Section 1 of the Fourteenth Amendment includes references to both citizens and persons:

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. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.

The text provide that only the "privileges or immunities" of citizens are protected. By contrast, persons receive the protections of the due process of law and the equal protection of the laws. And the first sentence instructs that not all pe

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