A foreigner is one who is born out of the territory—that is, the government—of the king.

Explanation

Citizenship and allegiance attach to the place of birth and the sovereignty under which one is born — a person born outside the jurisdiction owes no natural allegiance to it.

Where this applies

• A person born in Canada seeks to vote in a U.S. election without naturalization, and the court holds that one born outside the jurisdiction owes no natural allegiance to it and has no inherent right to participate in its governance.
• An immigrant argues that mere physical presence in the country should confer full citizenship rights, but the court distinguishes between presence and the allegiance that comes from being born under the sovereignty.
• A dual national is asked to clarify her primary allegiance for security clearance purposes, and the analysis turns on under which sovereign she was born, because birth under a sovereignty creates natural allegiance.