In the Constitution and laws of the United States the word
"citizen" is generally, if not always, used in a political sense
to designate one who has the rights and privileges of a citizen
of a State or of the United States. It is also used in section 1
of Article XIV of the amendments to the Constitution which
provides that " . . . ." But is also sometimes used in popular
language to indicate the same thing as resident, inhabitant, or
person. That it is not so used in section 5508 in the Revised
Statutes (Crimes Against the Elective Franchise and Civil Rights
of Citizens) is quite clear . . . .. Here the doubtful word is
"citizen" and it is used in connection with the rights and
privileges pertaining to man as a citizen, and not as a person
only or an inhabitant. . . . For these reasons we are satisfied
that the word citizen, as used in this statute, must be given the
same meaning it has in the Fourteenth Amendment of the
Constitution, and that to constitute the offense which is
provided for, the wrong must be done to one who is a citizen in
that sense.
[Baldwin v. Franks, 120 U.S. 678]
[30 L.C.P.Co. 766, 770-771 (1887)]
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Baldwin v. Franks