Congress has conferred birthright nationality, through legislation, to persons born in all inhabited territories except American Samoa and Swains Island, who are granted the status of non-citizen-nationals. A December 12, 2019 ruling by U.S. District Judge Clark Waddoups struck down the special status of American Samoans as non-citizen nationals as unconstitutional, holding that "any State Department policy that provides that the citizenship provisions of the Constitution do not apply to persons born in American Samoa violates the 14th Amendment." Government attorneys had argued that "Such a novel holding would be contrary to the decisions of every court of appeals to have considered the question, inconsistent with over a century of historical practice by all three branches of the United States government, and conflict with the strong objection of the local government of American Samoa." Waddoups stayed his ruling on December 13 pending appellate review, so it did not take immediate effect.