The following excerpt is from NORIO KIYAMA v. Rusk, 291 F.2d 10 (9th Cir. 1961):
The court noted the procedural rule set up to protect American citizens by birth is sui generis, and contrary to the general rule. See note 1, order of April 27, 1959, Kiyama v. Dulles, 268 F.2d 110 at page 111.
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