Although I am not a thorough scholar of constitutional law, i will suggest that an examination of the Forteenth Amendment might give some clue to the distinction.

This from

Amendment 14
1. All persons born or naturalized in the United States, and subject to the
jurisdiction thereof, are citizens of the United States and of the State
wherein they reside. No State shall make or enforce any law which shall abridge
the privileges or immunities of citizens of the United States; nor shall any
State deprive any person of life, liberty, or property, without due process of
law; nor deny to any person within its jurisdiction the equal protection of the

 [emphasis mine, for purpose of this discussion]