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The earliest recorded date of Native Americans' becoming U.S. citizens was in 1831 when the Mississippi Choctaw became citizens after the United States Legislature ratified the Treaty of Dancing Rabbit Creek. Under article XIV of that treaty, any Choctaw who elected not to move with the Choctaw Nation could become an American citizen. There has been considerable debate about Native American U.S. citizenship. In 1857, Cheif Justice Roger B. Taney expressed that since Native Americans were "free and independent people" that they could become U.S. citizens. Prior to the passage of the Indian Citizenship Act of 1924, nearly two-thirds of Native Americans were already U.S. citizens. The act of 1924 granted U.S. citizenship to those Native Americans who were not already U.S. citizens.

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