Are you a “U.S. Citizen” or an “American Citizen”?
by John-Henry Hill, M.D., Ph.D.
If you answered “U.S. Citizen”, congratulations! You just waived all of your “natural rights” as guaranteed by the Constitution; waived your :individual sovereignty; and turned yourself from a living man or woman into a “PERSON” and “SUBJECT” of the U.S. with only “privileges” and “immunities” that the U.S. government sees fit to grant to you (conveniently called “civil rights”), which the U.S. government can take away from you any time it chooses. All courtesy of the 14th Amendment.
1.) PERSON: In law a “person” is NOT equivalent of a living, breathing “man” [or woman or child]. Rather, a “person” usually refers to a man as a legal fiction or “strawman” or “artificial man” and may refer to corporations, as well as actors within corporations (officers and employees). Most importantly, as noted immediately above, a man as an individual sovereign is NOT a “person” – which means that if a man affirms that he is a “person”, he thereby waives his powers derived from the his rights as a sovereign and falls within the jurisdiction of the private, municipal corporation named the “United States”. Even a State, town, city or “county is a person in a legal sense,” Lancaster Co. v. Trimble, 34 Neb. 752, 52 N.W. 711; but a sovereign is not. In re Fox, 52 N.Y. 535, 11 Am.Rep. 751; U.S. v. Fox 94 U.S. 315, 24 L.Ed. 192 …. ; and Black’s Law Dictionary, 4th Ed., p 1300 In fact, in relation to the United States, a State is considered as BOTH a “person” and a “foreign country”, so that when a man enters a federal court, he is legally leaving his State and entering a foreign country.
2.) CITIZEN: The term the “citizen of the United States” is defined solely in the 14th Amendment ratified July 9, 1868 by the States after the Civil War. Section 1. states, “All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and [citizens] of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.” Section 5. “The Congress shall have the power to enforce, by appropriate legislation, the provisions of this article.”
Consequently, the terms “citizen” and “citizen of the United States” involve the definition of “person” AND the two (2) qualifications listed for “citizen of the United States”. A “person” may mean a man (as a “natural person”) OR it may mean a legal fiction or “artificial person”, such as a corporation or an actor within a corporation (officer or other employee) or even a foreign government. For the sake of argument, if we concede that the 14th Amendment refers to a “natural person” or man, that “person” is required to meet BOTH of the TWO (2) qualifications:
(A) born or naturalized in the United States
(B) subject to the jurisdiction thereof [of the United States].
First, note that the 14th Amendment goes on to state that, “No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States”. By becoming a “citizen of the United States”, a man had just waived his inherent, constitutionally-guaranteed RIGHTS; and now has ONLY “privileges” and “immunities” as granted by the United States government. And any “privilege” or “immunity” granted to you can just as easily be withdrawn.
Personally, I was born in Massachusetts (potentially meeting requirement #1, depending on how one defines the “United States. The U.S. Supreme Court has accepted at least FIVE (5) different definitions of the “United States” and U.S. Codes contain at least 29 different definitions of which I am aware.) So, in any document I always require that the definition of the “United States” be clearly written out. If NOT, then I simply refuse to sign that document – instead I substitute “Massachusetts, America. Note that I do NOT write the “State of Massachusetts”, since the “State of Massachusetts” is a sub-division of the corporate United States.
BUT I have NEVER signed any contract, sworn an oath (a contract in law) or otherwise ever stated or agreed that I am “subject to the jurisdiction thereof [of the United States].” Indeed, whenever I am asked if I am a “United States citizen”, I always reply, “NO. I am an American citizen.” (In fact, on the old U.S. passport applications, there used to be 2 boxes of which you needed to check one: 1) U.S. citizen; and 2) American citizen. I always checked #2; and whenever I renew my passport, I always write in that I am an “American citizen” and do NOT check the box next to “U.S. citizen”. Doing so it perfectly acceptable; and your passport will still be issued.)
The reader needs to be aware of the legal doctrine of “inclusio unius est exclusio alterius”, meaning that the “inclusion of some items means the exclusion of all alternative items” or that which follows the word “include” means ONLY those items and EXCLUDES all non-listed items. We have observed above that “United States” has at least four (4) different legal meanings. In this instance, does it mean the United States of America (#4 above) as States united (the “Union”) by and under the Constitution OR the sovereign Nation (#1) OR the corporate TRUST (#2) established by the Constitution OR, retroactively, the private, foreign municipal corporation (#3) established by the Congress through the District of Columbia Organic Act of 1871? Does it mean that one need only be born or naturalized in one of the geographic States of the United States of America? That would seem logical, BUT the Supreme Court has repeatedly ruled that the District of Columbia is NOT a State within the United States; and neither are any of the federal enclaves within the States, or territories and insular possessions of the United States. If “United States” means the foreign municipal corporation whose jurisdiction includes ONLY the District of Columbia, the federal enclaves within the States, or territories and insular possessions of the United States, then under the legal doctrine of “inclusio unius est exclusio alterius”, then does that definition exclude the people born or naturalized in the various 50 States and exclude the various 50 States? The confusion is dizzying!
Today’s “Commercial Courts” versus True “Courts of Record”
3.) COURT OF RECORD: To be a true court of record a court must have four characteristics, and may have a fifth. They are:
- A judicial tribunal having attributes and exercising functions independently of the person of the magistrate designated generally to hold it [Jones v. Jones, 188 Mo.App. 220, 175 S.W. 227, 229; Ex parte Gladhill, 8 Metc. Mass., 171, per Shaw, C.J. See, also, Ledwith v. Rosalsky, 244 N.Y. 406, 155 N.E. 688, 689][Black’s Law Dictionary, 4th Ed., 425, 426]
- Proceeding according to the course of common law [Jones v. Jones, 188 Mo.App. 220, 175 S.W. 227, 229; Ex parte Gladhill, 8 Metc. Mass., 171, per Shaw, C.J. See, also, Ledwith v. Rosalsky, 244 N.Y. 406, 155 N.E. 688, 689] [Black’s Law Dictionary, 4th Ed., 425, 426]
- Its acts and judicial proceedings are enrolled, or recorded, for a perpetual memory and testimony. [3 Bl. Comm. 24; 3 Steph. Comm. 383; The Thomas Fletcher, C.C.Ga., 24 F. 481; Ex parte Thistleton, 52 Cal 225; Erwin v. U.S., D.C.Ga., 37 F. 488, 2 L.R.A. 229; Heininger v. Davis, 96 Ohio St. 205, 117 N.E. 229, 231]
NOTE: A “transcript” is NOT a true “enrollment” or “recording”, for a perpetual memory and testimony. A “transcript” is merely the personal notes of the Clerk of the Court; and is composed of whatever the Clerk chooses to write down, officially called “Minutes”.
4. Has power to fine or imprison for contempt. [3 Bl. Comm. 24; 3 Steph. Comm. 383; The Thomas Fletcher, C.C.Ga., 24 F. 481; Ex parte Thistleton, 52 Cal 225; Erwin v. U.S., D.C.Ga., 37 F. 488, 2 L.R.A. 229; Heininger v. Davis, 96 Ohio St. 205, 117 N.E. 229, 231.][Black’s Law Dictionary, 4th Ed., 425, 426]
5. Generally possesses a seal. (but today a SEAL is considered OPTIONAL) [3 Bl. Comm. 24; 3 Steph. Comm. 383; The Thomas Fletcher, C.C.Ga., 24 F. 481; Ex parte Thistleton, 52 Cal 225; Erwin v. U.S., D.C.Ga., 37 F. 488, 2 L.R.A. 229; Heininger v. Davis, 96 Ohio St. 205, 117 N.E. 229, 231.][Black’s Law Dictionary, 4th Ed., 425, 426]
Following the Declaration of Independence and the American Revolution the people were and forever remain “individual sovereigns”. The concept of individual sovereignty stands on its own as a respected and valid concept, at least to those sufficiently educated and informed to understand it. As a king is a sovereign, so each man is an individual sovereign – and just as a sovereign king may consent to restrictions on his rights, so may each man so consent. But the king and the individual retain their sovereignty, which is not forfeited by any contracts or agreements. Therefore, a sovereign (either a King or an individual man) can withdraw his consent at any time for any reason.
“…at the Revolution, the sovereignty devolved on the people; and they are truly the sovereigns of the country, but they are sovereigns without subjects…with none to govern but themselves; the citizens of America are equal as fellow citizens, and as joint tenants in the sovereignty. Chisholm v. Georgia (US) 2 Dall 419, 454, 1 L Ed 440, 455 @DALL 1793 pp471-472
“The people of this State, as the successors of its former sovereign, are entitled to all the rights which formerly belonged to the King by his prerogative. Through the medium of their Legislature they may exercise all the powers which previous to the Revolution could have been exercised either by the King alone, or by him in conjunction with his Parliament; subject only to those restrictions which have been imposed by the Constitution of this State or of the U.S.”
Lansing v. Smith, 21 D. 89., 4 Wendel 9 (1829) (New York)”D.” = Decennial Digest Lansing v. Smith, 4 Wend. 9 (N.Y.) (1829), 21 Am.Dec. 89 10C Const. Law Sec. 298; 18 C Em.Dom. Sec. 3, 228; 37 C Nav.Wat. Sec. 219; Nuls Sec. 1`67; 48 C Wharves Sec. 3, 7.
NOTE: Am.Dec.=American Decision, Wend. = Wendell (N.Y.)
“There is no such thing as a power of inherent sovereignty in the government of the United States …. In this country sovereignty resides in the people, and Congress can exercise no power which they have not, by their Constitution entrusted to it: All else is withheld.” — Julliard v. Greenman, 110 U.S. 421
“The very meaning of ‘sovereignty’ is that the decree of the sovereign makes law.” American Banana Co. v. United Fruit Co., 29 S.Ct. 511, 513, 213 U.S. 347, 53 L.Ed. 826, 19 Ann.Cas. 1047.
“‘Sovereignty’ means that the decree of sovereign makes law, and foreign courts [U.S. commercial courts] cannot condemn influences persuading sovereign to make the decree.” Moscow Fire Ins. Co. of Moscow, Russia v. Bank of New York & Trust Co., 294 N.Y.S. 648, 662, 161 Misc. 903.
The concept of individual sovereignty  stands on its own as a respected and valid concept – at least to those sufficiently educated and informed to understand it. As a king is a sovereign, so each man is an individual sovereign – and just as a sovereign king may consent to restrictions on his rights, so may each man so consent. But the king and the individual retain their sovereignty, which is not forfeited by any contracts or agreements.
 SOVEREIGNTY (Black’s Law Dictionary, Fourth Edition) “The power to do everything in a state without accountability,–to make laws, to execute and to apply them, to impose and collect taxes and levy contributions, to make war or peace, to form treaties of alliance or of commerce with foreign nations, and the like.” Story, Const. Sec 207
“Sovereignty in government is that public authority which directs or orders what is to be done by each member associated in relation to the end of the association. It is the supreme power by which any citizen is governed and is the person or body of persons in the state to whom there is politically no superior. The necessary existence of the state and that right and power which necessarily follow is “sovereignty.”” Today “sovereignty in government” in its most expansive sense is meant as “supreme, absolute, uncontrollable power, the absolute right to govern. The word which by itself comes nearest to being the definition of “sovereignty” is will or volition as applied to political affairs.” City of Bisbee v. Cochise County, 52 Ariz. 1, 78 P.2d 982, 986.
RESERVATION OF SOVEREIGNTY: “ (b) Even if the Tribe’s power to tax were derived solely from its power to exclude non-Indians from the reservation, the Tribe has the authority to impose the severance tax. Non-Indians who lawfully enter tribal lands remain subject to a tribe’s power to exclude them, which power includes the lesser power to tax or place other conditions on the non-Indian’s conduct or continued presence on the reservation. The Tribe’s role as commercial partner with petitioners should not be confused with its role as sovereign. It is one thing to find that the Tribe has agreed to sell the right to use the land and take valuable minerals from it, and quite another to find that the Tribe has abandoned its sovereign powers simply because it has not expressly reserved them through a contract. To presume that a sovereign forever waives the right to exercise one of its powers unless it expressly reserves the right to exercise that power in a commercial agreement turns the concept of sovereignty on its head. MERRION ET AL., DBA MERRION & BAYLESS, ET AL. v. JICARILLA APACHE TRIBE ET AL. 1982.SCT.394 , 455 U.S. 130, 102 S. Ct. 894, 71 L. Ed. 2d 21, 50 U.S.L.W. 4169 pp. 144-148.
In Bond v. U.S. (2011) the Supreme Court recognized individual sovereignty when it ruled 9-0 that a criminal defendant [as a man] – not just states – indicted on charges of violating a federal statute, has standing to challenge the validity of the statute on the ground that it infringes on the powers reserved to the states and/or to the people under the Tenth Amendment. Bond v. United States, 131 S. Ct. 2355, 180 L. Ed. 2d 269 (2011) [2011 BL 158313]
Even though Bond’s attorneys successfully challenged the jurisdiction of the federal courts, it would have been more appropriate had the Supreme Court affirmed individual sovereignty over the federal government using the 9th Amendment, but unfortunately Bond’s attorneys made a crucial error by choosing ONLY the 10th Amendment on which to base the challenge to federal jurisdiction, thereby limiting the Court’s scope. Despite winning the appeal, Bond’s attorneys’ error was important in that it dealt only with POWERS (10th Amendment); NOT INDIVIDUAL RIGHTS (9th Amendment).
- 9th Amendment (Protection of individual rights not specifically enumerated in the Constitution.)
“The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others [other rights] retained by the people.”
- 10th Amendment (Powers of States and the people.)
“The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.”
Three points deserve emphasis here.
(1) The 9th Amendment guaranteed the natural RIGHTS possessed by the individual man (the people), whether or not listed in the Constitution or Bill of Rights (amendments 1-10). Thus, the 9th Amendment is an affirmation of individual sovereignty.
(2) The 10th Amendment guaranteed the POWERS reserved to the States or the people (as individuals) provided that:
(a) such powers had not been delegated to the federal government in the Constitution; OR
(b) such powers had not been prohibited to it by the States.
(3) While a POWER derived from a right may be delegated and the exercise of a RIGHT temporarily waived, a man, as an individual sovereign, NEVER waives or gives up possession of his natural rights.
While item (a) above – the issue of “delegated powers” – is often brought up in the courts, the issue of “powers prohibited by the States” is often ignored in terms of the powers of a single sovereign State. As the papers of the Federalists and anti-Federalists make clear, the “powers prohibited by the States” clause affirms the right of each State to prohibit the exercise of a particular power – in short, what is currently being termed in newspapers as the “state nullification of federal statutes” under the concept of each State’s sovereignty over the federal government. However, it should be remembered that each individual man forever has retained all of his natural rights and that, as an individual sovereign, his rights are NOT subject to any limitations by government. He may temporarily delegate some POWERS to a government, but as an individual sovereign with all his RIGHTS intact, a man may revoke from government those delegated POWERS at any time for any reason at his own will – the man’s wish becomes the law. Once again, “The very meaning of ‘sovereignty’ is that the decree of the sovereign makes law.” American Banana Co. v. United Fruit Co., 29 S.Ct. 511, 513, 213 U.S. 347, 53 L.Ed. 826, 19 Ann.Cas. 1047 and “To presume that a sovereign forever waives the right to exercise one of its powers unless it expressly reserves the right to exercise that power in a commercial agreement turns the concept of sovereignty on its head.” [Merrion et al., DBA Merrion & Bayless, et al. v. Jicarilla Apache Tribe et al. (1982) 455 U.S. 130, 102 S. Ct. 894, 71 L. Ed. 2d 21, 50 U.S.L.W. 4169 pp. 144_148]
It should be noted that following the Declaration of Independence, in America the various States of the Union were each considered individual, sovereign countries; and each State was considered a “foreign country” with respect to the other Union States. Similarly, when the Union called the United States of America was formed, each of the various States was considered a “foreign country” with respect to the United States government. Therefore, a federal court is considered a “foreign court” with respect to each of the various States and to the people. This concept remains valid today, as the Supreme Court has affirmed numerous times. In Brushaber v. Union Pacific Railroad Co.,240 U.S. 1 (1916), the Supreme Court ruled that Brushaber, under the law, was a “nonresident alien” of the United States corporation. Frank Brushaber made an important statement of fact which remained unchallenged at every level in the federal courts. He identified himself as a citizen of the State of New York and a resident of the Borough of Brooklyn, in the City of New York. He did not identify himself as a “citizen of the United States”, as a “United States citizen” or as a “resident of the United States”. He indicated that he lived and worked in New York State, outside the District of Columbia and outside any territory, possession or enclave governed by the Congress of the United States. “Enclaves“ are areas within the 50 States which are expressly “ceded” to Congress by the acts of State Legislatures (e.g., military bases).
The Supreme Court ruled that Brushaber was a “nonresident” because he lived and worked outside the areas of land over which the Congress has exclusive jurisdiction. The authority to have exclusive jurisdiction over this land was granted to Congress by the authorities at Article 1, Section 8, Clause 17 (“1:8:17”), and Article 4, Section 3, Clause 2 (“4:3:2”), in the U.S. Constitution – what some legal experts have called the “FEDERAL ZONE”. The Supreme Court also ruled that Brushaber was an “alien“ because his statement of citizenship was taken as proof that he was not a citizen of the federal zone. He was not a “citizen of the United States” nor a “United States citizen”, either through birth or naturalization, because the term “United States” in this context means only the federal zone. Therefore, he was an alien with respect to the District of Columbia and the federal enclaves, territories and possessions over which the Congress has exclusive legislative jurisdiction. This may sound strange to the casual reader, but the federal statutes do not refer to creatures from Mars: the lawyers who created the federal statutes knew precisely what they were writing, even if the average man does not.
However Frank Brushaber also made a fatal error which contributed to his ultimate downfall in the case. He identified his opposition as a corporation chartered by the State of Utah. This was incorrect. The Union Pacific Railroad Company was originally created in the year 1862 by an Act of Congress. The stated purpose of the corporation was to aid in the construction of a railroad and telegraph line from the Missouri River to the Pacific Ocean (from the “Union” to the “Pacific”). This Act was passed on July 1, 1862, by the Thirty-Seventh Congress, Second Session, as recorded in the Statutes at Large, (December 5, 1859, to March 3, 1863, at Chapter CXX, page 489). At that time, Utah had not yet been admitted as a State of the Union and therefore was not considered one of the several States. Utah was still a territory, i.e., a “federal state” within the “federal zone” over which the Congress indeed had exclusive legislative jurisdiction.
Being a creation of Congress, the Union Pacific Railroad Company was found to be a “domestic” corporation under the law – that is, the Union Pacific Railroad Company was with the exclusive jurisdiction of Congress and the United States municipal corporation (the District of Columbia and the federal enclaves, territories and possessions) as per the District of Columbia Act of 1871 and subsequent related acts. This is another term which is very confusing to the casual reader. In common, everyday language, the term “domestic” is often used to mean “inside the country”. For example, airports are divided into different areas for domestic and foreign flights, in order to allow Customs agents to inspect the baggage and passports of passengers arriving on flights from foreign countries. However, under federal statutes, the term “domestic” does not mean “inside the country”; it means “inside the federal zone” (the United States municipal corporation) as its own country which is an area that is much smaller than the whole country. Accordingly, a “foreign” corporation is a corporation chartered by a government that is “outside the federal zone“, just as each of the 50 sovereign States is still considered a “foreign country” in relation to the United States municipal corporation (the Federal Zone). Indeed, the U.S. Supreme Court has ruled on several occasions that each state is a “sovereign foreign nation” with respect to each of the other states and with respect to the “United States” (the U.S. government).
The Federal Zone consists of the enclaves, territories and possessions over which the Congress of the United States municipal corporation called the “United States.” (the District of Columbia and the federal enclaves, territories and possessions) has exclusive legislative jurisdiction. California is outside of the federal zone, for example, and corporations which are chartered in the California state are foreign corporations with respect to the federal zone called the “United States.”. Similarly, corporations chartered in France are likewise foreign corporations with respect to the federal zone called the “United States.”. It is simple, once you understand the proper legal definitions of the terms “foreign” and “domestic” in the federal statutes. To make things even more confusing, “California state” is one of the 50 sovereign States and therefore is NOT subject to the statutes legislated by Congress. However, the “State of California” is a sub-corporation of the United States municipal corporation called the “United States” and therefore falls under the jurisdiction of the federal zone and Congress’ statutes.
After the 14th Amendment was ratified in 1868 and District of Columbia Act of 1871 was enacted by Congress:
“It is quite clear, then, that there is a citizenship of the United States and a citizenship of a State, which are distinct from each other and which depend upon different characteristics or circumstances in the individual.” [whether or not the “United States” means the federal government as a corporate TRUST established by the Constitution and the limited territory over which it exercises exclusive sovereign authority OR as (definition #3 above) a private, foreign municipal corporation] Slaughter House Cases, 83 U.S. 36,(1873)
As discussed above, each man is an “individual sovereign” and the People, as individuals or as a group, are sovereign. The People are not subject to the jurisdiction of the federal government, even though they are born in the United States. The 14th Amendment attempts through confusing language to invert this relationship. One of the qualifications to be a “citizen of the United States” is that one is required to be born or naturalized in the United States. Another qualification is that one is required to be, “subject to the jurisdiction thereof. [of the United States]” It is not possible to be a citizen of the United States without meeting BOTH conditions: born or naturalized in the United States AND subject to the jurisdiction thereof. Thus, if you are born or naturalized, AND if you are subject to the jurisdiction of the United States, then you automatically qualify as a citizen of the United States (which means the United States municipal corporation called the “United States” – including ONLY the District of Columbia and the federal enclaves, territories and possessions.
From the point of view of the federal enforcers of federal acts or statutes, the qualifications are worked in reverse. They reverse-interpret the 14th Amendment as incorrectly meaning that if you say and/or do not deny that you are a citizen of the United States, then that automatically – as an unrebutted presumption – means you are totally subject to its jurisdiction [and have been born or naturalized]. This opinion is not shared by the judicial branch. See 14 C.J.S. 426, 430 (Corpus Juris Secundum):
The particular meaning of the word “citizen” is frequently dependent on the context in which it is found, and the word must always be taken in the sense which best harmonizes with the subject matter in which it is used. “One may be considered a citizen for some purposes and not a citizen for other purposes, as, for instance, for commercial purposes, and not for political purposes. So, a person may be a citizen in the sense that as such he is entitled to the protection of his life, liberty, and property, even though he is not vested with the suffrage or other political [legislated] (guaranteed rights ????) riand guarghts.
 Cal.–Prowd v. Gore, 2 Dist. 207 P. 490. 57 C.A. 458.
 Cal.–Prowd v. Gore. 2 Dist. 207 P. 490. 57 C.A. 458.
La.–Lepenser v Griffin, 83 So. 839, 146 La. 584
N.Y.–Union Hotel Co. v. Hersee, 79 N.Y. 454
 U.S.–The Friendschaft, N.C., 16 U.S. 14, 3 Wheat. 14, 4 L.Ed. 322
–Murray v. The Charming Betsy, 6 U.S. 64, 2 Cranch 64, 2 L.Ed. 208
Md.–Risewick v. Davis, 19 Md. 82
Mass.–Judd v. Lawrence, 1 Cush 531
R.I.–Greeough v. Tiverton Police Com’rs, 74 A 785, 30 R.I. 212
 Mass.–Dillaway v. Burton, 153 N.E. 13, 256 Mass. 568″
In any case, if you fail to object to the government’s view of your citizenship status, then the federal government will PRESUME that you agree with their view and that you are subject to the acts-statutes of the federal government. The ancient maxim of law applies: “A presumption NOT rebutted becomes a fact in law” for a particular case within any court. That means that by failing to formally rebut the court’s presumption that you have consented to be under that court’s jurisdiction (and thus its legislated act, statutes, codes, regulations, etc), then you have waived your “natural rights” under the Common Law and guaranteed by the Constitution (especially its “Bill of Rights”) AND you now possess only privileges as granted by the federal government. Therefore, the most practical method for a man to retain his rights as a individual sovereign is to reject the title of “citizen” and to state explicitly that one is NOT a “citizen of the United States” or a “citizen of a State”; and that one does NOT consent to federal jurisdiction and waives all benefits and privileges from government resulting from being a “citizen of the United States” or a “citizen of a State”. And, for goodness sake, do NOT claim to be a “sovereign citizen” – an obvious contradiction in terms, since one cannot possibly be a “citizen” and still retain one’s sovereignty.