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Natural born citizen: the right way around

I and may others look to the old legal decisions for a definition of “natural born citizen.” The court cases, however, provide less help than one might hope for. As I was putting a pickle slice on my sandwich just now, I had a thought that I’m sharing in this essay.

Those early cases were not about who could be president, but who was a citizen. They note that the Constitution doesn’t say who is a citizen, but that it mentions the term in two contexts, the “natural born citizen” who is eligible to be president, and the naturalized citizen who is made so by act of Congress.

I had thought that the Constitution recognizes the citizenship of the natural born, but I think I had that backwards. It is the Constitution, in the presidential eligibility clause, that makes “natural born” Americans into citizens of the United States. If it were not for this provision of the Constitution, one would have to look to less authoritative sources to determine that “natural born” Americans are citizens at all.

It appears that under English Common Law, natural born subject means those who are subjects from birth1, and further that anyone born in the allegiance of the sovereign (whether child of alien or subject) qualifies as a natural born subject. Our courts recognize the English Common Law foundation of citizenship in the United States. The US Supreme Court, for example, in US v. Wong cited Mr. Justice Swayne in US v. Rhodes:

All persons born in the allegiance of the King are natural-born subjects, and all persons born in the allegiance of the United States are natural-born citizens. Birth and allegiance go together. Such is the rule of the common law, and it is the common law of this country, as well as of England. . . . We find no warrant for the opinion that this great principle of the common law has ever been changed in the United States. It has always obtained here with the same vigor, and subject only to the same exceptions, since as before the Revolution.

Congress under its power of naturalization creates other citizens at birth (natural born citizens) fulfilling the second constitutional reference. Birthers say that Congress cannot create new natural born citizens, but the Constitution explicitly gives them this power.


1See “Natural born citizen, a Dicey proposition: the blogger who came in from the cold.”

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28 Responses to Natural born citizen: the right way around

  1. avatar
    Joey June 10, 2015 at 3:43 pm #

    I’ve been intrigued by the status of citizens created by COLLECTIVE as opposed to individual naturalization. For example, the Treaty of Guadalupe-Hidalgo which ended the Mexican-American War gave residents of the former Mexican state of Alta Californa the option of moving to the new boundaries of Mexico or remaining in what was to becme the U.S. states of California, Arizona, New Mexico, Nevada, Utah, Colorado, Wyoming and becoming American citizens. 90% of those former Mexicans decided to become Americans.

  2. avatar
    Sam the Centipede June 10, 2015 at 9:00 pm #

    Sorry Doc, you have it all upsode down. There is nobreason to believe that “natural born” has ever had anything other than its plain ordinary (if slightly archaic) English meaning of “born with that nature”. There is no need for some crazy invented definition, it’s in its ordinary meaning. You’re behaving like a birther in trying to find magic meanings for words when they have none.

    Your last patragraph is ambiguous but it should be clearly understood that Congress’s Article 1 power to create a “uniiform rule of naturalization” refers to ALL citizens, not only those who go through a separate process of naturalization in their adult life. A baby born on U.S. soil is naturalized as it is born; ALL citizens are naturalized in that sense. The “uniform rule of naturalization” means a uniform rule for deciding who is a citizen. Of course we usually employ the term “naturalization” to refer to later acquisition of citizenship but its wider sense (used there) includes applying the rule at birth.

    Why over-complicate something where a dictionary has the answers?

  3. avatar
    Jim June 10, 2015 at 9:07 pm #

    Joey:
    90% of those former Mexicans decided to become Americans.

    Were they naturalized American citizens?

  4. avatar
    Matt June 10, 2015 at 10:43 pm #

    Doc,

    In reference to this statement of yours, and the quote from Justice Swayne that follows it:

    It appears that under English Common Law, natural born subject means those who are subjects from birth, and further that anyone born in the allegiance of the sovereign (whether child of alien or subject) qualifies as a natural born subject

    Let’s look a little deeper and beyond just your one quote. From WKA:

    II. The fundamental principle of the common law with regard to English nationality was birth within the allegiance, also called "ligealty," "obedience," "faith," or "power" of the King. The principle embraced all persons born within the King's allegiance and subject to his protection.

    So far we’re in agreement. But what is meant by “birth within the allegiance”?

    Allegiance is nothing more than the tie or duty of obedience of a subject to the sovereign under whose protection he is, and allegiance by birth is that which arises from being born within the dominions and under the protection of a particular sovereign. Two things usually concur to create citizenship: first, birth locally within the dominions of the sovereign, and secondly, birth within the protection and obedience, or, in other words, within the allegiance of the sovereign.

    WKA p. 659 (emphasis added)

    Also, Chancellor Kent in his Commentaries:

    To create allegiance by birth, the party must be born not only within the territory, but within the ligeance of the government

    WKA, p. 664.

    Finally, I refer you to p.668 and the discussion of the first statutes pertaining to birth abroad. It was “suggested that this general provision of the statute of 25 Edw. III

    [that all children inheritors, which from henceforth shall be born without the ligeance of the King, whose fathers and mothers at the time of their birth be and shall be at the faith and ligeance of the King of England, shall have and enjoy the same benefits and advantages to have and bear the inheritance within the same ligeance as the other inheritors aforesaid, in time to come; so always, that the mothers of such children do pass the sea by the licence and wills of their husbands.]

    was declaratory of the common law” . You can read the whole thing for yourself, but according to Mr. Binney,

    The notion that there is any common law principle to naturalize the children born in foreign countries, of native-born American father and mother, father or mother, must be discarded. There is not, and never was, any such common law principle.

    In conclusion:

    1. The Constitution is framed in the language of the common law.
    2. By the common law, one had to be born in the territory/dominion, and under the protection of the sovereign. Anyone who met BOTH of these conditions was a natural born subject.
    3. Anyone who was born abroad, even to citizen/subject parents, did not fall under the common law, and required a naturalization statute (for example a statute conferring citizenship at birth) to be a citizen at all.

    Didn’t NBC make this argument or something like it on his blog two or three years ago? Or is my memory failing me?

    Sorry for the rambling post. Geez, I sound like Mario.

  5. avatar
    Joey June 11, 2015 at 3:48 am #

    Jim: Were they naturalized American citizens?

    Who knows?

  6. avatar
    Joey June 11, 2015 at 3:50 am #

    No, Matt did NOT sound like Mario. Matt made sense.

  7. avatar
    Lupin June 11, 2015 at 4:42 am #

    My understanding is that the Louisiana purchase Treaty made the formerly French citizens of Louisiana natural-born instead of merely naturalized because it unambiguously states that they will have all the same rights, privileges etc. than US citizens.

  8. avatar
    Keith June 11, 2015 at 10:12 am #

    Matt: In conclusion:

    1. The Constitution is framed in the language of the common law.
    2. By the common law, one had to be born in the territory/dominion, and under the protection of the sovereign. Anyone who met BOTH of these conditions was a natural born subject.
    3. Anyone who was born abroad, even to citizen/subject parents, did not fall under the common law, and required a naturalization statute (for example a statute conferring citizenship at birth) to be a citizen at all.

    My understanding, and I emphasize that IANAL, is that you are correct on all three points. However, ‘Common Law’ can be overridden, replaced, or supplemented by actual legislated law. As there is no ‘Common Law’ covering foreign born children of American Citizens, Congress has seen fit to ‘fill the gap’ with actual law and declared that those children, as long as the parents meet certain specified criteria, are indeed citizens at birth (and thus natural born citizens). Remember, common law is ALWAYS trumped by actual legislation.

    Lupin:
    My understanding is that the Louisiana purchase Treaty made the formerly French citizens of Louisiana natural-born instead of merely naturalized because it unambiguously states that they will have all the same rights, privileges etc. than US citizens.

    This may well have been covered in the treaty (I haven’t read the entire thing lately 😎 ), but my understanding is that this sort of thing is 100% common. The whole subject thing descends from the Middle Ages and the relationship between a Lord and his Serfs. Serfs belong to the land, and who-so-ever is the Lord of the Land, that is to whom the serfs owe their allegiance. So for example when William the Conquerer died, William’s lands were divided between his sons, with his eldest son. Robert, getting Normandy and his second son, William getting England. The ‘natural subjects’ of William became ‘natural subjects’ of either Robert or William depending on where they were born. In other words, when the border moves, according to ‘common law’, the quality of subject or citizen stays with the locale, unless it is otherwise overridden by law or treaty.

    On the other hand, there is another argument I have invented (if birthers can do it so can I) which doesn’t get much traction from others (eh, so be it). My argument interprets the ‘grandfather’ clause to be still important because of the phrase ‘citizens at the time of the adoption of the Constitution’ (paraphrased from memory). When was the Constitution adopted in Louisiana (or in Southern Arizona for that matter) the – On the effective date of the Louisiana Purchase (or the Gadsden Purchase in the case of Southern Arizona), certainly not in 1789. So those folks who were citizens of Louisiana were covered by the Grandfather clause, by this argument. Seems reasonable to me.

  9. avatar
    Joey June 11, 2015 at 1:15 pm #

    Here’s the sections of the Treaty of Guadalupe-Hidalgo with regard to the collective naturalization of former Mexicans into citizens of the United States:
    ARTICLE VIII

    Mexicans now established in territories previously belonging to Mexico, and which remain for the future within the limits of the United States, as defined by the present treaty, shall be free to continue where they now reside, or to remove at any time to the Mexican Republic, retaining the property which they possess in the said territories, or disposing thereof, and removing the proceeds wherever they please, without their being subjected, on this account, to any contribution, tax, or charge whatever.
    Those who shall prefer to remain in the said territories may either retain the title and rights of Mexican citizens, or acquire those of citizens of the United States. But they shall be under the obligation to make their election within one year from the date of the exchange of ratifications of this treaty; and those who shall remain in the said territories after the expiration of that year, without having declared their intention to retain the character of Mexicans, shall be considered to have elected to become citizens of the United States.

    In the said territories, property of every kind, now belonging to Mexicans not established there, shall be inviolably respected. The present owners, the heirs of these, and all Mexicans who may hereafter acquire said property by contract, shall enjoy with respect to it guarantees equally ample as if the same belonged to citizens of the United States.

    ARTICLE IX

    The Mexicans who, in the territories aforesaid, shall not preserve the character of citizens of the Mexican Republic, conformably with what is stipulated in the preceding article, shall be incorporated into the Union of the United States. and be admitted at the proper time (to be judged of by the Congress of the United States) to the enjoyment of all the rights of citizens of the United States, according to the principles of the Constitution; and in the mean time, shall be maintained and protected in the free enjoyment of their liberty and property, and secured in the free exercise of their religion without; restriction.

  10. avatar
    Jim June 11, 2015 at 1:35 pm #

    Doesn’t sound like they’re naturalized…

    “But they shall be under the obligation to make their election within one year from the date of the exchange of ratifications of this treaty; and those who shall remain in the said territories after the expiration of that year, without having declared their intention to retain the character of Mexicans, shall be considered to have elected to become citizens of the United States.”

  11. avatar
    Joey June 11, 2015 at 1:46 pm #

    Jim:
    Doesn’t sound like they’re naturalized…

    “But they shall be under the obligation to make their election within one year from the date of the exchange of ratifications of this treaty; and those who shall remain in the said territories after the expiration of that year, without having declared their intention to retain the character of Mexicans, shall be considered to have elected to become citizens of the United States.”

    Can you say “citizenship never never land,” boys and girls? One thing for certain, their offspring were natural born citizens.
    Birthers will argue that since the Constitution only grants Congress the right to create “an uniform rule of naturalization” they are naturalized. More objective sources might say that anyone who acquires citizenship after birth is naturalized.
    But those who became citizens by virtue of the 14th Amendment were not all born in the United States, some were born in Africa or the Caribbean Islands.

  12. avatar
    Matt June 11, 2015 at 9:06 pm #

    Keith: However, ‘Common Law’ can be overridden, replaced, or supplemented by actual legislated law. As there is no ‘Common Law’ covering foreign born children of American Citizens, Congress has seen fit to ‘fill the gap’ with actual law and declared that those children, as long as the parents meet certain specified criteria, are indeed citizens at birth (and thus natural born citizens). Remember, common law is ALWAYS trumped by actual legislation.

    Right you are, but that means that the determination of who is or can be a natural-born citizen can change at the whim of Congress. I doubt the Framers intended that, despite the fact that such a statute was enacted in 1790.

    Most of us here on this blog agree that there are two and only two classes of citizens: natural-born and naturalized. But what makes up these classes? There are two plausible arguments:

    The one held by most anti-birthers and legal experts is that if you are a citizen, and you did not require naturalization some time after you were born, you are a NBC.

    The other argument is that if you are a citizen, and it required legislation for you to be one (even if that legislation was applied to you at the moment of your birth), you were naturalized and thus cannot be natural-born (only two classes of citizen, right?)
    I believe this will be the argument briefed by Cruz’s challenger if that case ever makes it to SCOTUS.

  13. avatar
    Matt June 11, 2015 at 9:18 pm #

    Lupin:
    My understanding is that the Louisiana purchase Treaty made the formerly French citizens of Louisiana natural-born instead of merely naturalized because it unambiguously states that they will have all the same rights, privileges etc. than US citizens.

    This is an interesting point. I wonder what would happen if something like that were enacted today. Suppose Congress passed a law this week that said anyone born in Canada on or after Dec. 1, 1970 (Ted was born on the Dec. 22) is declared a natural-born citizen of the United States, with the same rights, privileges, and so forth.

    Would that answer Cruz’s eligibility question once and for all? Or, could that statute itself be challenged as unconstitutional?

  14. avatar
    Keith June 12, 2015 at 2:57 am #

    Matt: Right you are, but that means that the determination of who is or can be a natural-born citizen can change at the whim of Congress. I doubt the Framers intended that, despite the fact that such a statute was enacted in 1790.

    I agree. That’s why when Scott v Sandford stood the common law on its head, a Congressional Act just wasn’t good enough (it could be reversed again by a future Congress) and a Constitutional Amendment was required to restore historical understanding of the common law.

  15. avatar
    john June 13, 2015 at 5:05 am #

    Matt: Right you are, but that means that the determination of who is or can be a natural-born citizen can change at the whim of Congress.I doubt the Framers intended that, despite the fact that such a statute was enacted in 1790.

    Most of us here on this blog agree that there are two and only two classes of citizens: natural-born and naturalized.But what makes up these classes?There are two plausible arguments:

    The one held by most anti-birthers and legal experts is that if you are a citizen, and you did not require naturalization some time after you were born, you are a NBC.

    The other argument is that if you are a citizen, and it required legislation for you to be one (even if that legislation was applied to you at the moment of your birth), you were naturalized and thus cannot be natural-born (only two classes of citizen, right?)
    I believe this will be the argument briefed by Cruz’s challenger if that case ever makes it to SCOTUS.

    Yes, apparently Common Law regarding Natural Born Subject has been trumpted by Federal Law regarding that subject. According to 8 U.S. Code Chapter 12, Subchapter III – NATIONALITY AND NATURALIZATION – Part I—Nationality at Birth and Collective Naturalization (§§ 1401–1409),
    “The following shall be nationals and citizens of the United States at birth”
    Naturalization at Birth.

    Citizenship at birth is Nationalization given at Birth. Thus, Natural Born Citizen is different in the fact that it is a citizen that requires no Federal Law that is one born to US Citizens Parents on US Soil.

  16. avatar
    Dr. Conspiracy June 13, 2015 at 7:11 am #

    I cannot think of any authority who has ever said such a thing. How are persons born in California eligible to be President? California is state by federal legislation.

    john: Thus, Natural Born Citizen is different in the fact that it is a citizen that requires no Federal Law

  17. avatar
    john June 13, 2015 at 9:34 am #

    Dr. Conspiracy:
    I cannot think of any authority who has ever said such a thing. How are persons born in California eligible to be President? California is state by federal legislation.

    If they have been born to Citizen parents then they are a Natural Born Citizen. But a person born of Aliens in CAL, is a Citizen at Birth (Under Federal Law, they have been naturalized at birth) and is not a Natural Born Citizen. Congress gives the authority to make “Uniform rules of Naturalization” therefore anyone classified under as a Citizen under Federal Law can only be Naturalized either at birth or later. Congress can dictate certain rules for parents when the person is board abroad because Jus Soil doesn’t apply. However, when the person has been born on US Soil, the parents don’t apply as a rule in determining whether a person is a Citizen at Birth because of Jus Soil. So yes, there are only 2 types of Citizens, Natural Born and Naturalized (Which includes those Naturalized at Birth)

  18. avatar
    john June 13, 2015 at 9:56 am #

    john: If they have been born to Citizen parents then they are a Natural Born Citizen.But a person born of Aliens in CAL, is a Citizen at Birth (Under Federal Law, they have been naturalized at birth) and is not a Natural Born Citizen.Congress gives the authority to make “Uniform rules of Naturalization” therefore anyone classified under as a Citizen under Federal Law can only be Naturalized either at birth or later.Congress can dictate certain rules for parents when the person is board abroad because Jus Soil doesn’t apply.However, when the person has been born on US Soil, the parents don’t apply as a rule in determining whether a person is a Citizen at Birth because of Jus Soil.So yes, there are only 2 types of Citizens, Natural Born and Naturalized (Which includes those Naturalized at Birth)

    So in reference to Thomas’s comment, Children born abroad to US Citizens are Natural Born Citizens who have been classified under the rules of Congress (Federal Law) to be Citizens at Birth who don’t have go through a Naturalization Process (Because it is done instantly at Birth) provided the meet the exceptions cited under the law. If the the exceptions the law are not satisfied, you then have a situation where a Natural Born Citizen is not a Citizen at Birth and they must go through some sort of Naturalization Process to become a Citizen of the United States.

  19. avatar
    Arthur B. June 13, 2015 at 10:52 am #

    john: If the the exceptions the law are not satisfied, you then have a situation where a Natural Born Citizen is not a Citizen at Birth and they must go through some sort of Naturalization Process to become a Citizen of the United States.

    John, this is purest fantasy. Can you provide a historical example of someone who was a Natural Born Citizen but underwent naturalization in order to become a citizen of the United States?

  20. avatar
    john June 13, 2015 at 12:17 pm #

    Arthur B.: John, this is purest fantasy. Can you provide a historical example of someone who was a Natural Born Citizen but underwent naturalization in order to become a citizen of the United States?

    It would depend. You would have to find a case where someone was born abroad to 2 US Citizens but they didn’t satisfy residency requirements. How would this person be classified. Would they be an NBC, would they be a Citizen at Birth or wouldn’t be citizen at all.

  21. avatar
    Rickey June 13, 2015 at 12:23 pm #

    john: If they have been born to Citizen parents then they are a Natural Born Citizen.But a person born of Aliens in CAL, is a Citizen at Birth (Under Federal Law, they have been naturalized at birth) and is not a Natural Born Citizen.

    The District Court in Wong Kim Ark ruled that WKA was a natural born citizen. The government argued that if WKA was a citizen, it meant that he was eligible to be president.

    The Supreme Court affirmed the District Court decision, so WKA was indeed a natural born citizen and was eligible to be president.

    Which means that you are wrong. Again.

  22. avatar
    john June 13, 2015 at 12:32 pm #

    Rickey: The District Court in Wong Kim Ark ruled that WKA was a natural born citizen. The government argued that if WKA was a citizen, it meant that he was eligible to be president.

    The Supreme Court affirmed the District Court decision, so WKA was indeed a natural born citizen and was eligible to be president.

    Which means that you are wrong. Again.

    WKA was not a Natural Born Citizen according to the court.(lawyers may beg to differ but the court has the say.) WKA was a Citizen at Birth and I suppose in dicta thought that was sufficient for WKA to run as POTUS but the Constitution says only NBCs can run as POTUS which WKA wasn’t was.

  23. avatar
    Arthur B. June 13, 2015 at 2:18 pm #

    john:

    Arthur B.: Can you provide a historical example of someone who was a Natural Born Citizen but underwent naturalization in order to become a citizen of the United States?

    john: It would depend.

    Come on, john, get real. I asked you to provide a historical example and you said it would depend. It’s safe to say, isn’t it, that if you had an example you would have told us about it?

    There is no example because what you are saying has no basis in reality. Stamping your foot and saying that you’re right and everyone else is wrong even though you have no facts to support your position just makes you look foolish.

    Again.

  24. avatar
    Joey June 13, 2015 at 2:30 pm #

    john: WKA was not a Natural Born Citizen according to the court.(lawyers may beg to differ but the court has the say.)WKA was a Citizen at Birth and I suppose in dicta thought that was sufficient for WKA to run as POTUS but the Constitution says only NBCs can run as POTUS which WKA wasn’t was.

    There is no difference between a Citizen of the United States At Birth and a Natural Born Citizen. The terms are synonymous in the eyes of the law.
    Allen v Obama, Arizona Superior Court Judge Richard E. Gordon: “Arizona courts are bound by United States Supreme Court precedent in construing the United States Constitution, and this precedent fully supports that President Obama is a natural born citizen under the Constitution and thus qualified to hold the office of President. Contrary to Plaintiff’s assertion, Minor v. Happersett, 88 U.S. 162 (1874), does not hold otherwise.”–Pima County Superior Court, Tuscon, Arizona, March 7, 2012
    http://www.scribd.com/doc/84531299/AZ-2012-03-07-Allen-v-Obama-C20121317-ORDER-Dismissing-Complaint

    Tisdale v. Obama, U.S. District Court Judge John A. Gibney, Jr.: “It is well settled that those born within the United States are natural born citizens.”– Tisdale v. Obama, U.S. District Court of the Eastern District of Virginia, January 23, 2012.

  25. avatar
    J.D. Sue June 13, 2015 at 3:10 pm #

    john: WKA was not a Natural Born Citizen according to the court.(lawyers may beg to differ but the court has the say.)

    —-
    Wrong. Instead, lawyers differ with YOUR self-serving and confused interpretation of what the court said. Fact is, real lawyers understand and accept what the court had to say. It is you, a non-lawyer, who apparently does not know how to read a court opinion, who does not know how to follow lawyerly discussions about it, and who begs to differ with or misrepresent all legal authorities.

    Ignorance may be blissful, but it is still ignorance.

  26. avatar
    Rickey June 13, 2015 at 5:44 pm #

    john: WKA was not a Natural Born Citizen according to the court.(lawyers may beg to differ but the court has the say.)WKA was a Citizen at Birth and I suppose in dicta thought that was sufficient for WKA to run as POTUS but the Constitution says only NBCs can run as POTUS which WKA wasn’t was.

    You are doubling down on your ignorance, I see.

    The interpretation of the Constitution of the United States is necessarily influenced by the fact that its provisions are framed in the language of the English common law, and are to be read in the light of its history…The fundamental principle of the common law with regard to English nationality was birth within the allegiance, also called “ligealty,” “obedience,” “faith,” or “power” of the King. The principle embraced all persons born within the King’s allegiance and subject to his protection…Children, born in England, of such aliens were therefore natural-born subjects.

    The Fourteenth Amendment of the Constitution, in the declaration that “all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside,”
    contemplates two sources of citizenship, and two only: birth and naturalization. Citizenship by naturalization can only be acquired by naturalization under the authority and in the forms of law. But citizenship by birth is established by the mere fact of birth under the circumstances defined in the Constitution. Every person born in the United States, and subject to the jurisdiction thereof, becomes at once a citizen of the United States, and needs no naturalization.
    – United States v. Wong Kim Ark

    Wong Kim Ark was born in the United States while subject to the jurisdiction of the United States. He needed no naturalization. He was a natural born citizen.

  27. avatar
    Dr. Kenneth Noisewater June 14, 2015 at 12:23 am #

    john: WKA was not a Natural Born Citizen according to the court.(lawyers may beg to differ but the court has the say.) WKA was a Citizen at Birth and I suppose in dicta thought that was sufficient for WKA to run as POTUS but the Constitution says only NBCs can run as POTUS which WKA wasn’t was.

    Sorry john I can’t take what you claim seriously after you botched the meaning of Jus Soli so badly.

    The words natural born means having a certain characteristic at birth.

    Thus a natural born citizen is one who is born a citizen.

  28. avatar
    Keith June 14, 2015 at 3:23 am #

    john: WKA was not a Natural Born Citizen according to the court.(lawyers may beg to differ but the court has the say.) WKA was a Citizen at Birth and I suppose in dicta thought that was sufficient for WKA to run as POTUS but the Constitution says only NBCs can run as POTUS which WKA wasn’t was.

    According to Minor v Happersett, there are only TWO kinds of Apples: Red Apples and Yellow Apples.

    The facts of the situation demonstrate that WKA could not possibly be a Yellow Apple because he did not come from a tree that can produce Yellow Apples.

    Now the courst did not say that WKA was a Red Apple. According to the court, WKA was ‘just’ an Apple.

    Here is the summary of the assertions:

    Assertion 1: There are only Red Apples and Yellow Apples.
    Assertion 2: WKA could not possibly be a Yellow Apple.
    Assertion 3: WKA is in fact an Apple

    And here is the question you need to answer:

    Given the above 3 assertions what color Apple is WKA?