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  • ets forth the two principal modes of acquiring citizenship (birth in the U.S. and naturalization), nothing restricts the power of Congress to withdraw citizenship. (This case was overturned by Afroyim v. Rusk.) Montana v. Kennedy, 366 U.S. 308 (1961): A person born in 1906, whose mother was a native-born citizen of the United States and whose father was a foreign citizen, who was born overseas and
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