On November 3, 1884, the US Supreme Court ruled in Elk v. Wilkins that John Elk, an Indian who had tried to vote in a federal election in Omaha, Nebraska, was not a US citizen entitled to the protection of the 14th and 15th Amendments of the US Constitution. Native Americans became eligible for citizenship in 1887 under the Dawes Act, but only in 1924, under the Indian Citizenship Act, were all Native Americans born in the US made citizens.