, which held that Elk was not a citizen of the United States under the Fourteenth Amendment and thus had not been deprived of any right under the Fifteenth Amendment. The Court found that even though Elk was born in the United States and had severed his tribal relationship, he had never been naturalized and had not become a citizen through any statute or treaty.