A state law automatically legitimizing everyone born out of wedlock meets the "legitimation" requirement for citizenship for a foreign-born child of an unwed U.S. Citizen father, the federal 9th Circuit says in Anderson v. Holder (March 12, 2012). Citizenship is determined under the federal law that was in place at the time of the birth of the person in question, and in this case federal law in 1954 only granted citizenship in such a situation if paternity was "established" "by legitimation" before the child reached age 21. However, during his childhood he lived in Arizona, where there was no such thing as a court or governmental "legitimation" proceeding because of a 1921 state statute making all children automatically "legitimate." Judge Stephen Reinhardt wrote:
"... to require some unspecified formal act not only defies the state legislature, it imposes a Kafkaesque requirement to undertake a formal process that does not exist."