In 1884, the Supreme Court Ruled Against John Elk When

In 1884, the Supreme Court ruled against John Elk when he tried to claim American citizenship. What reason did the Supreme Court give for rejecting his petition?

A) He was not paying taxes and had not done anything to assimilate into American society.
B) He was not born within the boundaries of the United States, and thus was not subject to its "jurisdiction."
C) Whether he had achieved the degree of "civilization" required of American citizens was in question.
D) He did not follow the appropriate procedures and refused to give up his tribal affiliation.
E) Western courts had never denied Native Americans the rights afforded by the Fourteenth and Fifteenth Amendments.