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The word "inhabitant" has several meanings in law depending upon on the context. In some contexts it is equated with citizenship; in other contexts, specifically that of the federal civil rights acts passed during the Reconstruction, "inhabitant" has been held not to mean "citizen." Baldwin v. Franks, 120 U.S. 678, 690-692, 75 S.Ct. 656, 32 L.Ed. 766 (1887)

After comprehensive analysis of the intent of Congress which drafted this legislation, this court holds that the word "inhabitant" describes any person who is within the jurisdiction of the United States.

Upon introducing the provisions which eventually became 18 U.S.C. 242, its sponsor, Senator Stewart, explicitly stated that the bill protects all "persons." He noted that the bill "simply extends to foreigners, not citizens, the protection of our laws.". He added:

This bill extends the equal protection of the laws to aliens, so that all persons who are in the United States shall have the equal protection of our laws. It extends the operations of the civil rights bill . . . to all persons within the jurisdiction of the United States. United States v. Otherson (1979) 480 F.Supp. 1369, 1370-1373.

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