The U.S. has a long history. In 1789, the first Congress established that "all children born within the limits of the United States, and subject to its jurisdiction, are declared to be natural-born citizens" except those born outside the United States, who are deemed aliens. The Citizenship Clause was added by the Fourteenth Amendment in 1868. In 1898, the first federal law to grant citizenship to persons born abroad to parents who were U.S. citizens was enacted. The law, the Wong Kim Ark Act, provided that "any child born... during the term of his parent's residence in the United States shall be regarded as US Citizenship born in the United States." The U.S. Supreme Court held in 1917 that the phrase "subject to its jurisdiction" did not mean only U.S. residents and their descendants, but also nonresidents who have been living in the U.S. for five years. It has also ruled that a person born abroad may be a U.S. citizen if he or she is eligible to citizenship under the law and actually naturalizes, regardless of whether either parent is a U.S. citizen.