Just imagine how NYT had cried wolf if India had adopted such a rule.
Bloodline? Migration Is Complicating Both.
In a world where people are more mobile than ever, nations are struggling to recalibrate who can be a citizen.
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A woman in black stands in a narrow alley.
Noura Ghazoui, 34, in Genoa, Italy, this month. “I feel Italian, I think in Italian, I dream in Italian,” Ms. Ghazoui said. “But I am not recognized in my country.”Credit...Alessandro Grassani for The New York Times
Emma Bubola
By Emma Bubola
Reporting from Rome
Jan. 29, 2025
For two summers during high school, instead of joining her classmates at the beach, Noura Ghazoui had an internship at the town hall of her hometown, Borghetto Santo Spirito, on the Ligurian coast.
But when she tried to apply for a job there at age 19, she found herself ineligible because, like hundreds of thousands of children born to immigrants in Italy, she could not get Italian citizenship.
“I feel Italian, I think in Italian, I dream in Italian,” Ms. Ghazoui said in Ligurian-accented Italian. “But I am not recognized in my country.”
For generations, European countries have used mostly bloodlines to determine citizenship. The United States was an exception in the West as one of the last countries to grant citizenship unconditionally to virtually anyone born there.
President Trump’s order seeking to end birthright citizenship for the American-born children of undocumented immigrants, which a judge temporarily blocked last week, would bring the United States one step closer to Italy and other European countries.
But rising numbers of migrants in the United States and Europe have set off debates on both sides of the Atlantic over whether the systems for bestowing citizenship need to be updated in some way, either moderated or stiffened.
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A row of plastic sheets pinned to a low wall on a sidewalk.
Makeshift shelters outside an immigration office in Rome. Some wait overnight to secure the chance to apply for a residence permit.Credit...Alessandro Penso for The New York Times
Each approach — known by the Latin terms “jus sanguinis,” or right of blood, and “jus soli,” or right of soil — has its critics, and increasingly, countries have sought to rebalance the two.
Since the 1980s, Britain and Ireland (as well as Australia and New Zealand), which still had unconditional birthright citizenship, have moved in a direction similar to what Mr. Trump has chosen, limiting it.
But others, like Germany, have gone the other way, making it easier for people born to immigrants to gain citizenship. The shift, supporters say, nodded to the changing realities of a country where one in four people now comes from an immigrant background.
“Citizenship is a politically contested issue,” said Maarten Vink, the co-director of the Global Citizenship Observatory. “When it changes it reflects the outcome of a political struggle.”
A Tug of War in Europe
In Europe, bloodline citizenship has helped maintain ties with citizens who leave the country, and their descendants. But most countries in Europe also offer some form of birthright citizenship, though usually with tough restrictions.
In Europe, citizenship has at times been mixed with dangerous concepts of racism and ethnic purity, especially in colonial times and during the Nazi era, when Hitler’s regime stripped Jews of their citizenship before killing them.
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Today support for limiting access to citizenship for immigrants, as well as securing borders, is not found only on the far right. But the arguments have been harnessed by some of the continent’s extreme right-wing forces, who speak of a need to preserve cultural and ethnic identity.
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A long line of people snakes into a street past temporary toilets and metal barriers and down a sidewalk.
Lining up outside the immigration office in Turin, Italy, this month. Most countries in Europe offer some form of birthright citizenship, though usually with tough restrictions.Credit...Alessandro Di Marco/EPA, via Shutterstock
“We must stop migratory flows,” Jordan Bardella, the president of the far-right National Rally in France, said earlier this month. “Many French people, including even some who are of immigrant descent, no longer recognize France and no longer recognize the country they grew up in.”
Mr. Bardella’s party wants to abolish law that allows the children of foreigners born in the country to apply for citizenship at 18, as long as they meet minimal residency requirements.
While citizenship has often been described as a vehicle for belonging, it has also been a powerful means of exclusion, said Dimitry Kochenov, a professor at the Central European University and the author of the book “Citizenship.”
“Citizenship has been used by the state in order to denigrate certain groups,” Mr. Kochenov said.
The Italian Example
In previous centuries, a much poorer Italy was a country from which millions of citizens emigrated abroad, mostly to the Americas, in search of a better life. Generous bloodline citizenship rules helped Italy maintain a link with the diaspora.
Even today churches and town halls around Italy are clogged with requests from Argentines, Brazilians and Americans who have the right to claim citizenship through distant Italian ancestry. (Most recently, President Javier Milei of Argentina obtained Italian citizenship.)
But Italy has in recent decades turned from a land where people emigrate into one that also receives large numbers of immigrants. And while Italy has changed, its citizenship law has not.
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Javier Milei and Giorgia Meloni lean together in discussion.
President Javier Milei of Argentina and Prime Minister Giorgia Meloni of Italy at the Trump inauguration in Washington. Mr. Milei has recently obtained Italian citizenship.Credit...Pool photo by Saul Loeb
Italy does not grant citizenship to the children of immigrants who have legal status in the country. The Italian-born children of immigrants can only apply for citizenship once they turn 18; they have one year to apply and must prove they have lived in the Italy the whole time.
That ruled out Ms. Ghazoui, who spent part of her childhood in Morocco, where her parents are from. Now, 34, an employee at a company providing naval supplies, she has an Italian husband and an Italian child, and applied for citizenship based on protracted residency in the country.
“I am the only one in the house who is not Italian and not recognized,” she said.
While the public health-care system in Italy makes no distinction between citizens and noncitizens, second-generation children of immigrants face numerous hurdles. About 600,000 children born to immigrants study in Italian schools. They have often known no other country than Italy, but with no claim to citizenship, their lives are complicated.
Many cannot travel around Europe on school trips, and have to miss school or renew their residence permits. They also say they are constantly reminded that they are different from their classmates. Many Italian-born adults are in the same situation.
“Precariousness becomes the basis of your life,” said Sonny Olumati, 38, a dancer and choreographer who was born in Rome to Nigerian parents and still does not have Italian citizenship. “You create a sense of non-belonging.”
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Sonny Olumati sits on concrete cylinders in a grassy area.
Sonny Olumati, 38, in Rome this month. “Precariousness becomes the basis of your life,” said Mr. Olumati, who was born in the city to Nigerian parents and still does not have Italian citizenship.Credit...Alessandro Penso for The New York Times
Italy’s leaders support the law as it currently stands. Prime Minister Giorgia Meloni, a hard-line conservative whose Brothers of Italy party has post-Fascist roots, has said that “Italy has a great citizenship law.”
Tying the citizenship of children to that of their parents is convenient, Ms. Meloni argues, in case the immigrants return to their countries. She also said that she had higher priorities than changing the citizenship law.
Despite the government’s position, grass-roots associations proposed a referendum that would reduce the period of uninterrupted residence in Italy needed to become an Italian citizen to five years from 10. The vote is set to happen in the spring.
“This law does no longer represent the real Italy,” said Alba Lala, 27, the secretary of CoNNGI, a group that represents new Italian generations. “It’s completely outdated.”
Birthright in a Modern Age?
Some critics say much the same about unconditional birthright citizenship.
About 20 percent of countries use it, most in North and South America. The United States and Canada inherited the law from Britain, but birthright citizenship also fulfilled an important role in the newly independent countries as a way to constitute a nation.
Like those who favor bloodline citizenship, birthright advocates say it promotes social cohesion, but for a different reason — because no child is left out.
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Ms. Ghazoui and others sit at a table in a room with white walls.
Ms. Ghazoui at a community program in Genoa. She has an Italian husband and an Italian child, and applied for citizenship based on protracted residency.Credit...Alessandro Grassani for The New York Times
In the United States, the 14th Amendment allowed men and women of African descent to become citizens, and millions of children of Irish, German and other European immigrants became citizens as well.
But unconditional birthright citizenship remains an exception.
“In a world of massive migration and irregular migration, unconditional jus soli is an anachronism,” said Christian Joppke, a professor of sociology at the University of Bern.
Still, some argue that the Trump administration is not setting out to modernize a law but instead is trying to redefine the nation itself.
“It rejects the idea of America as a nation of immigrants,” said Hiroshi Motomura, an immigration and citizenship expert at the University of California, Los Angeles, School of Law.
Even under the current rules in the United States, birthright citizenship is not absolute. They exclude, for instance, the children of diplomats born in the United States. And most children of American citizens born abroad maintain an automatic right to American citizenship — in effect bloodline citizenry.
Citizenship by descent “is a really good way to connect with people who live outside the borders of a state,” said Mr. Vink. “But if you want to ensure you are also being inclusive within the borders of a state, you have to also have territorial birthright.”
Otherwise, he said, countries would have millions in their population who are not citizens.
“In a democracy,” he said, “that is not a good principle.”
Christopher F. Schuetze contributed reporting from Berlin, and Aurelien Breeden from Paris.
Emma Bubola is a Times reporter based in Rome. More about Emma Bubola
A version of this article appears in print on Jan. 30, 2025, Section A, Page 9 of the New York edition with the headline: Migration Is Muddling The Rules of Citizenship. Order Reprints | Today’s Paper | Subscribe
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