And territories, minor outlying islands, and a federal district.

>No, it wasn't.

Yes it was, the opinion of the court held that those born in American Samoa were born in the United States.:

>“Plaintiffs, having been born in the United States, and owing allegiance to the United States, are citizens by virtue of the Citizenship Clause of the Fourteenth Amendment,” Waddoups added.

It was eventually overturned, but the fact is a court's decision included American Samoa as "in the United States."

The point is courts can decide what is considered "under the jurisdiction there of" much as there can decide what is considered "in the United States." All it takes is another case to completely throw out the Insular Cases.

>In United States v. Vaello Madero, No. 20-303, 596 U.S. ___ (2022), Justice Neil Gorsuch concurred and noted that "The Insular Cases have no foundation in the Constitution and rest instead on racial stereotypes. They deserve no place in our law."[32] Gorsuch argues that the Court must find a case to overrule the Insular Cases which were "based on racist assumptions and imperial ambitions."