From the U.S. Constitution....
Quote:
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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; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
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Please note, it does not say states shall not deprive
citizens of life, liberty or property, without due process. It says "any person". Then we have "any person within its jurisdiction" that have "the equal protection of the laws."
It seems to me that if this was only in reference to "citizens" they would have used that word throughout. As "citizen" is defined in the amendment "any person" would appear to include someone who is excluded by that definition, therefore a person who is not a "citizen".