A new report from the conservative think tank Advancing American Freedom and the Edwin Meese III Institute is calling on Congress to limit birthright citizenship in U.S. territories, including American Samoa.

The report, released Tuesday, comes after the Supreme Court’s recent decision in Trump v. Barbara, which upheld near-universal birthright citizenship nationwide. The report’s authors argue territories are different, since citizenship there comes from federal statute rather than directly from the Constitution, relying on a set of rulings known as the Insular Cases. American Samoa is already the one U.S. territory where Congress never extended statutory citizenship at birth. People born there are U.S. nationals, not citizens.

The report argues Congress should amend citizenship statutes in the other territories, Puerto Rico, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands, to require that at least one parent be a citizen or lawful permanent resident.

Critics, including the advocacy group Right to Democracy, call the reasoning dangerous, arguing it revives a colonial legal framework that has long denied territories political rights and self-determination. The group also represents two American Samoa-born individuals facing federal charges in Alaska tied to their non-citizen status.