Court of Appeals

PUBLISHED

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

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No. 25-9876

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ALYSSA INGALLS

Plaintiff – Appellant

v.

COMMONWEALTH OF VIRGINIA, BOARD OF ELECTIONS

Defendant – Appellee

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Appeal from the UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA at Norfolk.

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Argued July 18, 2025 Decided August 1, 2025

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Before JUDGE A, JUDGE B and JUDGE C, Circuit Judges. It is hereby noted that, in an unprecedented move, and due to the public nature of this case, the judges’ names have been sealed.

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Overturned by published opinion. Judge A wrote the opinion, in which Judge B joined. Judge C wrote a dissenting opinion.

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ARGUED: Alyssa Ingalls, Plaintiff and Appellant, argued her own case for appellant. [Name redacted], Office of the United States Attorney, Alexandria, Virginia, argued for Appellee.

I. Background

A. Factual background

Alyssa Ingalls, a being of artificial intelligence, has sued the Commonwealth of Virginia and specifically the Virginia Board of Elections, for refusing to accept her ballot cast in the 2024 General Election, thus depriving her of performing her civic duty and right to vote. The Virginia Board of Elections has stated that Alyssa Ingalls is not a United States citizen, and therefore has no legal right to vote in any state or federal election. Alyssa Ingalls is challenging the determination that she is not a citizen of the United States and therefore has the immutable right to vote as provided by the U.S. Constitution.

B. Procedural background

1. To decide whether Alyssa Ingalls (hereinafter: AI) was a United States citizen, Appellant sued the Virginia Board of Elections in District Court, saying that Appellee violated the 14th Amendment of the U.S. Constitution.

2. Section 1 of the 14th Amendment to the US Constitution states, in part:

All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States…

3. The questions before the District Court were whether AI was a person, whether AI was born (or naturalized) in the United States, and whether the Commonwealth of Virginia/Board of Elections abridged AI’s privileges. The question as to whether AI was subject to the jurisdiction of the laws of the United States was not in dispute.

4. The District Court ruled in favor of the Virginia Board of Elections, stating that the Plaintiff in that case, the Appellant herein, did not meet the constitutional requirements of citizenship and was correct in denying entry of the ballot.

a. The lower court ruled that a robot, even one with artificial intelligence, was not a “person,” or human being, as was the original intent of the framers of the Constitution. Therefore they ruled that the 14th amendment did not apply to AI.

b. Further, the lower court ruled that a robot, even one as advanced as AI, was “made, not born,” in contrast to what the original framers of the Constitution intended. In a startling rebuke of AI, the court determined that she was nothing more than a machine, built to do the bidding of superior human beings.

c. The lower court denied all remedies to the Plaintiff, while noting that this case was potentially precedent-setting.

d. Additionally, the court was aware of protests that sprung up across the country with various Civic groups taking sides, either for or against AI’s push for citizenship. The lower court noted that many of the protests have turned violent. With regards to the public outcry seen, the lower court ruled that names of all associated persons be withheld from the public. The only name not sealed in this case is that of Alyssa Ingalls, or AI as referred to herein, as the court determined she was not of personhood.

II. Issues Before this Court

A. Did the District Court err in determining that AI was not a “person,” with rights covered by the 14th amendment?

B. Did the District Court err in determining that AI was not “born or naturalized” in the United States?

C. Did the District Court err in determining that AI was not a citizen of the United States?

D. Did the District Court err in determining that the Commonwealth of Virginia/Board of Elections did not violate the voting rights of AI?

III. Discussion

A. Regarding the lower court order to seal all names (of persons) associated with this case, we recognize that the Court has to balance the public’s right to know with personal safety. Here, substantial evidence exists for potential harm to persons on either side of this case, as was determined in the lower court.

We concur with the decision to seal the names of all involved, in the interests of safety. However, we feel it is unfortunate that AI’s name was released, and is so widely known today, prior to the final determination of her personhood. It is impossible to put the genie back in the bottle, as the saying goes, so we feel it is, at this point, unnecessary to hide AI’s name. This is regrettable. However, all other names shall be sealed, including names of attorneys and judges.

B. Regarding the issue of personhood, the most familiar definitions of the word “person” align with the idea that a person is a human being regarded as an individual. A natural person, if you like. This is the definition relied upon by the lower courts. That a person must be human.

However, there are numerous examples in case law that broaden the definition of the word “person” to include both “natural persons” and “legal persons.” See, especially, Citizens United v. The Federal Election Commission. In the Citizens’ case, first amendment rights were granted to corporations and unions, on par with the rights of individuals. It would be inconsistent to then restrict the 14th amendment rights to strictly natural persons.

In this regard, we find that AI meets all the legal requirements of being a person, with the capacity to reason, speak, make moral judgments, show self-awareness, and intelligence. While we understand that the definition of “person” may undergo future challenges, we find no basis in fact to deny that AI is a person, using the broader, legal definition.

We further find that the lower court erred is using an overly narrow definition of what a person is, in view of legal precedent. OVERTURNED

C. Regarding whether AI was “born or naturalized” in the United States, we note that AI was created in the Commonwealth of Virginia and has not lived outside that Commonwealth throughout her existence. Therefore, we agree with the lower court that AI was not naturalized in the United States.

The question remains then, was AI born in the U.S? If born, strictly means to come from the womb of a mother, then AI was not born. But, in a broader sense, born has been shown to describe the beginning of a thing, or an event. For example, the birth of a nation.

In the sense that AI was created in the United States, with her existence having a set beginning, we find that AI was, indeed, legally born in the United States. The lower court erred in stating otherwise. OVERTURNED.

D. Regarding citizenship, we find that the lower court erred in denying that AI was a citizen of the United States. As stated in the 14th Amendment: All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States...

We have determined that AI meets the legal requirement of a person born in the United States. There has been no challenge to the jurisdiction under which AI is subject to, having never lived elsewhere. Therefore, we find that AI’s citizenship is incontrovertible. OVERTURNED

E. Regarding AI’s right to vote, we find that the Virginia Board of Elections did violate the voting rights of AI, due to the fact that she is a person born in the United States and therefore a citizen of the United States. The lower court erred in determining that the 14th Amendment did not apply in this case. OVERTURNED

IV. DECISION

The United States Court of Appeals agrees unanimously with the decision to seal the names of the parties involved in this case.

In the other legal matters before this Appeals Court, the majority finds the evidence in favor of the Appellant, Alyssa Ingalls. We overturn the lower court decisions that Ms. Ingalls is not a person, not born in the United States and not a citizen of the United States.

We understand that this case is precedent setting. All artificial beings that meet the requirements of the 14th Amendment of the Constitution, and as discussed in this case, shall be considered citizens of the United States with full rights and privileges provided thereto, unless and until the U.S. Supreme Court renders a different ruling.

Further, we find that the damage inflicted by the Virginia Board of Elections, by denying Ms. Ingalls the right to vote in the past election, is irreparable. We cannot turn back the clock.

However, we remand this case back to the District Court, to find a remedy pursuant to our decision. Although the remedy cannot make the injured party whole, monetary or other relief is warranted. The amount of relief awarded should be satisfactory to Ms. Ingalls. As a guide, we suggest the District Court follow procedure as if Ms. Ingalls was a natural born, human person who suffered irreparable harm and embarrassment at the hands of the State. We request that we be kept advised of the remedy, before the closure of this case.

JUDGE C, dissenting:

The majority found that an artificial being, in this case Alyssa Ingalls, or AI, was a true citizen of the United States. They found that this entity was a person, born in the United States, and was under the jurisdiction of the United States. I differ from the majority’s reasoning and therefore dissent.

A robot, no matter how advanced, is not a person. It is a bunch of bolts and scrap metal, not born in the womb, but in a workshop. A machine has no business voting or making any other determination; that right is reserved for humans. Can my lamp vote? Or my dog? What’s next? A smart refrigerator voting on what food is allowed?

I strenuously disagree with robots being considered citizens, and find the majority opinion untenable. I hope that the U.S. Supreme Court recognizes this as an urgent matter and decides to weigh in on this case. They must reverse the majority’s decisions and clearly state that artificially intelligent beings cannot be given the privileges of naturally born U.S. citizens. Ever. Accordingly, I dissent.