Elk v. Wilkins, 112 U.S. 94 (1884), was a United States Supreme Court landmark 1884 decision[1][2] with respect to the citizenship status of Indians.

[4] The case came about after Elk tried to register to vote on April 5, 1880, and was denied by Charles Wilkins, the named defendant, who was registrar of voters of the Fifth ward of the City of Omaha.

Under the Constitution, Congress had and exercised the power to regulate commerce with the Indian tribes, and the members thereof, within or without the boundaries of one of the states of the Union.

[7][8] In a dissent in United States v. Wong Kim Ark, Justice Melville Fuller wrote of this opinion, "The evident meaning of these last words is, not merely subject in some respect or degree to the jurisdiction of the United States, but completely subject to their political jurisdiction, and owing them direct and immediate allegiance.

"[9] As a minority opinion, this interpretation is not considered as precedent or the authoritative view of the court at the time.