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CSI0010.1177/0011392115614781Current SociologyBoatcă and Roth
Article CS
Current Sociology
Manuela Boatcă
University of Freiburg, Germany
Julia Roth
Centre for Inter-American Studies, Bielefeld University, Germany
Abstract
An entire Occidentalist tradition of citizenship theory viewed citizenship as a modern,
progressive institution that helped overcome particularities of unequal social origin.
Contrary to the claims of this (mainly male) Western scholarly tradition, the article
argues, first, that the institution of citizenship has developed in the West through
the legal (and physical) exclusion of non-European, non-White and non-Western
populations from civic, political, social and cultural rights; these exclusions, and thus
citizenship as such, have historically been (en)gendered. Second, the article maintains
that citizenship and gender are the most decisive factors accounting for extreme
inequalities between individuals in rich and poor countries in the twenty-first century.
Forms of racialization, sexualization and precarization to which the acquisition of
citizenship and the corresponding gain in social mobility are linked today are illustrated
with examples of practices to subvert citizenship law through marriage or childbirth in
countries relying primarily on jus sanguinis and jus soli, respectively.
Keywords
Citizenship, coloniality, gender, global inequalities, migration, social mobility
Time and again, canonical sociology has presented and analysed citizenship as a counter-
balance to social inequalities. From Max Weber through Talcott Parsons and up to Bryan
Turner, the institutionalization of citizenship was seen as part of a sequence of social
Corresponding author:
Manuela Boatcă, Institut für Soziologie, Albert-Ludwigs-Universität Freiburg, Rempartstr. 15, 79098 Freiburg
im Breisgau, Germany.
Email: manuela.boatca@soziologie.uni-freiburg.de
change characteristic of the West, which entailed progress from bondage to freedom and
from ascribed to achieved positions in the inequality structure, ultimately defining the
alleged transition from tradition to modernity. By contrast, the present article argues that
a global perspective on citizenship reveals that its institutionalization in the West has
gone hand in hand with the legal (and physical) exclusion of non-European, non-White
and non-Western populations from civic, political, social and cultural rights. Both within
and outside the West, women have been granted such citizenship rights only gradually,
while populations of other regions have been gendered along colonial lines. On the one
hand, the article draws on recent legal and sociological scholarship on global inequalities
which has pointed to the ascribed character of citizenship and its key role in maintaining
high inequalities between countries in the modern world (Korzeniewicz and Moran, 2009;
Shachar, 2009). On the other hand, it builds on the literature on coloniality (Lugones,
2008; Mignolo, 2000; Quijano, 2000) in order to reveal the structural distribution of
unequal and gendered citizenship rights as a crucial component of modernity/coloniality,
or what we call the coloniality of citizenship.
the humanity of the Native Americans in the ‘New’ World, a theological, scientific and
scholarly debate on the nature of women took place in Europe, at the end of which the
view that women were essentially passive, sensual, fragile and mentally inferior prevailed.
As in the case of Amerindians and Black Africans, this shift was related to the capitalist
transformation of economic roles: to the degree that the economy was being geared
towards commodity production, women’s role as economic resource for their families’
subsistence turned into the one of emotional resource for their husbands (Merchant,
1980: 155). As a consequence, marriage was resignified as the social form which allowed
controlling women’s ‘unbalanced nature’ and which was therefore the most adequate
(i.e. desirable) social arrangement. Orthodox theologians began upholding the family,
centred around the authoritative figure of the father, as the institution capable of main-
taining social order on the basis of Christian values: ‘To this end, the authority of the
father was equated with the authority of God, and God with that of an absolute monarch.
By implication, this legitimated all other authorities – kings, nobles, landowners, priests’
(Pelizzon, 1998: 250).
Besides marking the religious celebration of motherhood and domesticity, the key
role attributed to the (holy) family as a social ideal entailed an entire range of norms and
regulations. They included the urban authorities’ enforcement of the ‘conjugal order’, the
normative upgrading of domestic violence towards women as a socially desirable means
of maintaining said order, and – most importantly – the gradual criminalization of contra-
ception, abortion, infanticide and unwed motherhood (Federici, 2004; Pelizzon, 1998:
238ff.) – in short, of all forms of sexual independence.2 Thus, 1492 was also the year in
which the first ordinance forbidding women under the age of 50 to live alone and stipulating
that they instead go into service until they were married was passed in Coventry, England
– soon to be followed by stricter ones all over Western Europe (Pelizzon, 1998; Peters,
2004). Although exceptions to this norm still remained socially acceptable a century later,
economic independence for single women was rendered increasingly difficult, while
marriage became associated with economic prosperity and status in the community
(Merchant, 1980; Peters, 2004). These trends were reinforced after 1550, when state
policies were more specifically aimed at excluding women from skilled craft, guilds and
high-status occupations, and Protestant theology reinterpreted marriage and the house-
hold – rather than outside employment or political issues – as the main concern of women
(Pelizzon, 1998: 243). By 1600, the gradual banning of unmarried women and widows
from most crafts and of all women from entering apprenticeships in many trades had
limited employment opportunities for lower-class women to unskilled work, especially
service activities, and to low-paid wage labor such as spinning (Merchant, 1980; Pelizzon,
1998). Prostitution, increasingly present in the cities both in the wake of the influx of
pauperized peasants and of the declining work alternatives for women, was gradually
stigmatized as morally reprehensible and its exercise restricted to special ‘women’s
houses’ (Mies, 1996: 81). Although women still figured in the public sphere throughout
the sixteenth and well into the seventeenth century, this tended to concern only those
public arenas ultimately linked with the household, such as markets. As Sheila Pelizzon
notes, ‘What the domestic ideology denied women in the end, was a right to freedom of
movement – i.e., women were never supposed to be unsupervised by some man, or not
under the immediate authority of some man. For example, this abbreviated the right to
travel, or to live alone or assemble freely’ (Pelizzon, 1998: 3). In the meantime, a woman’s
sex had become a better predictor of her sphere of activity than her class membership
(Merchant, 1980: 150).
It was with the emergence of the European institution of citizenship – understood as
an expression of liberty, i.e. the opposite of slavery – that the subsuming of women’s
rights under male authority was formally codified and their mobility rights further
curtailed. In the immediate aftermath of the French Revolution, citizenship rights were
only granted to male property-owners, whose ability to pay taxes and military tribute, i.e.
contribute to the maintenance of social order, qualified them as ‘active citizens’. Women,
foreigners and children were in turn defined as ‘passive citizens’ and denied all political
rights (Blackburn, 1988: 198; Wallerstein, 2003: 653ff.). While, in the case of white
Western European women, this was considered a temporary provision, to be remedied by
further educational measures, the reduction of enslaved Africans to commodities and
‘pure flesh’ also deprived them of a gender status compared to that of citizens.3 Both
Olympe de Gouges’s 1791 ‘Declaration of the Rights of Women and the Female Citizen’
and Mary Wollstonecraft’s 1792 ‘A Vindication on the Rights of Women’ pointed to the
male dividend of the human rights and citizenship discourse – to no immediate avail.
The French Constitution of 1793 extended active citizenship to all adult (not necessarily
propertied) males, thus leaving women to derive their membership in the social community
from their relationship to men (Hanagan, 2002: 167). Additionally defined as vulnerable
through the exclusion from the military and as close to nature on account of their repro-
ductive capacity, women would now find themselves increasingly outside the male
domain of culture, in turn associated with wage work and the tasks to protect and provide.
The culturally and normatively binding female ideal of the time found its expression in the
social role of the housewife (and mother), whose consignment to the private sphere of the
household entailed the simultaneous construction of the unpaid work done there as a natural
resource and therefore as ‘non-work’. Thus, the gendering of the private and the public
spheres, although only legally sanctioned in the wake of the French Revolution, in fact
built on the social definition of reproduction as a non-economic activity and as an exclu-
sively female one, which had been initiated with the degradation of women’s social and
economic standing in the sixteenth century.4 Werbner and Yuval-Davis describe the exclu-
sion of women from citizenship as ‘an intrinsic feature of their naturalization as embodi-
ments of the private, the familial and the emotional’ and as such ‘essential to the construction
of the public sphere as masculine, rational, responsible and respectable’ (Werbner and
Yuval-Davis, 1999: 6). By relegating women, children and foreigners in the (however
recent) past of the civilizing process that adult men had supposedly accomplished, the
implementation of allegedly universal principles was thus constantly creating racialized
and gendered particularisms. The corresponding exclusions ranged historically ‘from
colonial subjects to women, particular classes and racialized minorities, to people with
different sexualities and abilities’ (Dobrowolsky and Tastsoglou, 2006: 9ff.).
In the French colony of Saint-Domingue, where the revolution of the enslaved led by
Toussaint L’Ouverture resulted in the abolition of slavery in 1794, the racially constructed
notion of skin colour took precedence over property as a criterion for the granting of
citizenship. Since not all whites were property-owners, but relatively many free ‘mulattos’
were, the colonial assembly included the former in the right to vote even before this was
… not only did the few European women who went to the colonies as wives and ‘breeders for
race and nation’ rise to the level of proper housewives on the subordination and subjection of
the colonized women, so too did the women ‘back home’; first those of the bourgeoisie, later
also the women of the proletariat, were gradually domesticated and civilized into proper
housewives. For the same period which saw the expansion of colonialism and imperialism also
saw the rise of the housewife in Europe and the USA. (Mies, 1996: 101)
Consequently, to the extent that subsistence production outside Europe was declared
a ‘backward’ and ‘underdeveloped’ labor form, the bourgeois family model propagated
in Western Europe made it possible to stigmatize female housework as ‘non-work’ and
to define women into the norm of non-wage work altogether. Not only the naturalization
of women, but also that of peasants and slaves in the colonies thus occurred temporally
and (ideo)logically parallel to the process of housewifization of bourgeois women and to
that of the proletarianization of male non-wage workers in the industrial centres. Both
were conceived as dimensions of the larger civilizing process (Mies, 1996; von Werlhof
et al., 1983). Gender, revealed to be a colonial construction by a number of scholars
(Lugones, 2007; McClintock, 1995; Stoler and Cooper, 1997), has informed the modern/
colonial institution of citizenship from its emergence. Gender and citizenship have been
embedded in highly complex ways with other dimensions of stratification and inequality
such as racialization and enslavement, placing men, women and transgender persons at
very different positions in racialized colonial hierarchies. In her 1975 essay ‘The traffic
in women’, feminist scholar Gayle Rubin described the ‘sex/gender system’ as a ‘set of
arrangements’ through which sex is translated into gender and which serves as a prototype
of all social and economic relations. In this system, men exchange women among
themselves on a continuum ranging from prostitution to marriage (Rubin, 1975). Rubin
considered the sex/gender system to pertain not only to a capitalist economy but to con-
stitute the very fabric of culture throughout human history, while Jean Franco argued that
particular forms of the ‘exchange’ of colonized women – such as enslaved indigenous
women given as a gift to the Spanish conquerors or being exchanged between Aztecs
and Spanish men – were already part and parcel of the conquest (Franco, 1999: 71ff.).8
Bridging instead world-systems and decolonial analyses of the capitalist world-economy
(Mignolo, 2000; Wallerstein, 1974) with feminist perspectives, María Lugones coined
the term ‘modern/colonial gender system’ to refer to the co-constituency of gender,
modernity and coloniality under capitalism:
Colonialism did not impose precolonial, European gender arrangements on the colonized.
It imposed a new gender system that created very different arrangements for colonized males
and females than for white bourgeois colonizers. Thus, it introduced many genders and gender
itself as a colonial concept and mode of organization of relations of production, property
relations, of cosmologies and ways of knowing. (Lugones, 2007: 186)
thus employed blended the logic of gendering into that of racial and ethnic inferiorization
by equating primitiveness and exoticism with femininity and puerility. What Edward
Said had identified as the set of features used in describing the Orient as Other – ‘its
eccentricity, its backwardness, its silent indifference, its feminine penetrability, its supine
malleability’ (1979: 206) – applied to slightly varying degrees to African women, Oriental
men and the non-Western more generally.9
The social construct of race had gradually replaced religious denomination as an
identity marker and also as an indicator of a person’s position within the hierarchy of
methods of labor control outside Europe. At the same time, citizenship, initially defined
in relation to (male) gender, property status, literacy, and not least social and ethnic
extraction, fulfilled the same function in the newly emerging secular nation-states of
Western Europe. While the typologies thus established legitimated the hierarchy of
labor payment according to a person’s degree of proximity to this standard of citizen-
ship, institutional mechanisms ensured the normalization of the resulting ‘Others’. The
work of the Africans and Native Americans in the colonies, such as that of women and
children in the entire world economy, was treated as inferior, and that of housewives as
‘non-work’, and was therefore either non-wage or unpaid labor. National constitutions,
schools, hospitals, prisons and guidebooks were in charge of emphasizing the universal
norm, isolating or treating deviation, and preparing the young generation for the role of
the citizen as defined by Occidental standards. As decolonial philosopher Santiago
Castro-Gómez has argued for Latin America, the disabled, homosexuals and dissidents
fell just as short of the economically profitable and socially compliant national subject,
as women, the illiterate, non-whites, or the enslaved:
The acquisition of citizenship is … a filter through which only those are allowed to pass, whose
profile fits the type of citizen required by the project of modernity: male, White, paterfamilias,
Catholic, property-owner, literate and heterosexual. Those who do not meet these requirements
(women, servants, the mentally ill, the illiterate, Blacks, heretics, slaves, Indians, homosexuals,
dissidents) remain outside the ‘lettered City’ … sentenced to punishment and therapy by the
same law that excludes them. (Castro-Gómez, 2000: 149, our translation)
Especially in those parts of Latin America that had previously been central to the
Spanish empire before the eighteenth century, and which still had a sizable indigenous
population – such as Mexico, Central America and the Andean region – the inculcation
of Western norms through public education was part of extensive policies of cultural
assimilation that largely built on modified versions of the former colonial policies.10
In contrast, in Argentina, Chile and Uruguay, but also in the United States, the virtual
physical extermination of the natives and the conspicuous absence of Blacks from state
discourse silenced the question of the political participation and social enfranchisement
of the non-White population (Quijano, 2006: 199ff.). Thus, the civilizing mission brought
about a dual pattern of hierarchization of difference according to racial and ethnic criteria,
both of which were moreover gendered (e.g. depicting indigenous men as feminized and
lacking Occidental masculinity, while positioning enslaved Africans as hypermasculine,
threatening, and thus to be controlled). In turn, the respective gender positions have been
racialized and ethnicized along colonial patterns, creating the image of the white virtuous
woman and ‘mother’ of the race/nation – and later housewife – to be monitored and
protected from black male aggression, or of the sexually threatening, eroticized and
permanently available black female body, accordingly deprived of (the right to) protection
and motherhood. It is at this juncture of gender, race and ethnicity as products of the
colonial crucible that the institution of citizenship is revealed to be a key element in the
maintenance of the coloniality of power of the modern world-system. It is to the specific
mechanisms of its functioning throughout the history of the system that we refer as the
coloniality of citizenship.
At the same time, solid evidence for the fact that national citizenship represents the
best indicator of an individual’s position within the world’s inequality structure has come
from sociological analyses of the global income distribution. Using the Gini coefficients
of 96 countries, Korzeniewicz and Moran (2009) have shown that national inequality
patterns can be grouped into two distinct global clusters. In the high inequality cluster
(above a Gini of 0.5), containing the bulk of Latin America, the Caribbean and Africa,
systematic exclusion on the basis of ascriptive criteria such as race, ethnicity and gender
has historically served to limit access to economic, social and political opportunities to a
tiny elite. In turn, the low inequality cluster (below a Gini of 0.3), which encompasses
the whole of Western Europe and parts of Eastern Europe, as well as Australia, Japan and
Canada, has involved widespread relative inclusion of the population through the extension
of property and political rights increasingly derived from achieved (rather than ascribed)
characteristics, such as education, and has facilitated the development of welfare states.
The authors find that membership in both clusters goes back in time to the eighteenth
century and they clearly trace the origins of the institutional arrangements typical of high
inequality patterns back to colonial slavery (Korzeniewicz and Moran, 2009: 31). The
long-term stability of low inequality levels, they argue, has been safeguarded by restricting
physical access to these regions on the basis of ascribed categories, especially national
identity and citizenship, through the control of immigration flows – not of achieved
characteristics such as one’s level of education or professional position, or the economic
growth of the country or region itself.
In this case, too, the logical (and radical) conclusion is that international migration,
which entails gaining access to at least the average income of the poorer country deciles
of a much richer nation-state, becomes the ‘single most immediate and effective means
of global social mobility for populations in most countries of the world’ (Korzeniewicz
and Moran, 2009: 107). Thus, migration not only represents a strategy of upward mobility
for populations of ex-colonial countries possessing metropolitan citizenship, but also a
means of eluding the ascribed position derived from the national citizenship of a poor
state for populations able and willing to risk illegal, undocumented or non-citizen status
in a rich state.11
The possession of citizenship of the former metropole remains to this day a crucial
factor deciding the timing and the destination of ex-colonial subjects’ emigration as well
as the striving for independence in the remaining colonial possessions. This has been
documented for the postcolonial migration flows between several Western European
countries and their former colonies or current overseas departments, as well as for the US
and its ‘protectorates’: thus, fear of losing Dutch citizenship has led to an unparalleled
increase in Surinamese emigration to the Netherlands in the years preceding Surinam’s
independence from the ‘motherland’ (1974/1975) and is the main reason behind the lack
of political pressure for independence in the Dutch Antilles and Aruba in recent times
(Van Amersfoort and Van Niekerk, 2006). Likewise, the extension of US citizenship
rights to the populations of all Caribbean colonies after the Second World War triggered
a massive transfer of labor migrants from the Caribbean to the US (Cervantes-Rodríguez
et al., 2009).
This world-systemic reconceptualization sheds new light on the workings of the institu-
tion of modern citizenship from its very emergence in the context of the French Revolution.
On the one hand, the gradual extension of citizenship rights from propertied white males to
all white males and to white women (although to a large extent restricted until well into the
twentieth century) accounted for the development of low inequality within continental
France as of the eighteenth century. On the other hand, the categorical exclusion of Saint-
Domingue’s black and ‘mulatto’ population from French citizenship, irrespective of their
property status, ensured the maintenance of high inequality between France and Saint-
Domingue/Haiti, as well as between other Western colonial powers and their colonial
possessions more generally. It thus becomes clear that the entail of property that Shachar
used as an analogy to the entail of citizenship was a colonial entail, and that both helped
preserve inherited property, in the form of material goods proper and of rights to goods,
state support, social services and infrastructure in the hands of the (racially, ethnically and
geopolitically) designated heirs to the Western colonial enterprise for several centuries.
price of bananas, the country’s primary crop, had seriously damaged its economy (Dzankic,
2012). Within Southern and Eastern Europe, citizenship and residency programmes have
emerged especially as a result of the 2008 financial crisis. A real estate investment rang-
ing from €250,000 to €1,150,000 buys foreigners residency rights and, in some cases,
full European Union citizenship in Latvia, Hungary, Ireland, Spain, Portugal, Greece,
Cyprus, Macedonia, Bulgaria and Malta, whose investment programmes have all been
implemented since 2010 (BBC News, 2013; CNN Money, 2013). Visa-free travel to core
countries, citizenship of a Schengen zone state, or even the right to work in the European
Union thereby become available for the (moderately or very) wealthy, consequently link-
ing the inequality of income and property to the access to property commodified in the
form of citizenship. However, the commodification of citizenship does not represent a
viable option for most of the world’s population. Instead, it is either an option purposely
designed for a very select few or – more frequently – is scandalized, stigmatized and,
ultimately, criminalized when it threatens to become available to a wider number of people.
In most cases, the declared goal of economic citizenship programmes is to attract wealthy
investors, especially from China, but also, and increasingly, from Russia and the Middle
East. Yet it is only the citizenship of a few states that lends itself to being commodified
by virtue of being a scarce good awarding (relatively) rare benefits. From this point of
view, states whose citizenship includes the advantage of the above-mentioned visa-free
travel to Western countries or even the right to legal employment in them, offer what we
have elsewhere called ‘premium citizenship’ (Boatcă, 2014) that is attractive to investors.
States that are not part of the wealthy core, may, as in the case of St Kitts and Nevis, use
the residual benefits of having been a British colony and that today consist of being a
member of the Commonwealth of Nations – which share, among other things, a visa-free
travel area. This, however, hardly compares to the rights accruing from EU citizenship.
The European Union is home to eight out of the ten countries worldwide whose citizens
enjoy the most freedom of visa-free travel (International Business Times, 2013). At the
same time, it is the historic heir to Western colonial states whose colonial possessions
covered almost half of the inhabited surface of the non-European world as late as the
1930s and who today control 28 out of the remaining 58 colonial possessions (Böröcz
and Sarkar, 2005; Dependencies and Territories of the World, 2013). In accordance with
the worldwide division of labor, wealthy individuals in high positions through which
they enjoy access to ‘buying into’ a privileged citizenship are predominantly male.
The colonial entail of property thereby helps perpetuate the colonial entail of premium
citizenship for Western states alongside the gender dividend of citizenship worldwide.
European Union and the United States – only targets the latter: for labor migrants, inher-
ited citizenship and lengthy naturalization procedures are legally (re)inforced as the only
legitimate options. In addition, the curtailment of women’s rights, mobility and access to
capital, which has historically made them more vulnerable to physical and sexual violence
in Western societies and all the more so in the context of colonialism and enslavement,
continues to do so today. Currently, non-Western women – and other marginalized per-
sons of non-conforming gender performance – still are the most vulnerable migrants.
Their precarious position at the crossroads of multiple axes of inequality requires them to
negotiate their options for global mobility along the continuum ranging from prostitution
to marriage into which they have been defined since the sixteenth century. The title of
Barbara Ehrenreich and Arlie Russell Hochschild’s book Global Woman: Nannies, Maids,
and Sex Workers in the New Economy (2004) keenly summarized the main options that
the increasing feminization of migration offered to racialized women. Elaborating on
Rubin’s concept of ‘traffic in women’, Anca Parvulescu argues that, today, East European
women and women from the global South are ‘ “exchanged” so that they can do a lot of
the physical household work and the immaterial, caring labor traditionally performed by
a wife within the institution of marriage’ (Parvulescu, 2014: 2).
Unlike predominantly male wealthy investors, who can achieve global mobility in
exchange for a check, predominantly poor women, transgender persons and racialized
Others exchange themselves, i.e. offer their bodies, their emotional labor, housework, or all
of the above, for upward mobility through citizenship. Since marriage to the owner of a
Western passport provides one of the few legal and comparatively easy means of access
(as opposed to life-threatening illegal border-crossings), in some regions, tourism serves as
platform of options for all parties. Yet North–South tourism – and sex or ‘romance’ tour-
ism in particular (Pruit and LaFont, 1995) – is based on deeply unequal power structures.
Who can be a tourist and where to, and by whom s/he is being served, is related to highly
asymmetrical and colonial axes of stratification, deeply marked by racial and gendered
dimensions. Owners of a Western passport (with a medium or high income) can use their
citizenship privilege to travel to racially eroticized ‘fantasy islands’, e.g. to the Caribbean
(O’Connell Davidson and Sánchez Taylor, 1999; see also O’Connell Davidson, 2001).
In most formerly colonized regions, highly dependent on the tourism industry, romance
and/or sex are often part and parcel of the package dream holiday of Western tourists of all
genders.12 Against the backdrop of a long tradition of exoticizing and sexualizing the colo-
nial ‘Other’ (McClintock, 1995), Western men and women’s disadvantageous age, gender
and/or class positions are crisscrossed with the ‘cultural/racial capital of whiteness’ (Stam
and Shohat, 2012: 191) derived from their class and citizenship privilege as sex tourists to
a poorer country. Sex workers in the Caribbean, in turn, can transform their class and
citizenship disadvantage into erotic capital rooted in colonial and racialized erotic imagina-
tions of the black body and thereby gain financial advantage in a structurally unequal
encounter (Roth, 2013). In many places, tourism provides one the few ways of access to
hard currency, consumer goods or luxury products. In some cases, encounters with tourists
even result in such global mobility prospects as a holiday abroad through a tourist visa,
permanent residence, up to marriage and a Western passport. However, the non-Western
partners are highly dependent on their privileged passport partners, and women are, again,
particularly vulnerable to physical, psychic or sexual violence.13
legally, while the equally large group of Austrian men married to Asian women is not
listed as suspicious and is hardly exposed to observation and intrusion. Moreover, age
difference is only listed as suspicious when the Austrian woman is considerably older
than her partner, revealing a deeply patriarchal bias. The fact that, since 2006, the couple
has to prove a regular income of more than €1200 per month lowers the chances for low-
income groups.
If Germany and Austria provide examples of the criminalization of migrant practices
to subvert jus sanguinis arrangements, the Americas, where jus soli has historically under-
pinned colonial settlement, offer a different set of possibilities to migrants. Marriage is a
particularly attractive option for women in border regions, such as those crossing the south-
ern border to Mexico from Guatemala. Many of them eventually abandon their initial plan
to continue all the way to the US along highly insecure paths and therefore increasingly are
exposed to sex crimes and enforced prostitution. Women stuck in the border region between
Guatemala and Mexico often work as ‘ficheras’ in bars, which not only offers them more
money than other available jobs to pay for their further journey or send remittances to their
families back home, but also increases the possibility of meeting a potential husband with a
Mexican passport (Quintino et al., 2011: 107). A number of women stuck in a migrant shelter
in this border region get pregnant, as a baby born on Mexican soil promises permanent
residency for the mother (and the father), as well as access to health care and education
(Guevara González, n.d.; Guevara González, 2015). In the US, the same strategy is currently
subject to sanctions and criminalized through the ethnic and racial profiling of immigrants
who come to the country to give birth, and are accused of having abused the right of soil.
Immigration hard-liners describe a wave of migrants crossing the Mexican–US border in the
advanced stages of pregnancy to have what are dismissively called ‘anchor babies’ (Lacey,
2011). The term refers to the automatic granting of US citizenship, in virtue of the 14th
Amendment, to children born on US soil, who can in turn secure citizenship for their parents
upon reaching the age of 21. Contrary to their media depiction as a monstrous ‘threat to the
nation’, many immigrants arriving to give birth in the United States are frequent border
crossers with valid visas who travel legally in order to take advantage of better medical care.
Moreover, although the total US immigration population continues to grow, unauthorized
immigration has slowed in the past decade (Pew Research Center, 2013). Nevertheless,
several Republican attempts at amending the US Constitution since 2010 have mobilized
terms like ‘anchor babies’, ‘birth tourism’ and ‘accidental citizens’ in order to end the auto-
matic granting of citizenship, arguing that the provision attracts high numbers of unauthor-
ized migrants (Feere, 2010; Huffington Post, 2013). In 2014, the state of Texas stopped
issuing birth certificates to children born on its territory to undocumented migrants and
bearers of a Mexican passport without a valid US visa, making it impossible for parents to
authorize medical treatment for their children or enrol them in daycare or school (Texas
Observer, 2015). States are highly active and creative in restricting immigration – often
abusively, as shown in the case of the violation of the right to family life and privacy for
bi-national couples in Austria and Germany or of existing citizenship law for Mexican
mothers in the US. By withholding social protection, health services and other rights from
undocumented migrants and other non-citizens, states perpetuate the colonial entail of citi-
zenship rights for their own nationals, while the highly unequal global system of social
reproduction keeps producing ‘stratified workers and stratified mothers’ (Herrera, 2010).
Outlook
Investor citizenships and the commodification of marital options detailed above are
similar strategies of eluding the ascription of citizenship through recourse to the market.
Attempts to beat the ascriptive logic of citizenship at its own game – i.e. by undermining
the institution of birthright citizenship through migration or transnational marriage – meet
with critique, sanctions and criminalization from supra-state and financial institutions,
encounter legal countermeasures, and are policed along racial, ethnic and gender lines.
Citizenship, based on colonial racial and ethnic constructs, and gender, which has been
reconfigured during colonialism, are key components of the persistence of global in-
equalities today. As affluent middle-class families in the global North come to depend on
migrants from poorer regions to provide childcare, domestic work and sexual services,
Ehrenreich and Hochschild contended, ‘a global relationship arises that … mirrors the
traditional relationship between the sexes’ (2004: 11). Through the corresponding gender-
ing of globalized domestic work and globalized social reproduction, the global North
takes on ‘the role of an old-fashioned male, provider and successful in the public sphere
but in need of care in every other way, while countries of the South take on the role of the
traditional female, caring and nurturing and even sexually available, filling in the “care
deficit” that has emerged in the North’ (Dobrowolsky and Tastsoglou, 2006: 17). This was
the process that, in the 1970s, subsistence theorists had described as ‘housewifization’,
whose prototypical worker was the world-housewife or the worldwide ‘industrial reserve
army’, the ‘marginal mass’ – not, however, the proletarian. For analysing the continuities
of such junctures with regard to processes today, Floya Anthias has suggested a ‘trans-
locational lens’ that shifts attention away from fixed social positions, usually conceived
within a nation-state framework, and points to the transformation of interdependent and
mutually reinforcing inequalities over time and space (see Anthias, 2015).
The birthright transmission of citizenship and the gendered division of labor
(reinforced in the form of global care chains, transnational adoption, surrogacy and
sex tourism) are therefore no striking exceptions to a trend away from ascription, but
key mechanisms of global stratification. It is in the context of global colonial capital-
ism and its corresponding logic of accumulation that the institution of citizenship
emerged; the economic and political interests of the main European colonial powers
that pioneered it were essential in defining its central features, particularly its gen-
dered and racialized dimensions. As long as the gendered and racial dividend of citi-
zenship allocation still translates into the systematically unequal allocation of life
chances, the modernity of the institution of citizenship will be the very proof of its
coloniality.
Funding
Preliminary research for the argument unfolded here benefited from fellowship support to both
authors from desiguALdades.net, a Research Network on Interdependent Inequalities in Latin
America funded by the German Ministry of Education and Research (BMBF).
Notes
1. The following two sections summarize and build on arguments previously published in
Chapters 2 and 6 of Global Inequalities Beyond Occidentalism (see Boatcă, 2015).
2. Silvia Federici (2004) additionally sees the progressive delegitimization of abortive and con-
traceptive practices as part of a strategy of containing unproductive sexuality and thus sub-
jecting the female body to the capitalist dictate of the reproduction of labor power. Through
the control of women’s reproductive capacity, ‘the proletariat was expropriated from its body
as it had been expropriated from the land, where expropriation refers both to the destruction
of specific faculties and their subordination to the aims of the nascent system of production’
(Federici, 2004: 16). For a similar argument, see also Linebaugh and Rediker (2000: 92).
3. Sabine Broeck describes the process as follows: ‘enslaved African-origin female beings
never qualified as women (because of their non-humanness, it followed logically) in the
Euro-American modern world, and therefore were not interpellated to partake in the ongo-
ing social construction and contestation of gender … – a category that would have enabled a
black female claim on social negotiations did not apply to “things”, to what was constructed
as and treated as human flesh. Moreover, that very category gender emerged in western
transatlantic rhetoric precisely in the context of creating a space for white women, who
refused to be treated like slaves, like things’ (Broeck, 2008: 15).
4. For views according to which the Enlightenment ideal of female passivity and domesticity
was a result of the rise of scientific, especially medical knowledge of the human body and of
the subsequent naturalization of sex differences in the eighteenth century, see Nye (1993) and
Schiebinger (2004). For the counterargument that traces the naturalization of women’s repro-
ductive role back to the sixteenth century, and sees eighteenth-century science as a latecomer
to this task, see Federici (2004) and Pelizzon (1998).
5. Tellingly, Saint-Domingue’s first constitution as the independent republic of Haiti aimed at
erasing precisely the racial differences that had made such hierarchization by skin colour
possible. To that end, it ruled that all Haitians, including white women and members of natu-
ralized ethnic groups such as Germans and Poles, were to be referred to by the generic term
‘black’, thus turning the term into a political rather than a biological category (see Fischer,
2004: 233). The constitution thus seized upon the above-mentioned mechanism of deriving a
universal term by generalizing from a particular one, but in so doing reversed the prevailing
hierarchy. As Fischer (2004: 233) cogently remarked, ‘Calling all Haitians, regardless of skin
color, black … both asserts the egalitarian and universalist institutions and puts them to a test
by using the previously subordinated term of the opposition as the universal term.’
6. Practices and laws concerning the marriage of enslaved persons varied widely, in the US
slaves were, for example, denied legal marital status (see Goring, 2006). Being considered the
property of their owners and excluded from the social and even human (including gender) status
of the slave societies, enslaved persons were exposed to often arbitrary rules and practices.
7. For a recent comparison of taboos and legislation against interracial unions in nineteenth-
century Cuba, Brazil and the United States, see Morrison (2010).
8. Depicting ‘exchanged’ women like the Malinche in Mexico as representing ‘the incorporation of
the Conquest’ – the Other as feminized – Franco argues that such colonial practices of traffic in
women provided the ‘necessary services both sexual and practical’ for peopling the New World
and founding a mestizo population (Franco, 1999: 76). She also sees these practices as ‘the begin-
ning of the end of the gift economy’ and the transition to contract exchange (Franco, 1999: 74).
9. ‘Along with all other peoples variously designated as backward, degenerate, uncivilized, and
retarded, the Orientals were viewed in a framework constructed out of biological determinism
and moral-political admonishment. The Oriental was thus linked to elements in Western soci-
ety (delinquents, the insane, women, the poor) having in common an identity best described
as lamentably alien. Orientals were rarely seen or looked at; they were seen through, analyzed
not as citizens, or even people, but as problems to be solved or confined’ (Said, 1979: 207).
10. As Quijano notes, these policies were not straightforwardly assimilationist but retained their
colonial overtones: ‘However, said strategy never ceased to alternate and combine with
discriminating policies against the “indio” as well as with the othering of the “indio”. In this
way, de-Indianization could not encompass the majority of the “Indian” population, which
could only incorporate itself or be incorporated to a partial, precarious and formal extent in the
process of nationalizing society, the culture, and the state’ (Quijano, 2006: 201, our translation).
11. Using the inequality data for six countries interlinked through considerable migration flows,
Korzeniewicz and Moran are able to show how anyone in the poorest seven to eight deciles of
Bolivia or Guatemala can move up several global income deciles by migrating to Argentina or
Mexico, respectively, and gaining access to the average income of the second poorest decile
there. Even more strikingly, anyone but people in the wealthiest decile in both Argentina
and Mexico is able to skip several global income deciles by entering Spain or the United
States’ second poorest decile through migration (Korzeniewicz and Moran, 2009: 108ff.).
In all these cases, the upward mobility of migrant populations is considerably higher than
either the within-country educational attainment or the economic growth of one’s country
of origin would have allowed during a lifetime (judging by the most successful examples of
economic growth, such as South Korea in the 1980s or China today).
12. See Sánchez Taylor (2010) on sex tourism research and sex tourism and inequalities.
13. There are also marriage agencies offering the ‘racial, erotic’ capital of (mostly) females from
poor countries in exchange for the ‘citizenship’ capital of men (and women) in the global
North who do not easily find a partner back home or are looking for specific characteristics
in a partner (e.g. a decisively younger, devoted, caring, sexy partner to be chosen from the
agencies’ catalogues).
14. Dobrowolsky and Tastsoglou underscore the experience of gender exclusion shared by women
despite ‘women’s multiple, intersecting identities (such as race, ethnicity, class, ability, sexual
orientation, age, religion and so on)’. For migrant women in particular, these exclusions come
with limited citizenship rights: ‘women (im)migrants frequently find themselves in citizen-
ship limbo, or with various kinds of “partial citizenship” as is the case for temporary workers
… with very few if any rights to draw upon. This, in turn, can lead to further deprivation
and impoverishment, and an array of abuses or forms of exploitation. … They are affected
by structural processes (global, transnational, national and local) as they seek safe passage
across borders, or eke out an existence in borderlands, or struggle to re-establish professional
careers in new contexts when immigration regulations construct them as dependents on a
male breadwinner’ (Dobrowolsky and Tastsoglou, 2006: 5, 6).
15. Interestingly, marriages between German (or other) citizens and persecuted Jews (who were
deprived of their citizenship) are now being referred to as ‘Schutzehe’ (‘protective marriage’)
(see Messinger, 2012).
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Author biographies
Manuela Boatcă is Professor of Sociology with a focus on macrosociology at the Albert-Ludwigs-
University Freiburg, Germany. She was Visiting Professor at IUPERJ, Rio de Janeiro in 2007/2008
and Professor of Sociology of Global Inequalities at the Latin American Institute of the Freie
Universität Berlin from 2012 to 2015. Her work on world-systems analysis, postcolonial and deco-
lonial perspectives, gender in modernity/coloniality and the geopolitics of knowledge in Eastern
Europe and Latin America has appeared in the Journal of World-Systems Research, Cultural
Studies, South Atlantic Quarterly, Political Power and Social Theory, Berliner Journal für
Soziologie, Österreichische Zeitschrift für Soziologie, Zeitschrift für Weltgeschichte and Theory,
Culture and Society. She is author of Global Inequalities beyond Occidentalism (Ashgate, 2015)
and co-editor (with E Gutiérrez Rodríguez and S Costa) of Decolonizing European Sociology:
Transdisciplinary Approaches (Ashgate, 2010) and of Handbuch Entwicklungsforschung (with
K Fischer and G Hauck) (Springer, 2015).
Julia Roth is postdoctoral researcher and instructor of the BMBF project ‘The Americas as Space
of Entanglement(s)’, Centre for Inter-American Studies, Bielefeld University, Germany. Among
her research interests are gender studies, critical race studies, postcolonial and decolonial
approaches, critical whiteness and intersectionality, with a focus on the Caribbean. Her current
research project is titled ‘New Media – Persistent Inequalities? Trans-American Politics of Gender
and Race’. She is author of Occidental Readings, Decolonial Practices: A Selection on Gender,
Genre, and Coloniality in the Americas (WVT, 2014) and editor of Lateinamerikas koloniales
Gedächtnis. Vom Ende der Ressourcen, so wie wir sie kennen [Latin Americas Colonial Memory:
On the End of Resources as We Know Them] (Nomos, 2015).
Résumé
Toute une tradition théorétique occidentale sur la citoyenneté voit cette dernière
comme une institution moderne et progressive aidant à surmonter les particularités
d’une origine sociale inégale. S’opposant à cette vision d’une tradition scientifique occi-
dentale (et principalement masculine), cet article est structuré autour de deux argu-
ments. Le premier est que l’institution de la citoyenneté en Occident se soit développée
par le biais d’une exclusion légale (et physique) de populations non-européennes, non-
blanches et non-occidentales des droits civiques, politiques, sociaux et culturels (ces
derniers ayant, en plus, été filtrés selon le genre des individus). Le deuxième est que la
citoyenneté et le genre soient les facteurs les plus décisifs pour rendre compte des
inégalités extrêmes entre les individus des pays riches et pauvres du 21ème siècle.
L’acquisition de la citoyenneté liée à des formes de racialisation, de sexualisation et de
précarisation est illustrée à partir d’exemples d’allégations d’abus de lois de citoyenneté
concernant des mariages ou des naissances dans des pays dépendants principalement du
droit de sang et droit de sol.
Mots-clés
Inégalités mondiales, mobilité sociale, citoyenneté, genre, colonialité, migration
Resumen
Toda una tradición occidental de la teoría de la ciudadanía ha considerado a la ciu-
dadanía como una institución moderna y progresista que ha ayudado a superar particu-
laridades de orígenes sociales desiguales. Contrario a las afirmaciones de la tradición
académica occidental, que está compuesta principalmente por hombres, el artículo
sostiene, en primer lugar, que la institución de la ciudadanía se ha desarrollado en
Occidente a través de la exclusión legal y física de los derechos civiles, políticos y cul-
turales pertenencientes a las poblaciones que no son europeas, blancas u occidentales.
Estas exclusiones, y por tanto, la ciudadanía como tal, han sido históricamente atrave-
sadas por el género. En segundo lugar, el artículo sostiene que la ciudadanía y el género
son los factores determinantes principalmente responsables por las desigualdades
extremas entre los individuos de los países ricos y pobres en el siglo XXI. Las diversas
manifestaciones de racialización, sexualización y precarización que están ligadas a la
adquisición de la ciudadanía y movilidad social se ilustran con ejemplos de algunas prác-
ticas que subvierten la ley de ciudadanía mediante el matrimonio o el nacimiento en los
países que dependen principalmente del jus sanguinis y el jus soli.
Palabras clave
Desigualdades globales, movilidad social, ciudadanía, género, colonialidad, migración