[Red Steel]

American citizenship cannot be attained solely through marriage.

That's probably not the case over 100 years ago. As I remember, husbands bestowed citizenship through marriage just like their last names. All world cultures and societies were patriarchal, and to the most extend, still are today.

[trumandogz]

That's probably not the case over 100 years ago.

I am not all that sure that courtroom judges like to hear the word "Probably" when hearing a case.

Pekins v. Elg was in 1939 and not 100 years ago.

[Scanian]

That was the case in the US until 1922.