Chin, focused on a law that has been largely overlooked in the debate over Mr. The law conferred citizenship on children of American parents born in the Canal Zone after , and it made John McCain a citizen just before his first birthday. But the law came too late, Professor Chin argued, to make Mr.
McCain a natural-born citizen. But they added that nothing was very likely to follow from it. Spiro, an authority on the law of citizenship at Temple University. McCain has dismissed any suggestion that he does not meet the citizenship test. In April, the Senate approved a nonbinding resolution declaring that Mr. McCain is eligible to be president.
A lawsuit challenging Mr. There are, Professor Chin argued in his analysis, only two ways to become a natural-born citizen. One, specified in the Constitution, is to be born in the United States. A series of earlyth-century decisions known as the Insular Cases, he wrote, ruled that unincorporated territories acquired by the United States were not part of the nation for constitutional purposes.
The Insular Cases did not directly address the Canal Zone. But the zone was generally considered an unincorporated territory before it was returned to Panama in , and some people born in the Canal Zone when it was under American jurisdiction have been deported from the United States or convicted of being here illegally. The second way Mr. McCain could have, and ultimately did, become a citizen was by statute, Professor Chin wrote. In Rogers v.
Bellei in , the Supreme Court said Congress had broad authority to decide whether and when children born to American citizens abroad are citizens. At the time of Mr. The Canal Zone was beyond the limits of the United States but not beyond its jurisdiction, and thus the law did not apply to Mr. View all New York Times newsletters. In , Congress addressed the problem, enacting a law that granted citizenship to people born in the Canal Zone after That made Mr.
McCain a citizen, but not one who was naturally born, Professor Chin said, because the citizenship was conferred after his birth. In his paper and in an interview, Professor Chin, a registered Democrat, said he had no political motive in raising the question.
In March, Laurence H. Tribe, a law professor at Harvard and an adviser to Senator Barack Obama, prepared a memorandum on these questions with Theodore B. Olson, a former solicitor general in the Bush administration. Hawaiian Department of Health spokeswoman Janice Okubo elaborated on state policy for the release of vital records: "If someone from Obama's campaign gave us permission in person and presented some kind of verification that he or she was Obama's designee, we could release the vital record.
In , birth notices for Barack Obama were published in both the Honolulu Advertiser and the Honolulu Star-Bulletin on August 13 and 14, , respectively, listing the home address of Obama's parents as Kalanianaole Highway in Honolulu. Such notices were sent to newspapers routinely by the Hawaii Department of Health.
In an editorial published on July 29, , the Star-Bulletin pointed out that both newspapers' vital-statistics columns are available on microfilm in the main state library. It has been suggested that Obama obtained Indonesian citizenship and thus may have lost U. There was in fact no such ban.
McCain's citizenship called into question
A New York Times article and U. State Department travel advisories from make it clear that travel to Pakistan by U. An April Fools' Day hoax email circulated on the Internet starting in It falsely claimed that Obama applied to Occidental College under the name "Barry Soetoro" claiming to be "a foreign student from Indonesia" in order to obtain a Fulbright scholarship which does not exist for undergraduate students from Indonesia. Another theory of Obama's ineligibility is that, regardless of his place of birth, he does not meet the constitutional definition of a natural-born citizen. The Fourteenth Amendment to the United States Constitution states: "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States Chin , "there is agreement that 'natural born citizens' include those made citizens by birth under the 14th Amendment.
Despite this agreement, two similar but distinct theories nonetheless contend Obama, although born in Hawaii, does not qualify as a "natural-born citizen". Some campaigners, such as the Tennessee-based Liberty Legal Foundation, contend that in order for a person to be a natural-born citizen within the meaning of Article II, Section 1, it is necessary that both parents be U.
Those who subscribe to this theory argue that since Obama's father was not a U. The Liberty Legal Foundation has cited a passage in the decision on an voting rights case which came before the U. Supreme Court— Minor v. Happersett —in which the court stated there was no doubt that "all children born in a country of parents who were its citizens" were natural-born citizens.
Governor of the State of Indiana Others, including New Jersey attorney Leo Donofrio , have falsely claimed that a person cannot be a natural-born citizen if he is a dual citizen at birth. Those who subscribe to this theory argue that because Obama's father was a Citizen of the United Kingdom and Colonies at the time Obama was born, Obama was born a dual citizen and therefore was not a natural-born citizen.
However, Kenya's constitution prohibited dual citizenship in adulthood. Obama therefore automatically lost his Kenyan citizenship on his 23rd birthday in , by failing to formally renounce any non-Kenyan citizenship and swear an oath of allegiance to Kenya. The current Kenyan constitution effective since permits dual citizenship, but requires those who lost Kenyan citizenship prior to to complete a registration process in order to regain citizenship. Notable advocates of the view that Obama may not be eligible for the Presidency include Philip J.
Berg describes himself as a "moderate to liberal" Democrat who backed Hillary Clinton for president. Senate election , served as a diplomat in the Reagan administration , and is currently a media personality and self-described "conservative political activist". Other notable advocates include Andy Martin , a perennial candidate who was "widely credited with starting the cyberwhisper campaign" that Obama is a secret Muslim,  and Robert L. Schulz , a tax protester and activist who placed full-page advertisements in the Chicago Tribune in December arguing that Obama had been born in Kenya or had subsequently renounced U.
The website AmericaMustKnow. The talk radio hosts Michael Savage , G. Rush Limbaugh , Sean Hannity and Lou Dobbs have also broached the issue several times on their shows. Some celebrities have promoted or touched upon the ineligibility claims, as well. In August , actor Chuck Norris , while not embracing the eligibility claims, wrote an open letter to Obama urging that he officially release his "original birth certificate", saying, "Refusing to post your original birth certificate is an unwise political and leadership decision that is enabling the 'birther' controversy.
And I got proof! Nothing photoshopped about my birth certificate. According to Mark Potok of the Southern Poverty Law Center , "the birther movement has gained a large following on the radical right Some of those "noxious elements" include a number of avowed white-supremacist and neo-Nazi groups. In March , after Obama was no longer the president, Malik Obama , his paternal half brother, posted on Twitter an image of a fake Kenyan birth certificate, which had been "debunked" in when it was first presented as part of one of the failed lawsuits that challenged Obama's ineligibility.
Trump was the most prominent promoter of birther conspiracy theories. The strategy worked: when Trump flirted with running for president in , his popularity was concentrated among the sizable share of Republicans who thought that President Obama was foreign born or a Muslim or both.
In , at the urging of Donald Trump 's lawyer Michael Cohen , the National Enquirer began promoting a potential Trump presidential campaign , and with Cohen's involvement, the tabloid began questioning Obama's birthplace and citizenship. In March , during an interview on Good Morning America , Donald Trump said he was seriously considering running for president, that he was a "little" skeptical of Obama's citizenship, and that someone who shares this view should not be so quickly dismissed as an "idiot"  as Trump considers the term "birther" to be "derogatory" .
Trump added, "Growing up no one knew him",  a claim ranked Pants-on-Fire by Politifact. On October 24, , Trump offered to donate five million dollars to the charity of Obama's choice in return for the publication of his college and passport applications before October 31, While those who did so were Clinton supporters, there is no evidence of Clinton or her campaign questioning Obama's birthplace. Volunteer investigators working under the direction of Maricopa County, Arizona , Sheriff Joe Arpaio have asserted that Obama's birth certificate is a computer-generated forgery.
Rejecting this claim, an assistant to Hawaii's attorney general stated in July that "President Obama was born in Honolulu, and his birth certificate is valid Regarding the latest allegations from a sheriff in Arizona, they are untrue, misinformed and misconstrue Hawaii law. He said he would submit his evidence to federal authorities. Matthew Hill , one of a handful of Tennessee General Assembly members widely reported at the time to be birthers, demanded in that newly-elected president Obama should be compelled to present Hill and other Tennessee state legislators with a certified copy of his Hawaiian birth certificate.
During The Matthew Hill Show he stated:. We've said on this program many times And I've said, "Look it's really simple. If he's not a U.
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He hides them. He's hiding them. We need the truth. We need the documents unsealed. We need to know what's going on. Senate candidate and former Chief Justice of the Alabama Supreme Court Roy Moore first questioned Obama's citizenship in , and said in that he didn't believe Obama had natural-born citizenship. In February , the Cullman Times , an Alabama newspaper, reported that at a town hall meeting there, U.
Senator from Alabama Richard Shelby was asked if there was any truth to the rumors that Obama was not a natural-born citizen. According to the Times report, Shelby said, "Well his father was Kenyan and they said he was born in Hawaii, but I haven't seen any birth certificate. You have to be born in America to be president. A Shelby spokesperson denied the story, but the newspaper stood by it. Blunt responded: "What I don't know is why the President can't produce a birth certificate.
I don't know anybody else that can't produce one. And I think that's a legitimate question. No health records, no birth certificate. But the courts don't. She had earlier voted to certify the Electoral College vote affirming his presidency, and had said she believes Obama is a U.
In November , then-Representative Nathan Deal replied to a question about whether he believed that Obama "is a native-born American citizen who is eligible to serve as president" with a statement that "I am joining several of my colleagues in the House in writing a letter to the President asking that he release a copy of his birth certificate so we can have an answer to this question.
During a December 3, interview on Rusty Humphries ' radio talk show , Humphries asked Sarah Palin if she would make Barack Obama's birth certificate a campaign issue in , should she decide to run. Palin responded, "I think the public rightfully is still making it an issue. I don't have a problem with that. I don't know if I would have to bother to make it an issue, because I think that members of the electorate still want answers. The McCain—Palin campaign didn't do a good enough job in that area.
After news organizations and blogs picked up the quotation,  Palin issued a statement on her Facebook page in which she clarified that she meant to say that voters have the right to ask questions, and she herself has never asked Obama to produce a birth certificate. She then went on to compare questioning of Obama's birth certificate to questions that were raised during the presidential elections about her maternity to her son, Trig.
Tracey Mann, a candidate running for Congress from Kansas in , stated at a candidate forum that Obama "should show his birth certificate to really resolve this thing one way or another". In a radio interview, he answered a question as "I think the president of the United States needs to come forth with his papers and show everyone that he's an American citizen and put this issue to bed once and for all. At a townhall meeting in Metairie, Louisiana on July 11, , Senator David Vitter responded to a question about Barack Obama's birth certificate saying "I personally don't have standing to bring litigation in court, but I support conservative legal organizations and others who would bring that to court.
I think that is the valid and most possibly effective grounds to do it. On September 11, , former Speaker of the House Newt Gingrich stated that Obama could only be understood by people who "understand Kenyan, anti-colonial behavior". Gibbs went on to say, "You would normally expect better of somebody who held the position of Speaker of the House, but look, it is political season, and most people will say anything, and Newt Gingrich does that on a, genuinely, on a regular basis. In December , Andy Martin plaintiff in Martin v. Lingle and self-described "King of the Birthers" announced his candidacy to seek the Republican nomination for the President of the United States.
On February 28, , on Steve Malzberg 's radio program Mike Huckabee , a candidate for the Republican presidential nomination, falsely claimed that Obama had been raised in Kenya  and that "[Obama] probably grew up hearing that the British were a bunch of imperialists who persecuted his grandfather. In March , Representative Michele Bachmann told conservative radio host Jeff Katz on his program, "I'll tell you one thing, if I was ever to run for president of the United States, I think the first thing I would do in the first debate is offer my birth certificate, so we can get that off the table.
That's for the president to state. Coffman stated that he did not know where President Barack Obama was born. Coffman went on to say of Obama that "in his heart, he's not an American. He's just not an American. In December , three out of the eleven electors from Arizona who cast their votes for Mitt Romney , raised doubts about Barack Obama's birthplace. Morrissey later insisted that he is not a birther, but stated that "In [his] opinion, what [he has] seen from the president, produced as a birth certificate, does not convince [him] that it is a real document.
Senator Lindsey Graham , October 1, . Although claims about Obama's citizenship were evaluated in by the McCain campaign and ultimately rejected,  they became a significant issue among sections of the political right. By mid, the natural born citizen issue was one of the hottest and most lucrative sources of fundraising for organizations on the right that raise funds through direct mail and telemarketing. Online petition sites such as that of Alan Keyes , who has been collecting signatures on the birth certificate issue, are a major source for generating mailing lists of movement conservatives.
Moderate conservatives have found themselves "bombarded with birther stuff". NBC Nightly News reported that other members of Congress often hear the issue too; an anonymous congressman told the program that he was reluctant to advertise his own town hall meetings for fear of this issue drowning out everything else. A number of Republican legislators have proposed legislation and constitutional amendments at the state and federal levels to address issues raised by the birth certificate campaigners.
Some Republicans are said to "want the issue to go away", seeing it as a distraction. Democratic commentators have criticized the reluctance of some Republicans to distance themselves from the proponents of the conspiracy theories, suggesting that "Republican officials are reluctant to denounce the birthers for fear of alienating an energetic part of their party's base".
Republican National Committee Chairman Michael Steele released a statement through his spokesperson saying, "Chairman Steele believes that this is an unnecessary distraction and believes that the president is a U. Conservative Joel Pollak , writing for The American Thinker , has stated that the reason the "Birther theory" has caught on particularly among conservatives, is the weakness of the Republican opposition, stating:.
In the absence of strong Republican leadership, some find the Birther theory a compelling, if desperate, solution. Republican presidential candidates need to figure out how to diffuse [ sic ] angry birthers who are bound to show up and demand their attention. If they give credence to the birthers, they're not only advancing ignorance but also betraying the narrowness of their base.
If they dismiss this growing movement, they might drive birthers to find more extreme candidates, which will fragment a Republican political coalition. The demographics tell the basic story: a black man is president and a large majority of white southerners cannot accept that, even in The fringe defines what's left of the Republican centre.
However, Republicans and Southerners were far more likely than other political or demographic groups to doubt that Obama was born in the United States. Support for the belief that Obama was born outside the U. Politico 's congressional reporter, Glenn Thrush, commented that the Research poll "explains why Republicans, including Roy Blunt, are playing footsie with the Birther fringe.
The poll found that those who do not believe that Obama was born in the United States, or do not know, are predominantly middle-aged, lower-income Republican-leaning individuals without a college education. The percentage of doubters plummeted after President Obama released the long form certificate in April In July , four months before Donald Trump was elected to the presidency, 41 percent of Republicans disagreed that Obama was born in the United States and 31 percent neither agreed nor disagreed, per an NBC poll.
Because a portion of Republican voters and their Tea Party supporters believe Obama is not eligible to hold public office see Opinion surveys section , Republicans sometimes found themselves caught in a dilemma between losing support or damaging their credibility. At a town hall meeting, Castle was confronted by constituents who jeered him for insisting that Obama is a citizen of the United States. Leslie Savan of The Nation has compared the so-called "birthers" to other groups as well, including those who deny the moon landing , the Holocaust or global warming ; "Teabaggers who refuse to believe they must pay taxes" and creationists who believe the earth is 6, years old.
A specific new breed of American conspiracy theorists who believe that the real problem with Barack Obama being president is that he can't possibly have been born in the United States. He's not eligible to be president. The birth certificate is a fake. He's a foreigner. Once this has been exposed, I guess, he will be run out of the White House A number of conservative commentators have criticized its proponents and their effect on the wider conservative movement. Talk show host Michael Medved has also been critical, calling them "the worst enemy of the conservative movement" for making other conservatives "look sick, troubled and not suitable for civilized company.
Do you know how many different flights she [Ann Dunham] would have had to take to get to Kenya in ? How much would that have cost? And then you would be stuck having your baby in Africa rather than in a modern American hospital in Honolulu. Or you could go the other way around the world — it's about the same distance either way. An editorial in the Honolulu Star-Bulletin dismissed the claims about Obama's eligibility as proposing "a vast conspiracy involving Obama's parents, state officials, the news media, the Secret Service , think-tanks and a host of yet-to-be-uncovered others who have connived since Obama's birth to build a false record so that he could eventually seek the presidency 47 years later.
Petersburg Times' fact-checking website, PolitiFact. There is not one shred of evidence to disprove PolitiFact's conclusion that the candidate's name is Barack Hussein Obama, or to support allegations that the birth certificate he released isn't authentic. And that's true no matter how many people cling to some hint of doubt and use the Internet to fuel their innate sense of distrust.
In November , commentator and social critic Camille Paglia criticized the "blathering, fanatical overkill" of the topic, but also questioned Obama's response: "Obama could have ended the entire matter months ago by publicly requesting Hawaii to issue a fresh, long-form, stamped certificate and inviting a few high-profile reporters in to examine the document and photograph it", she said. In response to the notion that Obama's grandparents might have planted a birth announcement in newspapers just so their grandson could some day be president, FactCheck suggested that "those who choose to go down that path should first equip themselves with a high-quality tinfoil hat.
For some people, when their side loses an election, the only explanation that makes sense to them — that they can cope with — is that sinister, bad, evil people arranged some kind of fraud. American political writer Dana Milbank , writing for the Washington Post , described the Obama citizenship theories of Bob Schulz chairman of the We the People Foundation , which in publicly challenged Obama's citizenship as "tales from the tinfoil-hat brigade". Some commentators have asserted that racism is a factor motivating the promotion of Obama citizenship conspiracy theories.
Richard Cohen, the President of the Southern Poverty Law Center , an organization that monitors hate groups and extremism, wrote an e-mail to supporters in July declaring: "This conspiracy theory was concocted by an anti-Semite and circulated by racist extremists who cannot accept the fact that a black man has been elected president. Obama as the insidious 'other' would have been conducted against a white president. The controversy over Obama's citizenship and eligibility for the presidency prompted a number of Republican state and federal legislators to propose legislation aimed at requiring future presidential candidates to release copies of their birth certificates.
Some legislators also lent their support to birth certificate-related litigation against Obama, joining as co-plaintiffs. Although Obama was confirmed as president-elect by Congress on January 8, ,  and sworn in as President on January 20,  litigation continued into his presidency. Numerous individuals and groups filed state or federal lawsuits seeking to have Obama disqualified from standing or being confirmed for the Presidency, or to compel him to release additional documentation relating to his citizenship.
In April , the Arizona legislature became the first to pass a bill "requiring President Obama and other presidential candidates to prove their U. Obama is not the first President to be the subject of controversy surrounding the location of his birth. Andrew Jackson was the subject of similar claims, although it is not certain that they were raised during his presidency. Some said that Chester A. Arthur was born outside the United States, with his birth records later allegedly falsified to show he was born in Vermont.
Onaka , who had certified both released birth certificates. In September , the State Objections Board of Kansas, composed of "three of the state's top elected Republicans", delayed acting on a petition to remove Barack Obama's name from the ballot, requesting information from Hawaii regarding his birth certificate;  but later voted unanimously to accept Obama's citizenship and retain him on the state's ballot, despite objections from the floor by Orly Taitz. A common claim among those arguing that President Obama was not born in Hawaii is that all doubt would be settled if Obama released his "long form" birth certificate.
However, commentators noted that doing so would be disadvantageous to Obama. First, it would encourage speculation as to why it took so long to release the document. Second, caving in to his political adversaries' demands would embolden them by giving them a victory. Finally, it would open the door to demands for other personal records unrelated to his birth certificate. Lester, this question in many ways continues to astound me.
The Obama birth certificate: a timeline | PolitiFact
The state of Hawaii provided a copy with the seal of the President's birth. I know there are apparently at least , people laughter that continue to doubt the existence of and the certification by the state of Hawaii of the President's birth there, but it's on the Internet because we put it on the Internet for each of those , to download.
At a July 27, , press briefing, radio talk show host Bill Press asked Gibbs if there was anything he could say to make the issue go away. Gibbs answered, "No. I mean, the God's honest truth is no," because "nothing will assuage" those who continue to pursue what he called "made-up, fictional nonsense" despite the evidence that Obama had already provided.
On August 6, , Gibbs commented, "You couldn't sell this script in Hollywood," and summarized the contentions that he considered "totally crazy":. All while this is transpiring in cahoots with those in the border, all so some kid named Barack Obama could run for President 46 and a half years later.
At the February National Prayer Breakfast , Obama commented, "Surely you can question my policies without questioning my faith. Or for that matter my citizenship. Williams asked Obama about the fact that a fifth of the American people do not believe that he is either American born or a Christian.
Obama responded that "there is a mechanism, a network of misinformation that in a new media era can get churned out there constantly". He then added, "I can't spend all my time with my birth certificate plastered on my forehead. On a few occasions, Obama has joked about the conspiracy theories surrounding his birth certificate and citizenship.
At White House Correspondents' Dinner , Obama said there are few things in life harder to find and more important to keep than love, and then added, "Well, love and a birth certificate. Two years into my presidency, some are still bent on peddling rumors about my origins. So today, I want to put all those rumors to rest. It is true my great-great-great-grandfather really was from Ireland. It's true. Moneygall , to be precise. I can't believe I have to keep pointing this out. In an April interview with George Stephanopoulos , Obama said, "I think that over the last two and a half years there's been an effort to go at me in a way that is politically expedient in the short-term for Republicans, but creates, I think a problem for them when they want to actually run in a general election where most people feel pretty confident the President was born where he says he was, in Hawaii.
He doesn't have horns. We may disagree with him on some issues and we may wish that you know, the unemployment rate was coming down faster and we want him to know his plan on gas prices. But we're not really worrying about conspiracy theories or And so I think it presents a problem for them. On April 27, , referring to "sideshows and carnival barkers",  Obama appeared in the White House press room an hour after the release of the long form and said, "I know there is going to be a segment of people for which no matter what we put out this issue will not be put to rest. But I am speaking to the vast majority of the American people, as well as to the press.
We do not have time for this kind of silliness. We've got better stuff to do. Later in , Obama's re-election campaign offered for sale mugs with a picture of Obama captioned "Made in the USA" and the image of the birth certificate. From Wikipedia, the free encyclopedia. This is the latest accepted revision , reviewed on 7 November Conspiracy theories falsely asserting that Barack Obama is not a natural-born citizen of the US.
So I'm here to tell you that those who think the president was born somewhere other than Hawaii you're crazy Main articles: Barack Obama presidential eligibility litigation and United States presidential eligibility legislation. Play media. April , President Obama discusses the release of his long-form birth certificate. United States portal Politics portal. White House.
Retrieved March 8, The Guardian. Retrieved July 20, Vergano, Dan May 1, USA Today. The New York Times. April 27, Zakaria, Fareed April 22, Global Public Square. Omaha Press. Associated Press. Archived from the original on March 26, Retrieved May 1, July 28, October 31, Honolulu Star-Bulletin. Retrieved January 1, April 9, Retrieved August 17, Archived from the original on April 24, Retrieved April 18, Understanding American Government , p.
International Herald Tribune. Archived from the original on June 10, Retrieved October 23, Call it a vast linguistic conspiracy: proponents of the major conspiracy theories of the day — the truthers, the birthers, the deathers — share a suffix that makes them all sound like whackdoodles. National Post. Archived from the original on December 27, Retrieved February 19, The Daily Telegraph.
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Retrieved December 15, Honolulu Advertiser. Documents hospital's name change. The Washington Post. January 20, Archived from the original on December 31, Retrieved December 19, The Arizona Independent. Mohave County, AZ. Archived from the original on January 19, Retrieved May 11, Hawaii Business Magazine. Archived from the original on August 7, Retrieved November 26, Dingeman, Robbie December 3, The Honolulu Advertiser. Retrieved January 15, New York: Crown Publishers.
Retrieved January 31, The Jakarta Post Retrieved January 28, PR Newswire. Archived from the original on April 6, Retrieved January 4, Obama is a Muslim who has concealed his religion. I am a strong supporter of the Muslim community, and I believe Muslims have been scapegoated. Obama has a great opportunity to be forthright. Instead, he has treated his Muslim heritage as a dark secret. His grandfather was named 'Hussein. Los Angeles Times. December 3, Retrieved October 14, So it's worth considering the persistence of the Internet rumors that Obama, well known to Chicagoans as a Christian, is actually a stealth Muslim, a "Manchurian candidate" who would take the presidential oath with his hand on the Koran.
The rumors first surfaced during Obama's run for Senate but took off in a viral e-mail campaign in Retrieved September 17, McClatchy DC. Retrieved November 14, Tampa Bay Times. Retrieved March 30, Retrieved February 2, Archived from the original on March 1, Then in August Phil Berg, an ex-deputy attorney general for Pennsylvania and a renowned conspiracy theorist, filed a lawsuit alleging that Mr Obama was ineligible to be a candidate The Philadelphia Daily News. Archived from the original on October 28, Philip J.
Berg alleged in a complaint filed in federal district court on Aug. October 19, Retrieved May 6, The Standard. June 27, Archived from the original on June 27, U-T San Diego. ABC News. Archived from the original on July 6, Retrieved November 8, Agence France-Presse. June 12, Obama for America. Archived from the original on September 22, State of Hawaii Department of Hawaiian Homelands. Retrieved July 23, Archived from the original on April 13, Retrieved April 19, National Review.
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