Certain rights in the U.S. Constitution, like the “right” to “vote” in the 24th Amendment, are explicitly applicable to “citizens,” while other rights apply to all “persons” in the nation. For example, the 5th Amendment forbids government from taking the “life” of any “person” in the U.S. without “due process.” Contrary to the belief that “persons” is a synonym for “citizens,” the Constitution clearly distinguishes between them, sometimes in the same paragraph, like the opening one of the 14th Amendment. Thus, the U.S. Supreme Court has consistently held that “person” means everyone in the nation. For example, the Court ruled in Yick Wo v. Hopkins that “the guarantees of protection” in the 14th Amendment “extend to all persons within the territorial jurisdiction of the United States.” In the Constitution, “the people” is shorthand for “the people of the United States,” meaning citizens. This is why the 2nd Amendment “right of the people to keep and bear Arms” applies only to citizens.