Legal scholars agree that the constitutional question of citizenship in American Samoa is not connected to legal questions about the protection of land, culture, or self-determination in American Samoa.

• Craig R. Shagin and Delaram Rezaeikhonakdar, The American Samoan Oxymoron: The Noncitizen National And The Meaning Of Citizenship, 53 UC LAW SF CONST. Q. 559 (2026): “[R]ecognizing American Samoans as citizens, similar to residents of other unincorporated territories, would seemingly have no adverse impact [on the preservation of land or culture]. … While protecting indigenous culture is important, U.S. citizenship need not threaten it. Citizenship can coexist with the territories’ heritage and their ability to determine their political future.”

• Amy McMeeking, Citizenship, Self-Determination, and Cultural Preservation in American Samoa, 70 UCLA L. Rev. 840 (2023): “[T]here is no clear relationship between the outcome of Citizenship Clause litigation and the protection or erosion of traditional practices in American Samoa. An extension of U.S. citizenship to American Samoans would not necessarily be harmful to fa`a Sāmoa. Conversely, maintaining the status quo is no guarantee that courts will uphold American Samoa’s current laws and policies if legal challenges arise.”

• Cassandra Burke Robertson & Irina D. Manta, Integral Citizenship, 100 Tex. L. Rev. 1325, 1368 (2022): “When courts directly faced constitutional challenges to practices rooted in territorial culture, judges did not hesitate to strike down those practices without relying on citizenship status.”

• Guy C. Charlton & Tim Fadgen, Case Note: Fitisemanu v. United States: U.S. Citizenship in American Sāmoa and the Insular Cases, 39 UCLA Pac. Basin L.J. 25, 41, 45 (2022): “Given the plenary authority of Congress and the Executive over the territory which enables Federal Government [to] alter the constitutional structure and rights of the population of American Sāmoa as it deems fit, it is arguable that a grant of citizenship is likely more important to the ‘dignity’ and ‘autonomy’ of individuals in the territory than local autonomy subject to Congressional oversight. The precariousness of American Sāmoan rights under the Plenary Power doctrine, rather than exhibiting self-determination and dignity, seemingly reinforces the ‘subject’ status of American Sāmoans as colonized peoples.”