The Revolution in Citizenship

Few of President Trump’s second-term actions have proved as controversial as his Day One executive order that seeks to end birthright citizenship. Like much else that he has done and said, the order, though still on hold legally, reopens political questions long thought settled. But debates about citizenship aren’t new. What does it mean to be a citizen? In what sense is citizenship a right? These are not merely academic questions; many contemporary political disputes ultimately hinge on the value of citizenship.

In a wealthy democracy, citizenship holds particular significance for two groups: aspiring migrants and the native middle class. It holds far less value for transnational elites, who often advocate its dilution.

Much of the confusion surrounding the term “citizenship” stems from a failure to grasp its complex history. Because citizenship is both ancient and modern, any discussion of its meaning today must begin with understanding how the concept has developed over time.

When English historian Simon Schama titled his monumental history of the French Revolution Citizens, he acknowledged that a profound shift in political identity had occurred in 1789. The old bonds of local communities had been superseded by new, higher loyalties. No longer simply peasants, merchants, artisans, priests, or nobles, the French were now, first and foremost, citizens. Until then, the idea that all residents of France might share some sort of common status would have been barely conceivable. (This cognitive dissonance is played for comic effect in Monty Python and the Holy Grail, when an increasingly enraged King Arthur tries to explain to bemused peasants that they are, in fact, Britons.)

The French Revolution thus implied the creation of a new kind of man—though one with ancient roots. Jean-Jacques Rousseau, perhaps the most influential literary figure behind the revolution, looked to the Greeks and Romans as citizens par excellence and lamented their absence in his own time. Indeed, both ancient societies and early modern France serve as useful reference points for understanding what citizenship means. The word itself comes to us from Latin via French: citoyen derives from cīvīs, the Latin term for a member of the political community, a rendering, in turn, of the Greek polites.

An ancient citizen was distinct from a mere inhabitant or subject. He enjoyed privileged membership in the polity and all the duties that such membership entailed. As historian Claude Nicolet put it in his great study of the subject, “The citizen was a voter, but before that he was a soldier and, incidentally, a taxpayer.” Tellingly, this tripartite definition emphasizes not rights but obligations: participation in the governance, defense, and economic support of the city. And while ancient citizenship certainly carried material benefits, its significance was not reducible to material terms. Citizenship was valued as an end in itself. The Roman plebeian was as fiercely protective of his status as any member of the equestrian or senatorial classes, even though he derived far fewer material rewards from it.

Ancient citizenship was highly exclusive. In a world of slaves, foreigners, women, and other outsiders, the franchise was restricted to select males. Alexis de Tocqueville declared that all Greek or Roman citizens, whether rich or poor, belonged to a kind of de facto aristocracy. A non-Athenian could never become an Athenian, even if he shouldered the obligations of citizenship, as the example of the metics, who remained foreign residents despite their contributions to the Peloponnesian War, showed. Descent from past citizens remained a nonnegotiable requirement.

It wasn’t until the Social War, 91–88 BC, that Rome extended the citizenship franchise to its former allies across the Italian peninsula. As the Roman Empire expanded throughout the Mediterranean, citizenship gradually lost much of its exclusivity.

Machiavelli praised the Romans for their openness in extending citizenship—even to foreigners—arguing that, unlike the insular Greeks, this inclusiveness enabled them to build and sustain a vast empire.

Even then, citizenship continued to imply certain rights and protections. Hence the significance of the phrase cīvis Rōmānus sum (“I am a Roman citizen”), famously deployed by Paul the Apostle to avoid corporal punishment at the hands of Roman centurions.

Modern citizenship presents different characteristics. After the fall of the Roman Empire, the ancient model of citizenship gave way to entirely new forms of social and political organization, shaped by feudal and ecclesiastical authority across the continent. Then, after eighteenth- and nineteenth-century revolutions shattered this ancien régime, it became common for historians to view the replacement of outdated hierarchies with modern citizenship as a revival of an ancient type. But any resemblance between ancient and modern citizenship should not be overstated. It’s more accurate to see modern citizenship as new wine in an old bottle.

Whereas ancient citizenship was the prerogative of a privileged few, modern citizenship is regarded as a universal right to which everyone is entitled. It is the means by which we look to ensure our individual rights and protections; consequently, it is instrumental in a way that its ancient counterpart was not. True, one can see attempts to reproduce the classical ethos of citizenship in, say, Adam Smith’s exhortation that “he is certainly not a good citizen who does not wish to promote, by every means in his power, the welfare of the whole society of his fellow-citizens.” Yet the prevailing modern sensibility emphasizes benefits over obligations and severs the link between citizenship and military service. Citizenship is primarily understood as a status that confers entitlements.

Modern citizenship also has a decidedly administrative quality. In place of sacred duties, buttressed by honor and shame, we have passports. As the political anthropologist James Scott has observed, “If you wish to have any standing in law, you must have a document that officials accept as evidence of citizenship, be that document a birth certificate, passport, or identity card.” Yet this formalism introduces greater flexibility, making citizenship more fluid. Whereas classical citizenship was a birthright, modern citizenship—through passports—can be assigned, revoked, or replaced.

Nowhere are the instrumental and formal features of modern citizenship more apparent than in the novel possibility of changing one’s citizenship or acquiring multiple citizenships at once. Historically, citizenship in a political community was not a fungible commodity; for the most part, one either possessed it or did not. Moreover, it was tied exclusively to a single polity. Cicero stated: “According to our civil law, no one can be a citizen of two cities at the same time; a man cannot be a citizen of this city, who has dedicated himself to another city.”

Empires and other dominions may have allowed greater freedom of movement, but that mobility often came without the benefits or obligations of citizenship. After his exile from Athens, the wily statesman and general Themistocles secured a high-ranking administrative post with his former enemy, the Achaemenid Empire. But his case was the exception that proved the rule: despite his new position, he did not exchange his Athenian citizenship for Persian. In ancient times, true citizenship remained a fixed and exclusive status.

What explains this conceptual shift? A key difference today is, of course, mass migration. Have the estimated 280 million migrants worldwide—nearly 4 percent of the global population—denatured citizenship itself?

That seems like an incomplete explanation. Migration is as old as we are, far older than anything resembling modern civilization. Historically, empires across the world have encompassed diverse peoples and languages, often with frontiers rather than fixed borders, allowing for population exchanges. But the scale and context of the current flux are truly distinctive: people are moving not between permeable empires but between the settled, defined political communities once associated with ancient city-states.

Unlike in the ancient world, people today are encouraged to assume new political—not just physical—circumstances. The United Nations Universal Declaration of Human Rights includes both the right to leave any country, including one’s own, and the right to change one’s nationality. If citizenship itself is primarily conceived of as a right, the argument goes, then why should that right be restricted? If citizenship is held in a given country, then why not another? If it is held in one country, then why not many?

Of course, we do not live in a borderless world. All countries impose certain restrictions on the entry of noncitizens, and none offers unconditional citizenship to foreigners. Some even limit the right to exit. In Iran and Tunisia, renouncing citizenship is subject to government approval; in the United States, those who give up their citizenship must pay an exit tax; and in countries such as Morocco and Argentina, citizenship cannot be renounced at all.

Still, these exceptions do not represent a comprehensive alternative to the generally flexible norms of modern citizenship. Argentines are not otherwise living as Spartans in the modern world. Typically, those who manage to emigrate can acquire citizenship in other countries, regardless of constraints imposed by their country of origin.

Not all citizenships are created equal. Citizenship in some countries confers privileges in others: some passports are more valuable than others, allowing frictionless travel around the world. Behavior reveals preferences. Migration flows are net positive for some countries and net negative for others. Millions are willing not only to exchange one citizenship for another but also to bear substantial material costs in the process. To put it bluntly: when millions of Turks immigrate to Germany, they are tacitly assigning greater value to German citizenship than to Turkish.

If citizenship in a high-functioning country is an asset of enormous worth, its value fluctuates with personal wealth. This fact is both fundamental and underappreciated, largely because those with the greatest power and influence often take it for granted. Cosmopolitans may hold multiple passports, own properties in several jurisdictions, maintain foreign residencies, or draw income from multinational corporations or nonprofits. They are the chief beneficiaries of the globalist dispensation that prevails within their class. The influential political scientist Samuel Huntington worried that a certain class of elites might escape from the gravitational pull of nation-states, enabling them to exist within a rarefied stratum of global society.

A significant consequence is that the fortunes of the most privileged citizens no longer rise and fall with those of their homeland, as they once did. A Russian oligarch can hedge his bets by securing British or Israeli citizenship. A Silicon Valley billionaire can relocate to Singapore ahead of a lucrative IPO. Rather than take pride in their superior capacity to contribute to the good of their country—as ancient elites might have bragged about furnishing ships and chariots to their city—modern elites now happily rely on modes of tax avoidance unavailable to the average citizen. This is especially true in developing nations, where the wealthy have long enjoyed a kind of neocolonial lifestyle: access to cheap labor from their poorer compatriots, along with modern conveniences otherwise denied to those same compatriots. Yet as citizenship grows more fluid, elite citizens in the developed world may come to rely on a servant class for many of their daily needs. In a trenchant essay, political analyst Alex Hochuli refers to the extension of this dynamic to developed, formerly egalitarian, countries as the “Brazilianization of the world.”

By contrast, the median citizen has none of these advantages. His assets and wages are locally concentrated, not globally dispersed. He is far more likely to experience the global flows of people and capital as sources of competition rather than opportunity. From housing and education to employment, public safety, and government services, the quality of life for the non-rich depends on the prudent management of a country’s central resources in a way it does not for the wealthy.

Middle-class citizens will therefore place a higher premium on, and seek to defend, citizenship—even if they do not frame their political preferences in exactly those terms. Not wealthy enough to disregard their own representative governments, they have much to lose from national decline. Like shareholders in a publicly traded company, they are rich enough to hold stock but not powerful or organized enough to prevent others from diluting their stake. It is partly for this reason that the past decade has witnessed greater political tumult associated with the middle class, from Brexit to the rise of nationalist parties in Europe to Donald Trump winning not just the electoral but the popular vote in 2024. By contrast, the wealthy have generally been more sanguine about the dilution of citizenship.

Americans are not accustomed to thinking this way. Our understanding of citizenship is intuitively egalitarian. One’s status as a citizen is not thought to be conditional on class, genealogy, or material assets; we now disapprove of past restrictions on voting rights. But citizenship itself involves inherent inequality, depending on where one claims it. Moral philosophers sometimes refer to this as “constitutive luck”: the unearned fortune of being born in a certain time and place, or in a certain way. That people are born into radically different circumstances would not have posed a problem for ancient citizens, who understood citizenship as an exclusive status to be desired and preserved. These days, however, a tension exists between egalitarian assumptions (that everyone is entitled to citizenship) and reality (that it is clearly more desirable to hold it in some countries than others). Equality within a given country may not be coextensive with equality across countries, and the tension between the two drives many of our most contentious political disputes today.

This tension returns us to the present controversy over birthright citizenship, whose legal status awaits resolution. The dominant current in American thought is to think of citizenship as a right or, in Hannah Arendt’s mordant phrase, as “the right to have rights.” That neglects the reality that citizenship is such a valuable asset. Citizenship in an economically developed and politically stable country like the U.S. holds immense value for two key groups. First is the native middle class. Second are the aspiring migrants who possess enough money to migrate but not enough to be comfortable in their home countries. Research suggests that emigration is a parabolic phenomenon: below a certain income threshold, those in developing countries lack the means to migrate; and above it, they lack the incentive.

Insulated from the stresses of migration and demographic change—and, in some cases, positioned to benefit from them—the wealthy citizens of developed countries are often best placed to make the strongest arguments for global egalitarianism. They see little problem with relaxing border controls, expanding immigration, and increasing foreign aid. Meantime, wealthy residents of developing countries may view the emigration of their poorer compatriots as a convenient valve for alleviating political pressures. Yet it is the middle classes of wealthy democracies who are most likely to focus on material conditions within their own countries—their incomes, access to housing, vulnerability to crime, and quality of schools are all directly affected by a potential influx of new citizens.

One way to think about contemporary populism is that it reflects a jealous assertion of citizens’ prerogatives. Political controversies over immigration, protected industries, and elite loyalties flow from a wellspring of disagreement about the importance of citizenship. The fault lines of these disputes increasingly map to structural disparities in wealth. Such conflicts will persist as a central feature of democratic politics as long as ordinary citizens remain susceptible to the stresses of demographic change from economic migrants and political refugees.

It should be remembered, however, that such conflicts among citizens—not just who gets what but who is what—are as old as citizenship itself. In this, at least, modern citizenship continues to resemble its ancient forebear.

Top Photo: Modern elites often hold several passports, reflecting their view of citizenship as a leverageable asset. (Dmytro Chernykov / iStock / Getty Images Plus)