Due to the increasing tensions between Russia and Ukraine, the Polish government is calling up all reserves but however that has been deemed insufficient. According to Polish sources at the Polish embassy in Washington DC, an informal agreement has been reach between President Biden and the Polish government to all Poland to call up dual male citizens of both countries that reside in the US for service in the country’s military. While some have argued in the media that such an agreement would be unconstitutional, there is a lot of precedent allowed this between allied nations. In 1940, in Birchfield v. Simpson, the US Supreme Court ruled the UK could draft their dual citizens residing in the US due to the previous alliance between the US and the UK in World War I. As a result of this decision approximately 2,300 British dual Citizens were detailed by the Department of defense and sent to Canada and enlisted in the UK military. This decision was upheld in 1968, when the South Vietnam government did the same thing to 600 dual male citizens in the US, in Phung v. Hardwick, and also in 1994, in Rosenthal v. Gerry, when Israel had 125 US dual citizens detained and sent to Israel to serve in the IDF. The agreement between President Biden and the Polish government will apply to all Polish dual Citizens in the US between 18 and 39. They will be called up and possibly detained and transported to Poland.