When Donald Trump announced that he wanted to remove the right to American citizenship from people born in the country, some immediately saw an echo of Nazi Germany.
However, Germany never granted automatic citizenship to children born in its territory - it was obtained if at least one of the parents was German, but citizenship rights were not tied to race and religion. When Hitler became chancellor in 1933, about 400,000 Jews in the country were German citizens. At that time, foreigners had to have resided in Germany for at least 15 years to obtain citizenship.
However, this changed after the Nazis came to power. The Nuremberg Laws of 1935 stripped German Jews of their citizenship and basic rights. Soon after, the legislation was extended to include blacks and Roma in Germany.
But is this comparable to Donald Trump's intention to strip citizenship from those born in the US whose parents were in the country temporarily or were illegal immigrants?
"This is absolutely ridiculous"
Citizenship by birth was written into the US Constitution in 1868 by Republicans who, after the Civil War, wanted to grant civil rights to formerly enslaved African Americans. The 14th Amendment to the US Constitution, which describes this right, is a symbol of a tolerant multiracial society. This explains why many US states successfully filed lawsuits to block Trump's order to repeal the law.
"We are the only country in the world that allows this, as you know, so this is absolutely ridiculous", Trump said when he signed the presidential order repealing the law. But fact-checking platform "Politifact" explained that this statement is not true: in fact, there are a number of countries in the world, such as Brazil and Argentina, that automatically grant citizenship to those born on their territory. Not least because the former colonies wanted to attract more citizens with their more liberal naturalization laws.
According to the sociological journal "World Population Review", 35 countries in the world automatically grant citizenship to those born there, regardless of the status of their parents. Among the world's 20 largest economies, however, Canada and the United States are the only ones with such legislation.
Is Trump's move authoritarian?
"The stripping of citizenship is, of course, a hallmark of authoritarianism," said Jamie Raskin, a Democratic congressman. He cited the "Reich Citizenship Act", part of the Nuremberg Laws - a step that was soon followed by fascist Italy under Mussolini.
"To this day, authoritarian states strip people of their citizenship to punish them for political activism or dissent," the lawmaker added. Preserving the inviolability of birthright citizenship is something that makes the United States unique, he pointed out. "The privileges of citizenship are shared by all people born in our country, not just those who fall into a particular hereditary classification based on race or origin."
In recent years, Germany has updated its naturalization laws to make it easier for people born in the country to non-German parents to obtain German citizenship. But now Germany's new conservative government wants to tighten immigration rules - with the controversial support of the far-right "Alternative for Germany": Chancellor Friedrich Merz wants to reintroduce restrictions on obtaining citizenship.
Meanwhile, in June, the US Supreme Court ruled that a temporary injunction preventing the administration from removing the right to birthright citizenship was unconstitutional. However, the court has yet to rule on the merits of Trump's attempt to overturn a fundamental principle of the Constitution.
Author: Steward Brown