United States v. Wong Kim Ark was an 1898 U.S. Supreme Court case that dealt with the issue of birthright citizenship as it applied, in this case, to a person of Chinese descent born in the United States. Wong was born in San Francisco in 1873 to immigrant parents. His father was a merchant and was affiliated with the firm Quong Sing & Co. in San Francisco. Under the Naturalization Act of 1790, Wong’s parents were not eligible to become citizens of the United States, which the act extended only to “free white persons.” Nothing changed after the passage of the Naturalization Act of 1870, which extended citizenship to “aliens of African nativity and persons of African descent.” Wong, however, was born in the United States, so he was presumably entitled to U.S. citizenship under the citizenship clause of the Fourteenth Amendment to the Constitution, 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.” That is to say, under the doctrine of birthright citizenship, he was in fact a U.S. citizen.