In Gorsuch’s opinion, full citizenship and privileges should be conferred onto all residents on American territory, which would expand birthright citizenship. For instance, those born in American Samoa do not currently receive this benefit, but under the Gorsuch doctrine, they would, even though they do not pay federal income taxes. Gorsuch feels this is necessary to correct the supposedly racist actions of America’s past. Racism is the only reason America would deny these privileges to the territories, according to Gorsuch. Activists have already filed cases to test this opinion and fundamentally change American law.