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The Forgotten Story of the Expatriation Act

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By Rachel Michelle Gunter

On April 10, 2025, the House of Representatives passed the Safeguard American Voter Eligibility (SAVE) Act on a largely party-line vote. Republicans hailed the bill as a way to safeguard American elections from undocumented migrants voting.

Critics, by contrast, warn it could make voting more difficult—if not impossible—for legally eligible voters. That’s especially true for tens of millions of married women, who may not be able to provide the required documentation to prove their citizenship to register to vote. Presenting a birth certificate remains the easiest way to do so under the Act. However, many married women take their husband’s surnames and therefore don’t have birth certificates that match their current legal names.

If the Senate passes the SAVE Act and President Donald Trump signs it into law, it will mean that millions of American women could find themselves in the shoes of Ethel Mackenzie, an early 20th century suffragist. Like McKenzie, they might see their ability to register and vote inhibited due to a congressional effort to prevent non-citizens from voting.

When Mackenzie tried to register to vote after California adopted woman suffrage in 1911, she was shocked to find out she couldn’t—despite being born in the Golden State. The culprit: the 1907 Expatriation Act, a federal law that stripped American women of their citizenship when they married non-citizens. Mackenzie’s case exposed how nativist policies could harm not just immigrants, but also the rights of American women. Now, the Save Act threatens to do the same.

In 1855, Congress passed the Naturalization Act. The law made any immigrant woman who married a citizen man into a citizen herself, as long as she met the racial requirements for citizenship. In 1868, the 14th Amendment established birthright citizenship for all people born in the U.S., except for American Indians and the children of foreign diplomats.

In the last three decades of the 19th century, however, nativist sentiment surged. In 1882, Congress passed the Chinese Exclusion Act, banning Chinese laborers from immigrating to the U.S. In 1892, Congress extended and expanded the ban in the Geary Act. And in 1907, President Theodore Roosevelt negotiated the Gentleman’s Agreement with Japan restricting Japanese immigration to the U.S.

That same year, the State Department pressured Congress to pass the Expatriation Act. Officials argued that marriages between citizens and non-citizens were handled differently by different nations and without a uniform rule in the U.S., the department couldn’t determine who was entitled to an American passport and protection while outside of the country.

Advocates for women’s suffrage thought the bill wasn’t a good idea and expected the courts to find it unconstitutional. They believed it was was wildly out of step with the ongoing erosion of coverture, a set of legal practices that the State Department had specifically used to justify their recommendation to Congress. Coverture derived from English common law and dictated that women suffered “civil death” upon marriage. They ceased to have a legal identity, and instead became covered by their husband’s legal identity. This left them unable to sign contracts or own property.

Suffragists fought to curtail coverture. But they also pushed another agenda item—one that helped propel the passage of the Expatriation Act—disfranchising non-citizens.

In the colonial era and the Early Republic, voting eligibility was often tied to property ownership and residency, rather than citizenship. As such, non-citizen voting was often legal and common. The practice surged again in the midwest in the 1830s, and was added to several state constitutions in the Deep South as a Reconstruction reform after the Civil War to counter the votes of unreconstructed white southerners.

But in the nativist climate of the early 20th century, the practice had fallen out of favor, and suffragists and other progressives fought to end it. Some suffragists argued that immigrants opposed suffrage for women and prohibition, and therefore immigrant voting posed a threat to their agenda. Reflecting how the two concepts became intertwined, South Dakota, Texas, and Arkansas put amendments on their ballots to enfranchise women while simultaneously ending non-citizen voting. The amendments passed in South Dakota and Arkansas.

As adoption of the Expatriation Act proved, the push to end non-citizen voting proved too powerful for suffragists to control. The new law made married women dependent citizens; their citizenship status was now entirely derived from that of their husbands.

When McKenzie discovered that the new law prevented her from voting, she filed suit, arguing that Congress could not take away by law what the Constitution granted her by birthright. While suffragists expected the courts would overturn the Expatriation Act, the nativist sentiments of the day were stronger than the trend towards women’s rights.

In 1915, the Supreme Court ruled against Mackenzie. As Ohio Representative John Cable summarized, the Court found that citizenship “was not such a right, privilege, or immunity that it could not be taken away by an act of Congress.” The justices found that Mackenzie’s decision to marry a non-citizen amounted to “voluntary expatriation.” She was now stateless and unprotected in her own country.

The decision left suffragists concerned that without married women’ independent citizenship, suffrage would be an impossibility.

Such fears proved wrong: in 1920 the ratification of the 19th Amendment prohibited states from barring women from voting on account of sex. Passage of the suffrage amendment encouraged Congress to revisit married women’s independent citizenship, because it meant that immigrant women naturalized through marriage could vote, while American women denaturalized by marriage were disfranchised. The League of Women Voters, formed out of the National American Woman Suffrage Association, lobbied Congress for married women’s independent citizenship.

In 1922, they scored a partial victory when Congress passed the Cable Act, which ended automatic denaturalization for American women if their spouse was an immigrant racially eligible for citizenship. The law also provided a pathway for denaturalized women to reclaim their citizenship. But it still excluded women who married Asian immigrants.

Some politicians used this period of denaturalization strategically to their own advantage. In 1928, Ruth Bryan Owen, daughter of William Jennings Bryan, became the first woman to win election to the U.S. House of Representatives from a former Confederate state. But upon her victory, her opponent sued arguing that her period of denaturalization after marrying a British serviceman during WWI meant that she hadn’t been a citizen for the previous seven years—a constitutional requirement to serve.

The challenge forced Owen, a native born citizen; daughter of a three-time presidential candidate, congressman, and Secretary of State; and a duly elected official from Florida to plead her case before Congress. Her fellow lawmakers chose to seat Owen, rejecting the challenge that threatened to undo the will of her constituents.

During the 1920s, Congress amended the Cable Act several times. Then, in 1933 the Senate voted to adopt the convention of the Pan American Conference, which argued that differences in nationality laws based on sex should be eliminated. The next year, President Franklin D. Roosevelt signed the Equal Nationality Act, through which American women achieved full, independent citizenship.

Sixty years later, a new round of concerns of undocumented migration prompted Congress to make it a crime for non-citizens to vote in federal elections. Lawmakers did so even though it hadn’t been legal for non-citizens to vote in either state or federal elections in any state since Arkansas’s ban went into effect in 1926.

Republicans allege that the SAVE Act will help enforce this existing law. But instead, it threatens to disenfranchise millions of married American women.

The law stipulates that people can prove citizenship either by presenting a REAL ID or a military identification card, if they confirm a person’s citizenship status. But many can not, which leaves people registering to vote with the option of presenting a state identification card or driver’s license in conjunction with a certified birth certificate that includes the “full name” of the applicant. It’s this last provision which poses a problem for up to 69 million women who took their husband’s name upon getting married. That means their birth certificates no longer include their full legal names.

The law makes no allowances for such situations. It does leave room for states to decide which secondary documents to accept, but this would still be an additional burden on married women, could be applied unevenly across the country, and may open the door for challenges to election results—like the one faced by Ruth Bryan Owen—on the grounds that states didn’t meet these onerous requirements.

A century after the suffrage movement, the SAVE Act threatens to echo the harms of the Expatriation Act. While it’s supporters claim it will target non-citizen voters, instead it could prevent American women from voting.

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Guyana, CDF Sign US$18m Agreement for Agricultural Development

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The Government of Guyana and the CARICOM Development Fund (CDF) have signed a US$18 million financing agreement to kickstart the Agricultural and Infrastructural Development Programme (AIDP).

The programme aims to benefit over 4,300 farmers across the ten regions of Guyana, with 40% of the beneficiaries being women and youth.

The programme will provide support for compliance with food safety, sanitary, and phytosanitary standards in the agriculture sector.

Senior Minister in the Office of the President with Responsibility for Finance and the Public Service, Dr. Ashni Singh, noted that the project aligns closely with Guyana’s national development priorities and the regional agenda on food security.

Dr. Singh emphasized the importance of a strong and competitive non-oil economy, with agriculture being a principal pillar.

He added that the project will contribute to Guyana’s food security agenda and economic growth, particularly in rural and hinterland areas.

The project will be implemented by the Ministry of Agriculture, led by Minister Zulfikar Mustapha.

The CDF’s CEO, Mr. Rodinald Soomer, stated that the programme is a bold and strategic investment in the fulfilment of CARICOM and Guyana’s shared vision for a resilient, productive, and inclusive agricultural sector.

The programme includes the construction of a modern swine abattoir, 13 new or upgraded agro-processing facilities, and eight enhanced surveillance outposts.

These components will lay the foundation for a safer, more competitive agricultural sector and contribute to the Government’s broader diversification strategy.

The project aligns with Guyana’s National Strategy for Agriculture (2020-2030) and will enable the Ministry of Agriculture to propose policies and investments that generate the hi

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Don’t Betray “America First” With a War on Iran

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By Reid Smith

Sometimes, the most crucial test of a powerful country involves not its strength but its judgment. The United States faces just such a test now, as Israel wages a determined campaign against Iran and U.S. President Donald Trump weighs whether to join it.

In recent days, the president has sent mixed signals. “We now have complete and total control of the skies over Iran,” he posted yesterday on Truth Social, pointedly using the first-person plural. In other posts the same day, he mused about killing the supreme leader of Iran and demanded “UNCONDITIONAL SURRENDER!” from the Islamic Republic. After months of talking up the prospects for diplomacy with Iran (and years of bemoaning past American military failures in the Middle East), the famously mercurial Trump seemed to have embraced a more hawkish view.

Earlier today, however, he was more equivocal. “I may do it,” he told reporters. “I may not do it. I mean, nobody knows what I’m going to do.”

If the United States does wind up at war with Iran, it would hardly come as a shock. Enmity toward the Islamic Republic runs deep in Washington—and understandably so. The Iranian regime has held Americans hostage and supported terrorists and insurgents who have killed U.S. service members in Lebanon and Iraq. And a sense of American solidarity with Israel naturally springs from cultural bonds, mutual security interests, and decades of strategic partnership. What is more, this is a fight that makes sense for Israel—a country that is pursuing the kind of strategic clarity that Washington has failed to achieve in its own recent wars. Emerging from the trauma of the October 7 attacks, Israel has sought to eliminate profound threats rather than merely manage them. Israel shattered Hezbollah’s command structure and political standing in Lebanon, helped collapse Bashar al-Assad’s brutal regime in Damascus, and devastated Hamas in Gaza. With Iran’s proxies dismantled and Syrian airspace suddenly open to Israeli jets, the Islamic Republic has become a far more vulnerable adversary. It now faces an Israeli military with formidable intelligence capabilities, superior weaponry, and the political resolve to finish the fight.

There is little doubt that the world is better off without a nuclear-armed Iran. And the United States should always support its allies and partners. But those countries’ wars of necessity should not become Washington’s wars of choice. The United States has a role to play in this conflict, but it should not cross the threshold into direct military action against Iran. Calls for U.S. military strikes rest on the dangerous assumption that such action would be clean, quick, and contained. If Trump decides to enter this war, however, it would likely escalate in ways that would produce severe negative consequences for the United States, its allies, and the global economy. Washington can and should continue to assist Israel by providing missile defense interceptors and logistical aid to protect Israeli civilians from Iranian drone and missile attacks. But it should not take part in airstrikes against Iranian targets, join in any efforts to carry out regime change, or deploy U.S. ground forces. Simply put, the United States should not become a co-combatant in this war.

Doing otherwise would represent a catastrophic error of judgment on Trump’s part. It would also compromise the “America first” foreign policy that helped bring him to power and that a large majority of Americans support. When he burst onto the political scene in 2015, a significant part of Trump’s appeal rested on his refreshing honesty about Washington’s blunders in the Middle East. At a time when most Republican officials were still trying to say as little as possible about the disastrous Iraq war, Trump loudly echoed the conclusion that the vast majority of Americans had reached years earlier: “Obviously, the war in Iraq was a big, fat mistake,” as he put it in an early GOP primary debate that year.

Now, however, Trump risks making a similarly significant error in the Middle East. His strategic instincts seem to be leading him astray. With any luck, his strong political instincts will kick in, and he will step back from the brink.

ONE THING LEADS TO ANOTHER

The notion that the United States could conduct a limited action against Iran without provoking a desperate and ferocious response reflects a lack of imagination. What begins as a surgical strike on hardened Iranian enrichment facilities buried deep underground at the Fordow site risks spiraling in unpredictable directions. Reprisal attacks would ensue, and all sides would climb the escalation ladder.

Iran would likely retaliate against U.S. troops stationed at exposed and vulnerable bases in Iraq and Syria. It might also hit major American military installations such as the Al Udeid Air Base in Qatar and the U.S. Navy’s Fifth Fleet headquarters in Bahrain. Cyberattacks targeting American energy, financial, and communications infrastructure could follow. Iran could cripple global shipping by lining the Strait of Hormuz with mines and encouraging the Yemen-based Houthi militia to step up its attacks on ships in the Red Sea. In response, the U.S. would almost certainly launch its own retaliatory strikes at a broad array of Iranian military and proxy targets across the region.

As in past American interventions in the Middle East, the conflict could become self-perpetuating. Political off-ramps may evaporate under the inevitable pressure to escalate. What began as a limited strike could transform into a regional war.

Meanwhile, China would probably seek to exploit such a situation to advance its own interests. In recent days, after the Pentagon ordered the USS Nimitz aircraft carrier to relocate from the Indo-Pacific to the Middle East, the Chinese military carried out provocative sea and air patrols in which it shadowed U.S. allies in contested waters. If U.S. forces wind up deployed to the Middle East for a longer period, China could increase its pressure on Taiwan and ramp up its harassment of vessels from the Philippines and Japan. Such provocations would test the resolve of U.S. allies in the region and raise doubts about Washington’s reliability.

MR. MERCURIAL

In addition to posing risks to U.S. interests, American military intervention in Iran could also hurt the very party it intended to help: Israel. For decades, Israeli leaders have made the case that they must defend themselves, by themselves. They have invested heavily in airpower, missile defenses, and cyber-capabilities precisely to ensure that, during a crisis, they are not dependent on an outside power or the whims of their patrons in Washington. American intervention now would render those efforts meaningless, solidifying Israel’s dependence and its junior-partner role in its relationship with Washington.

An American entry could also alter the contours of Israel’s war aims. Even if Trump decides to enter the fight, he may have another change of heart and pressure (or force) Israel to stop short of what Israeli leaders would otherwise consider a satisfactory end state. Trump, after all, is hardly a paragon of consistency. A mere month ago, he demoted his national security adviser, Mike Waltz, by nominating him to serve instead as U.S. ambassador to the United Nations; according to The Washington Post, Trump was irritated that, while he was pursuing a deal with Iran, Waltz had been coordinating closely with Israeli Prime Minister Benjamin Netanyahu on plans to attack. Now, however, Trump himself has apparently leapt into such planning.

Trump might reverse course again, however, especially if he believes the American public—and, in particular, his supporters—are not on board. An Economist/YouGov poll of Americans conducted between June 12 and June 16 asked: “Do you think the U.S. military should get involved in the conflict between Israel and Iran?” Just 16 percent of respondents said yes, while a striking 60 percent said no. Even among Trump voters, who are not necessarily more hawkish but tend to fall in line with the president, only 19 percent supported U.S. military intervention, whereas 53 percent opposed it. Trump is likely keeping a close eye on such numbers—as is Netanyahu.

American military intervention in Iran could hurt the very party it intended to help: Israel.

There is also the question of congressional authorization for any American military action, which remains a bedrock constitutional requirement, although one that has been routinely ignored in the past few decades. There is no standing Authorization for Use of Military Force that applies to Iran. If the administration believes direct military action is warranted, it should appear before Congress and make the case to the American people.

Trump, however, is highly unlikely to ask for congressional approval before acting. With a pliant GOP in charge of both houses, he may feel he can ignore Capitol Hill altogether. But Congress could complicate things for Trump, especially if a critical mass of Republican legislators began to oppose U.S. military action. Prominent conservatives are already sowing doubt. “I don’t want us fighting a war. I don’t want another Mideast war,” Senator Josh Hawley, a Republican from Missouri and a fervent supporter of Israel, told a reporter from CNN earlier today. “I’m a little concerned about our sudden military buildup in the region,” he added. American intervention, particularly if U.S. service members are killed, could trigger high-profile congressional hearings and vocal opposition in conservative media outlets. This could amplify public skepticism and further erode support for U.S. participation in the war.

Given these strategic, political, and constitutional considerations, the United States should help Israel finish this war on its own, and on its own terms. But that is all Washington should do. This is Israel’s fight, and Israel’s war to win. There is no reason to make it Washington’s war to lose.

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Oil Prices Climb as Iran-Israel Conflict Escalates

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Oil prices surged on Tuesday as the conflict between Iran and Israel continued to intensify, with no end in sight.

Brent crude futures rose $2.11, or 2.88%, to $75.35 a barrel, while U.S. West Texas Intermediate crude gained $1.43, or 1.99%, to $73.20.

The conflict has raised concerns about potential disruptions to oil flows, particularly through the Strait of Hormuz, a vital waterway for oil shipments.

Although there have been no significant disruptions to oil infrastructure and flows so far, the market remains cautious.

Iran partially suspended gas production at the South Pars field, which it shares with Qatar, after an Israeli strike caused a fire.

Israel also targeted the Shahran oil depot in Iran, further escalating tensions.

Phil Flynn, senior analyst with the Price Futures Group, said the conflict is likely to have a lasting impact on oil markets, similar to the Russia-Ukraine conflict.

However, Saxo Bank analyst Ole Hansen believes the risk of disruption to oil shipments through the Strait of Hormuz is low, given the potential economic consequences for Iran.

Despite the conflict, oil supplies remain ample, with the International Energy Agency revising its world oil demand estimate downwards and increasing its supply estimate.

Investors are also focused on central bank interest rate decisions, with the U.S. Federal Open Market Committee set to discuss rates later on Tuesday.

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