Writing for the majority, Chief Justice Roger Taney distinguished between “people of the United States” and “citizens of the United States.” Taney wrote, “… they are not included, and were not intended to be included, under the word ‘citizens’ in the Constitution, and can therefore claim none of the rights and privileges which that instrument provides for and secures to citizens of the United States.” Indeed, as early as 1796, historian Craig Robertson explains that “Black sailors received a seaman’s protection certificate that stated the bearer was a “Citizen of the United States of America.”