On what grounds did the Supreme Court rule against John Elk when he applied for citizenship? Provide a brief description of the Elk v. Wilkins (1884) ruling. Please include Elk's argument and the Court's decision.

In the case of Elk v. Wilkins (1884), the Supreme Court ruled against John Elk when he applied for citizenship on the grounds that he was not a member of a recognized tribe. Elk, a Native American born in the United States, argued that he should be granted citizenship under the 14th Amendment, which granted citizenship to all persons born or naturalized in the United States. However, the Court held that Elk was not a citizen because he was a member of a tribe and therefore not subject to the jurisdiction of the United States. The ruling established that Native Americans were not considered citizens unless they renounced their tribal affiliations, a decision that was not overturned until the Indian Citizenship Act of 1924.