Patsone v. Pennsylvania , 232 U.S. 138 (1914) was a U.S. Supreme Court case that upheld Pennsylvania’s Act of May 8, 1909, deeming it unlawful for "unnaturalized foreign born residents" to kill wild animals, except for when defending their property or person and only by means of a pistol; the Pennsylvania statue barred unnaturalized foreign born residents from possession of shotguns or rifles for any reason.[1] Although the case was directly addressing Second Amendment rights of noncitizens in the context of wild game, it also brought forward discussions of Fourteenth Amendment rights for noncitizens, State’s rights to wildlife, and symmetry of justice.[2] [3]