William J. Brennan, Jr., Rogers v. Bellei — Dissent
“ In the light of the complete lack of rational basis for distinguishing among citizens whose naturalization was carried out within the physical bounds of the United States, and those, like Bellei, who may be naturalized overseas, the conclusion is compelled that the reference in the Fourteenth Amendment to persons 'born or naturalized in the United States' includes those naturalized through operation of an Act of Congress, wherever they may be at the time. ”
