 In an influential essay first published in 1950, the British sociologist T.H. Marshall posited “an evolution of citizenship which has been in continuous progress for some 250 years” (Marshall and Bottomore 1987: 7). Marshall employed a tripartite distinction that was, in some ways, similar to the traditional distinction found in the opinions of the U.S. Supreme Court, but his purpose was very different from any effort to hierarchically sort citizens into different categories with differing sets of rights. He assumed that the rights of citizenship should be the same for all, and his aim was to show that the set of rights had been expanding over the centuries.