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Does any of the US states or aforementioned entities maintain a legal status comparable to that of citizenship/nationality, specific to people who are for example born in that state or have acquired that citizenship by rules fixed by the state?

Something like that would include, for example, specific protection abroad (= out of the state, incl in another US state) by the state's government, additional rights within the state as opposed to those only having the federal citizenship, or the state for example trying to impede or decide how is conducted a federal suit within its boundaries on people having their citizenship...

I think this is somewhat the case for Indian reservations, which are more independant with the federal government than the states are.

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    Have you read the 14th amendment to the US constitution?
    – phoog
    Aug 1, 2023 at 7:39
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    @phoog yes, but I'm not sure of the extent of the "privilege and immunities" constraint. For example, Texas banned abortions yet they are legal in other states, so it is depriving citizens (those it can get its hands on) of a privilege granted in another state. Same with electoral procedures, which were a key point of Bush v Gore. I'm not sure how those qualifies, and where the boundary for state action is. The question also applies to Territories, and I think there's at least something weird with the Samoa. Aug 1, 2023 at 11:27
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    I was more asking about the 14th amendment's mention of state citizenship, which (by this provision) accrues to US citizens in the state in which they reside. Is this what you're asking about? From your comments it seems that you may be asking whether there are any practical consequences to state citizenship in the US (or to analogous arrangements elsewhere).
    – phoog
    Aug 1, 2023 at 12:38
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    Any special reason to focus on these four countries or would an answer about Switzerland be relevant? Swiss law has detailed rules about communal and cantonal (= provincial) citizenship and how they are inherited. For naturalization, you first get a federal “naturalization licence” and then have one year to acquire cantonal citizenship according to the rules of the relevant canton. You only become Swiss through cantonal citizenship. Until very recently, a citizen's place of origin was responsible to provide support if they became destitute.
    – Relaxed
    Aug 1, 2023 at 20:06
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    In Canada I know all laws on citizenship are statutory rather than constitutional, meaning they can be amended by an act of Parliament without any provincial ratifications. Aug 2, 2023 at 1:12

9 Answers 9

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German Länder do not provide any citizenship-like benefits.

You are a resident and that determines your administrative duties like where you register your car, which public school you can go to, where and which taxes you have to pay etc.

Some places in Germany differentiate their services between "locals" and "others", for example beach access in tourist cities is sometimes locked behind a fee to non-locals (aka tourists). But that never depends on federal state, but on way smaller units. Residents of one beach town might be "tourists" 20km down the road at the next city's beach. It is more of a "the people whose taxes allow us to maintain this, go for free" approach.

Outside of badly translated internet forms originally made for the US, I have never been asked for my Bundesland. The Bundesland is not printed on our national ID cards. Although anybody with a little knowledge of geography (or access to Google) can find out your Bundesland by just looking up the actual address that is printed on the ID card, the information of which Bundesland this is is really not important outside of government bureaucracy.

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    If this was a germany-only question, I would validate the answer. Upvoted. Aug 1, 2023 at 11:13
  • I have long thought the phrase "federal state" is a lousy way to translate the German word "Bundesland," but a person who knows far more about that I do tells me that all proposals for ways to translate it are lously. Aug 2, 2023 at 0:53
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    This is not entirely true. States can have subsidies that are only eligible for their own residents. For example, Hessen provides a subsidy for cargo bikes; someone living in a neighbouring state cannot benefit, even if they buy the bike in Hessen. It's not citizenship, but residency does come with benefits.
    – gerrit
    Aug 2, 2023 at 8:06
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    @EikePierstorff According the the most recent guidelines, it is based on a combination of factors including income, social criteria and the duration of one's residence or employment in a given municipality. Note that, much like the beaches in the answer, this is a subsidy based on the Gemeinde and not on the Land. When it comes to buying property in Erding, a person from Augsburg is treated like a person from Berlin (assuming Erding makes use of the Einheimischenmodell at all)
    – xyldke
    Aug 2, 2023 at 9:45
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    Bavaria in theory has its own citizenship (article 6 of the constitution), but the corresponding detail law was never passed. Article 8 says that all German citizens with residence in Bavaria have the same rights and obligations as bavarian citizens. Aug 2, 2023 at 23:32
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US states establish residency, used for access to services (like public libraries), things like in-state public university tuition, and paying taxes. Generally this is less of a service to the residents than a revenue source by the state (new car registration, for example).

Residency is established solely by where you physically live (there are weird exceptions for people living RV-life type existences, but many will find this fringe existence difficult). There is no application for change of residency, no restrictions exist on what state you can live in. If you move there, you will be a resident there.

US states don't do anything for a resident who is in another state. They have no effect whatsoever on federal courts inside their borders except for passing state laws that federal courts may use.

Quasi-citizenship does exist for states. The 14th Amendment states that "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." It specifies US citizenship and thus invalidated previous theories that US citizenship required some type of state citizenship. I can find exactly zero methods to acquire citizenship in a state, certainly not in the last two I've lived in, other than residing in one.

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    @Gouvernathor federal courts use state law when it governs relevant questions, for example family relations, property ownership, contracts, that sort of thing. Tiger Guy under the federal constitution's 14th amendment US citizens are citizens of their state of residence. Does this have any bearing on your answer?
    – phoog
    Aug 1, 2023 at 12:42
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    This is more incorrect than it is correct, although the issue is subtle. U.S. state citizenship absolutely does exist and is expressly recognized in the U.S. Constitution.
    – ohwilleke
    Aug 1, 2023 at 13:27
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    US state citizenship exists but has exactly no effect on people's lives.
    – Tiger Guy
    Aug 1, 2023 at 14:37
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    It may also affect your eligibility to vote and the amount of state taxes you pay. It's entirely possible to own property in two or more states and qualify for residency in both but you can only vote in the state you are a citizen of.
    – hszmv
    Aug 1, 2023 at 19:12
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    Again, I suggest that residency is the primary thing here, not "citizenship," which is solely determined by residency. It's not like you get a document that shows state citizenship.
    – Tiger Guy
    Aug 2, 2023 at 14:10
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Under the 14th Amendment to the United States Constitution, a U.S. citizen is also a citizen of the state in which the citizen resides, a term usually interpreted to match the common law concept of domicile.

There are two privileges and immunities clauses in the U.S. Constitution. One protects the privileges and immunities that U.S. citizens hold in every state which generally speaking has been narrowly interpreted to protect only rights that flow from the federal government. The other entitles a citizen of one U.S. state to the privileges and immunities of citizens of another state where the person may be present, facially seeming to prohibit discrimination based upon state citizenship.

A state may insist that you are a citizen of a U.S. state to vote in that state's elections. It may also prefer state citizens in matters of hunting and fishing licenses and tuition at public educational institutions. But, a state may not limit occupational licenses in the state to state citizens.

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  • "Section 1. 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...."
    – Henry
    Aug 1, 2023 at 14:51
  • The boundary (in your third paragraph) still seems vague to me, is it that a right can be made less easily accessible based upon state citizenship, as long as the right is not cut out completely ? Aug 2, 2023 at 0:56
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    @Gouvernathor This is because the law itself is not clear in that regard and has been derided as inconsistent and results driven.
    – ohwilleke
    Aug 2, 2023 at 16:03
  • All right, fair enough. Aug 3, 2023 at 7:25
  • I was born overseas to US parents, and thus am a citizen by statute rather than by the 14th Amendment. So I wonder whether there may be relic state laws, ignored since 1868 but never repealed, that by their letter would apply differently to me. Aug 27, 2023 at 11:01
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Switzerland is another example of different countries doing things differently. You become a citizen of Switzerland by becoming a citizen of a municipality. Different cantons have different laws regulating the granting of citizenship by municipalities.

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    @Gouvernathor : I'm not sure how much discretion municipalities currently have. They used to have much broader discretion in denying citizenship than they do now. A person born in Hungary once told me that the first time he applied for Swiss citizenship, it was denied because the mayor of the village thought he looked like a hippie. Aug 2, 2023 at 1:02
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    @Gouvernathor No, the federal government has its own requirements and issues “naturalization licenses”. But it cannot make someone a citizen on its own. And people can also switch cantonal / municipal citizenship.
    – Relaxed
    Aug 2, 2023 at 6:27
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    @MichaelHardy Until 20 or so years ago, some municipalities would hold a referendum where all current citizens vote on individual citizenship decisions and it was hard not to suspect some decision were based only on prejudice (e.g. all Italians would be approved, all people from the former Yougoslavia would be denied). The top federal court banned such votes on the grounds that the decision was insufficiently justified and applicants were entitled to a justification.
    – Relaxed
    Aug 2, 2023 at 6:31
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    @Relaxed Italians would be approved? How times have changed! My uncle called them Gotthard-Chinesen.
    – gerrit
    Aug 2, 2023 at 8:01
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    @Gouvernathor Federal laws are supreme in Switzerland (within the constitutional limits) so the canton and commune must follow the minimum requirements set by the federal government (as the constitution assigns the power to the Confederation).
    – xngtng
    Aug 2, 2023 at 9:19
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Citizenship is a national concept

Australian states, territories, and local governments can and do have the concept of residency which may or may not be tied with citizenship.

For example, if you are a citizen, your place of residence as recorded on the Australian Electoral Roll determines which state/territory and local government elections you vote in.

Where you employ people determines in which state/territory you are liable for payroll tax and worker’s compensation insurance. Where you live determines which state/territory you must get your driver’s license etc.

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  • So, the federal roll determines in which local elections you can vote ? Tht means if a state decides to change the boundary between two municipalities, it must notify the federal govt so that the fed roll gets updated ? For states and territories it's understandable that the federales need to be notified I guess, assuming it's more or less like US/Canada ^^ Aug 1, 2023 at 11:30
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    @Gouvernathor There is a state electoral roll and a Federal electoral roll but the state and Federal Electoral Commissions share data so when you enrol nationally you enrol at the state level too. They are also the bodies that determine electoral boundaries so …
    – Dale M
    Aug 1, 2023 at 11:34
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    @Gouvernathor just to add a bit of context, voting in Australia is compulsory, which is different from places such as the US. And if you don't vote, you can be eligible for fines. So these electoral rolls are regularly scrutinized and updated. I've only avoided being fined for not voting by showing that I was out of the country for extended periods of time when elections have been called.
    – Peter M
    Aug 1, 2023 at 13:14
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For 2023, the answer by @nvoigt is correct. However, prior to the german re-unification, West Berlin did have special status. While being a Bundesland (county) of West Germany, it was in parts governed by allied laws back from post-WW2 occupation times. The most famous effect being that residents of West Germany were exempt from compulsory military service. This made Berlin universities popular among parts of the young male population who saw studying in Berlin a way to get out of that.

Also, the people of West Berlin did not have the same passport as other western Germans, but were issued a "provisional passport". Here is a rare picture of one in item #5: https://www.t-online.de/region/berlin/news/id_90751288/berlin-vor-der-wende-10-dinge-die-nur-west-berliner-miterlebt-haben.html

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  • Not strictly part of the question, but very interesting. Aug 3, 2023 at 7:23
  • What happened to people born in West Berlin, moving to other states? There are all kinds of advantages and disadvantages depending on residency, but that wasn't the question. Was there an official "West Berlin Citizenship" that you kept after moving?
    – nvoigt
    Aug 5, 2023 at 5:20
  • @nvoigt thanks for the question. I've added a section about passports that was specific to people born in West Berlin. The military service thing was a bit more tricky and I don't remember all the details. I THINK that technically, residency in West Berlin didn't count, but since there was no mandatory military service in West Berlin, you couldn't be taken while residing there. The same way many people today escape mandatory military service in their home countries by staying abroad during the years they could be drafted into it.
    – Tom
    Aug 5, 2023 at 7:09
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    @nvoigt people moving out of western berlion were issued new documents - altering the western berlin documents to reflect western Germany residency actually voided them!
    – Trish
    Aug 5, 2023 at 8:59
  • @nvoigt no, since 1934 was only one citizenship. Allied law restricted the way ID or passports were issued and didn't allow the draft. 1934 the state citizenships were abolished. Dec 11, 2023 at 22:14
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Indigenous nations have their own citizenship/membership requirements (the terminology and conception can vary from people to people).

For an example within , see the The Constitution of the Nisga’a Nation, s. 8:

  1. Citizenship

(1) Every Nisga’a participant who is a Canadian citizen or permanent resident of Canada is entitled to be a Nisga’a citizen

(2) A person who is not a Nisga’a participant and who is a Canadian citizen or permanent resident of Canada may become a Nisga’a citizen if permitted by, and in accordance with, Nisga’a law.

The consequences of Nisga'a citizenship are outlined in the constitution.

The membership in Indian Act "bands" is recorded on a "Band List" that may be controlled by the band:

A band may assume control of its own membership if it establishes membership rules for itself in writing in accordance with this section and if, after the band has given appropriate notice of its intention to assume control of its own membership, a majority of the electors of the band gives its consent to the band’s control of its own membership.

The consequences of band membership are presented in this Q&A: What are the consequences of "band" membership under Canada's Indian Act?

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"Naturalization and Aliens" falls under the exclusive jurisdiction of the federal government in Canada as one of several classes of subjects enumerated in section 91 of the Constitution Act, 1867 (originally enacted as the British North America Act 1867 by the Parliament of the United Kingdom). Although Canadian citizenship as a separate legal status was not established until 1947, the Parliament of Canada previously regulated the process of naturalizing aliens into British subjects in Canada, subject to the limits imposed by the British Empire.

However, the law does not prevent provinces from granting certain benefits to certain classes of citizens or residents in general. Notably, it is a constitutional right to move to and take up residece in any province and to pursue the gaining of a livelihood in any province, but other areas are not regulated.

For example, everyone who was born in Quebec, or who was selected by Quebec as immigrants, may benefit from resident tuition rates, even if they move away from Quebec immediately after their birth or landing. Resident tuition rates also exist in some other provinces (Ontario and Newfoundland and Labrador), although the place of birth has no effect on the qualification there. Quebec is in many aspects a special case, as there is a strong sovereigntist movement and it runs its own immigration system (all provinces have the shared power over immigration, but Quebec is the only one exercising that power). So there was a reason to make some nationality-like thing. Nonetheless, the resident tuitition rates qualification is a really limited application and the status could not really be called as nationality or citizenship.

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additional rights within the state as opposed to those only having the federal citizenship

Hunting.

There are many such rules around hunting. In Ontario, , for example, All non-residents wishing to hunt black bear must contract the services of an operator licensed to provide bear hunting services. Only Ontario residents are allowed to go hunting black bear on their own in Ontario. There is a similar rule for moose, with the exception that an Ontario resident who holds a valid moose tag can bring along a non-resident on the hunt if they are an immediate relative.

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